Sustainable development principles

We have been growing rapidly, systematically increasing our production capacity, developing infrastructure. Our products are sold on new export markets and the team of the Śnieżka Group has continued to expand. Concentrated development processes take place in the environment of care for transparency of rules and procedures which is embedded in our operations and the resulting regularity and consistency of processes. In addition, we have been constantly developing a multi-dimensional monitoring of non-financial activities which is confirmed by the indicators analysed further in this report.

What are we driven by?

As a Group, we have been coordinating the actions taken at various levels of the organization, making sure that the rapid rate of growth does not undermine the principle of sustainable development which has been implemented through, among others:

  • taking care of our employees’ rights, safety and development;
  • maintaining quality of production processes and resulting products;
  • rational use of natural resources;
  • ensuring transparency of market activities;
  • creating projects to support equalization of opportunities.

In our day-to-day activities we strive to ensure that the rate of change connected with our market development does not undermine the key aspects of sustainable development, i.e. care for the natural environment, as well as direct and indirect impact of our activities on individuals and local communities in which we conduct our business operations.

In the context of our activities, the aspects of sustainable development are reflected in the policies and indicators described further in this document. The Group’s key policies are described in the following chapter. Their implementation is monitored and they are subject to periodic reviews, also as part of the due diligence procedures. All detailed internal documents, such as policies, regulations or instructions remain compliant with the Group’s policies.

As regards materiality assessment conducted in 2017, key areas of operations were identified, which, after the selection of relevant ratios, have been described in detail herein.

The key areas of sustainable development in the Group are defined as: People, Environment and Quality. The efficient management of strategic goals supported by the values and the principle of transparency plays an important role in the responsible reacting to the challenges defined with respect to these areas.

Area: People


The members of our staff are the strength of our organization. Their commitment and ability to act in an innovative manner are the basis of our ideas and solutions that contribute to the establishment of a competitive advantage. By ensuring proper working conditions, safety and development of our employees we create a friendly and inspiring work environment.

The defined aspect of sustainable development is also understood as our impact on the the community residents, in the vicinity of which companies belonging to the Group operate. On a daily basis we do make sure so that our activities do not affect their comfort of life negatively, and by creating new jobs and creating our own social initiatives, we contribute to minimizing social exclusion in the areas defined by us. Examples of such activities are described in the “Social initiatives” section.

At the global level of the society at large, we strive to ensure that our products are a source of satisfaction and inspiration for customers on all our markets.

Those activities include the development of products which are safe to health and products which improve the quality of indoor air.

Area: Quality


Our philosophy is based on the principle of the best product quality and the best production standards. The path of every product – from the concept board, through technological, production, logistical and commercial processes – is strictly monitored and subject to multi-dimensional control. Our objective is to deliver best quality products which meet rigorous standards, are durable and robust.

The focus on quality permeates all processes in our operations. It is also reflected in the transparency of our market and communication activities, as well as in the dedication to high standards of cooperation with our shareholders, trading partners and counterparties.

Area: Environment


In creating our technological solutions, manufacturing products and continually developing our own infrastructure, we strive to ensure that the operations of the Group meet the highest environmental standards. This approach applies to both our products’ impact on the environment, as well as the production process itself, including how we use the natural resources. By the continuous monitoring of the environmental aspects of our operations, and following legislative developments, we ensure responsible management of our plants and create in-house best practices as regards the protection of nature. The same applies to our products, which not only meet the highest external standards, but are also subject to rigorous internal environmental safety requirements.

What is our care for due diligence based on?

Description of specific due diligence policies and procedures and outcomes of their application

FFIL ŚNIEŻKA SA, as a listed company, maintains efficient systems of internal control (ISO), risk management and compliance. The compliance monitoring system serves the purpose of review of compliance of all areas and aspects of the company’s operations with the applicable laws, internal regulations and voluntary standards, including:

  • Transnational provisions;
  • Domestic law – acts and lower-ranking documents;
  • Corporate internal regulations:

    - The Articles of Association, organizational regulations, procedures, etc.

    - Soft law (voluntary standards).

A number of processes implemented within all areas of the Śnieżka Group’s operations are regulated pursuant to many policies, procedures, instructions and regulations. Thus, establishing the framework of the Group’s operations, we do maximize their efficiency, consistency and transparency.

The key due diligence policies and procedures will be presented in the sections that follow, while this chapter is dedicated to the general practice indicating the Group’s care for observance of the strictest due diligence standards in all aspects of the organization’s activities. The Book of Organizational Values (referred to in item 3.1.9) adopted by the Parent Company and defining the principles of due diligence with reference to six values set out and described therein, plays a significant role with this respect.

Each of the documents adopted in the form of a policy, procedure, instruction or bylaws is made available to employees via the internal document management system, in a separate module. Publication of any new files is announced in advance in a communiqué specifying the scope and subject of the document Blue collar workers with no access to the system are informed by their superiors and/or via internal media.

The access to knowledge of new documents is essential for their appropriate implementation. In the case of documents considered to be of key importance, the employees are obligated to confirm their knowledge of such documents with a signature or a confirmation in the system.

Thanks to the internal document management system and other electronic solutions implemented in the group, it is possible to rapidly develop the due diligence procedures, establishing new practices which constantly improve the Group’s efficiency and transparency. Examples of such solutions include, inter alia:

The electronic system of internal document management consisting of the following modules:

  • a module of electronic management of contracts with a function of assignment of the document owner and archiving the final version which contributes to transparency of the process of contract elaboration;
  • a module of electronic recording of incoming and outgoing correspondence ensures a reliable and a smooth flow of correspondence;
  • a module of electronic management of invoices provides for the possibility of a flexible assessment of business partners, and assures timeliness of payments;
  • module for reservation of conference rooms, business cars and other fixed assets made available to the employees for shared use improves their availability and efficient use;
  • a system of electronic complaint handling (Guarantee Service Centre) which ensures shorter handling times as well as the process transparency and archiving;
  • an electronic book of orders making it possible to monitor task delegation and reporting;
  • an electronic book of controls, i.e. archives in an electronic form of all controls carried out at the Company;
  • an electronic book of guests where all persons who visit the Company’s facilities are recorded.

Other internal systems:

  • a system of registration of all incoming and outgoing goods ensures an accurate assignment and control over circulation of goods and materials;
  • a system of registration and internal circulation of applications addressed to board meetings;
  • a supplier-acquisition system, the so-called procurement platform, supports cost optimization thanks to selection of suppliers offering goods at best prices;
  • the so-called auction portal where the employees are offered the possibility to buy company products and equipment at attractive prices;
  • a system of internal information in the form of a newsletter, communications displayed on screens located in production facilities and a printed employee quarterly magazine; “In Colour”;
  • a system of electronic registration of holiday leaves and business trips ensures control over a proper performance of management and settlement tasks.

The Group puts great emphasis on a continuous search of new solutions to optimize its internal and external processes. In March 2018, the Company commenced cooperation with SAP Sp. z o.o., to exchange and improve IT systems and tools used in the Company. As a result of the changes adopted, create intuitive electronic solutions will be in place, both in the scope of the above-described and newly defined processes. The duration of the project implementation within the scope of software development and implementation established by the parties is expected to last 3 years. The program, which the company called "Change IT", covers activities in which several projects are being implemented in parallel, with several project teams working on it.

In September 2018, implementation and testing were completed, and at the beginning of October, a new reporting system for sales and resale data based on the SAP CAR (Customer Activities Repository) tool was launched. In October 2018, work was also begun in the next two key projects, i.e. as part of replacement of the existing ERP IFS system into ERP SAP (SAP S/4HANA project) and as part of the implementation of a new warehouse management system, i.e. the launch of the SAP eWM system.

In 2018, the eCommerce B2B team completed the design phase and proceeded to the implementation phase of the new sales and electronic cooperation system for business clients. The launch of this tool is scheduled for March 2019. At the same time, a customer relationship management system (CRM - Customer Relationship Management) based on the SAP Hybris C4C product and a tool supporting marketing activities of Hybris Marketing are to be launched.

The application of due diligence procedures at the level of the entire Group takes place in all departments in relation to the issues managed by them. The source of the due diligence principles are numerous instructions, thanks to which it is possible to ensure continuity and quality of processes, also in volatile market conditions, or when changing personnel handling a given case.

By saving principles such as "Business efficiency" or "Innovation" in the Book of Organizational Values, and taking into account the fact that each employee of the Parent Company is subject to evaluation of their implementation, the fact is constantly motivating members of the Śnieżka team to look for new solutions optimizing due diligence, both at the level of the Company and the entire Group.

Key policies

Description of due diligence policies and procedures applied by the Company in reference to employee issues

Description of the policies and due diligence procedures applied by the Group in relation to employee matters

The most important document defining the basics and principles of human resource management in the Śnieżka Group is - based on organizational values - Personnel Policy of the Śnieżka Group. This document, closely connected with the adopted business strategy and the idea of responsible business, is a guide for actions undertaken in the field of employee matters. The fundamental assumption of the personnel policy is the value that each employee taken on in the Group contributes to the organization. Diversity of personality, knowledge, experience, beliefs, interests and passions of our employees provides us with great potential, is our capital and largely influences our successes. The unwavering belief that it is the value of people that translates into the organization’s competitiveness, it makes us want to invest in our employees and create an organizational culture that will support their development. Transparent personnel policy, appropriate procedures and processes in place help us manage this area.

Personnel Policy of the Śnieżka Group is an integral part of the Group's policy and its development strategy. It imposes on the Company and its subsidiaries obligation to carry out such activities that will ensure:

  • access to qualified staff that meet expectations both in the area of competence and compliance with organizational values;
  • retention of employees with key and critical skills, talents and potential - by building a positive image of an attractive employer and creating value for the candidate and employee;
  • high employee involvement as part of creating a competitive advantage - thanks to creating space for broadly understood professional and personal development, exchange of knowledge and experience as well as openness to undermining status quo, embracing changes and introducing innovations;
  • organizational effectiveness at the Capital Group level - thanks to the introduction of new technologies, unification of processes and integration of functions and employees.

All the activities concerning the human resources management are conducted in accordance with the applicable law, pursuant to the Labour Code. In the area of HR management, the due diligence procedures include the documents such as, inter alia,: The Labour Bylaws, the Compensation Bylaws and the Organizational Bylaws, which pertain to the basic issues related to the employment by the Company as well as Bylaws of the Company Social Benefits Fund.

The Human Resources Management Department, separated in the organizational structure of FFiL Śnieżka SA, is responsible for acting in accordance with the legal guidelines. It takes care of transparency of activities, compliance with personnel policy and the principles contained in bylaws and regulations, as well as establishes internal procedures and policies that specify the procedures in individual processes related to the employee's life cycle in the organization.

Detailed policies concerning employee matters operating within the Company and their main assumptions:

  • The recruitment and employment policy is based on high anti-discrimination standards. It is based on the assumption of equal treatment irrespective of gender, age, health, sexual orientation, religion, marital status or country of origin and ensures equal opportunities. An important element is protection of personal data. We review compliance with the assumptions - subjecting the recruitment and employment process to cyclical assessment of candidates and employees, as well as examining their experience.
  • The training and development policy assumes that all employees regardless of age or gender can benefit from training and development activities. The main criteria for the availability of training are the organization's business needs and opportunities, the need to have specific knowledge, authorizations, skills or competences on a particular position, as well as development needs diagnosed in the assessment process, consistent with the scope of activity of a given department, position or employee potential.
  • The remuneration policy ensures a consistent wages system based on job valuation (grading categories assigned to individual organizational positions) and analysis of market remuneration in the manufacturing sector. The basis for valuation is the assessment of responsibility of individual positions.

The Company plays a predominant role in achieving the goal defined in the Personnel Policy of the Śnieżka Group. The solutions in subsidiaries are implemented gradually which allows to transfer the Polish market models into foreign ones on a regular basis.

Description of policy and due diligence policies and procedures applied by the Company

The Śnieżka Group’s operations are driven by its equal treatment policy (anti-discrimination and mobbing). In Poland, in the context of the issue of respect for employee diversity, the basic legal act is the Labour Code (Journal of Laws of 1974 No. 24 item 141). The internal documents regulating work of specific companies comprising the Group have been developed on the basis of the act in question.

When appointing the company’s management and its key managers, we strive to ensure versatility and diversity, especially in the area of gender, education, age and professional experience. A decisive aspect here are above all high qualifications and substantive preparation for performing a specific function.

The equal treatment policy is for us the first step to build diversity management within the Śnieżka Group, which is why we commit ourselves to be driven by principles of equal treatment and to counteract all forms of discrimination, both among our employees and associates throughout the entire value chain, as well as to promote and disseminate them to all stakeholders of the organization.

Our commitments include:

  • Creating an organizational culture that ensures respect for diversity and helps the employees feel respected and appreciated, as well as supported in developing and fulfilling their professional potential. We carry out it by providing a friendly, tolerant 'organization language', supporting employee initiatives associated with equality practices in the company or openness to employing people who are socially excluded or threatened with marginalization in the labour market.
  • Full compliance with anti-discrimination and anti-mobbing policies and procedures;
  • Shaping human resource management in a manner to include a policy of equal opportunities in all internal documents specifying codes of conduct in individual processes as far as the employee's life cycle in the organization is concerned;
  • Communication to employees regarding the diversity policy implemented by the Group, including by informing employees about the diversity policy and conducted media activities available to employees as well as providing employees with training on preventing anti-discrimination and mobbing;
  • Implementation of a system for monitoring, analysing, measuring results and reporting diversity management, including anti-discrimination and anti-mobbing activities, promotions, training and remuneration by age and gender, employee turnover or complaints they lodge.

The diversity policy of the Śnieżka Group applies to FFiL Śnieżka SA and all its subsidiaries. By creating an inclusive environment, we want to make the most of the diversity potential.

Description of policy and due diligence policies and procedures applied by the Company in reference to respect for human rights

In its operations, the Śnieżka Group is driven by a policy preventing human rights violations by observing applicable law. In Poland, the issue of respect for employee diversity is regulated by the Constitution of the Republic of Poland and the Labour Code (Journal of Laws of 1974 No. 24, item 141). On the international level, the Universal Declaration of Human Rights (of 1948) is the most comprehensive legal act pertaining to the area of human rights. The list of basic, universally recognized human rights is contained in the International Charter on Human Rights. The source of standards in this respect is also the Declaration on basic principles and rights at work adopted by the International Labour Organization (ILO), which defines the fundamental human rights in the work environment.

By virtue of these legal acts and conventions, internal documents were drawn up which regulate work of individual Group companies, the most important of which is the Human Rights Policy of the Śnieżka Group. It sets out principles of actions and behaviours related to human rights within the Group, including our supply chain and rapport with our stakeholders.

The Group's human rights policy supplements and consolidates aspects of human rights included in other policies, guidelines and other documents regulating the operations of the Group companies.

If the Group's policies, procedures and obligations towards other parties are more restrictive than those in force in a given country, we put our standards before them. If local regulations are less restrictive than the Universal Declaration of Human Rights, we make every effort to develop appropriate policies in the Group, guided by our policy.

The Śnieżka Group respects human rights in a universal dimension, without valuing them. However, due to the transparency of our commitments and their availability to our stakeholders, we particularly want to highlight the following areas of our commitment to counteracting human rights violations (we also require this from our business partners):

  • Occupational health and safety – we manage employee risks in such a manner to prevent the possibility of accidents at work;
  • Ensuring freedom of assembly – we understand freedom of assembly in the business sector as above all the opportunity for employees to freely express their opinions and attitudes on matters related to their work. We do not limit employees' right to associate;
  • Elimination of exploitation – we undertake to promote a work environment free from all forms of harassment, exploitation, abuse and violence in accordance with the definitions used in the regulations of each country, where we conduct our business;
  • Compliance with employment conditions – we comply with the provisions regarding employment conditions, including the provisions on basic working time and overtime, health and safety at work, adequate remuneration, as well as the arrangements made with employee representatives;
  • Prevention of discrimination – we are committed to ensuring that every employee and potential employee is treated fairly and with dignity. No cases of discrimination based on race, colour, sex, sexual orientation, age, religion, ethnicity, national or social origin, property status, political or other views, disability, birth or other aspects will be tolerated;
  • Respecting the rights of local communities – we are committed to respecting the rights of local communities, respecting their subjectivity, willingness to self-determination and all their legitimate rights. As part of this commitment, we take adequate security measures to minimize negative impact on local communities and the natural environment.

Description of policy and due diligence policies and procedures applied by the Company in reference to natural environment

The Group’s Quality, Environment and Health and Safety Policy is the document encompassing the issues of environmental protection and quality. With this respect, the following values are considered to be critical: “Responsibility and commitment” and “Strategic outlook”. All product solutions designed within the Group are created with due care, with responsibility taken for both the product and the environmental impact of its production. Such approach is embedded in the production technology itself and all related processes.

In respect of the adopted assumptions, bearing in mind the continuous technological supervision over the properties of raw materials and finished products with a view to ensuring their compliance with the eco-label requirements, the companies of the Śnieżka Group endeavor to reduce the impact of their plants on the natural environment. The environmental requirements are achieved by way of continuous formal and legal oversight and implementation of the obligations specified in environmental decisions. Furthermore, good practices in the area of environment protection include an efficient consumption of raw materials and energy, compliance with the regulatory norms for emissions of pollutants into the air, water and soil, rational management of waste and packaging, and the application of solutions that improve the operational safety of technological installations. New investment projects are based on state-of-the-art technologies.

The Group’s companies conduct on-going monitoring of their environmental impact, by maintaining registers of information and data on the scope of their use of the environment. They monitor consumption of energy and water, emissions of pollutants, generation of waste and packaging.

The Śnieżka Group has obtained the necessary environmental decisions, regularly pays its environmental fees, fulfills its reporting obligations and participates in the creation maintenance of a system for the collection, transport, recovery and disposal of waste generated from packaging introduced into the environment and participates in the conduct of educational campaigns. The Policy enforcement means that the Group takes efforts to strengthen its leading position in terms of product quality and pollution prevention, account being taken of safety and health at work.

The Quality, Environment and Health and Safety Policy has been established on the basis of the Company’s procedures that set forth the principles of due diligence in the respective areas. These include the procedures listed in the Book of the Integrated Management System: Formalization, Supervision over Documented Information, Identification of Environmental Aspects, Waste Management, Managing Emissions to Air, Water and Sewage Management, Environmental Emergencies, Management Review, Infrastructure Supervision, Management of Trade Agreement Preparation and Review Process, Customer Communication, Launch of New/Modified Products and Merchandise, Procurement, Supply Control, Production Process Management, Storage and Delivery of Finished Products to Customers, Supervision over Measurement and Monitoring Equipment, Product Control, Internal Audits, Non-Compliance Handling, and Remedial and Prevention Measures.

The EcoLogical Strategy of the Group

The main objective of the environmental strategy of the Śnieżka Group is the protection of natural resources by observing and implementing environmental and quality requirements, as well as creating appropriate attitudes and awareness of employees regarding environmental aspects. It was assumed that the highest quality of products, taking into account customer preferences, market conditions and care for the environment is an indispensable condition for the sustainable development of the Śnieżka Group.

The environmental objectives in the FFIL ŚNIEŻKA SA are addressed in accordance with the applicable legal requirements as well as the procedures and instructions. As part of the integrated ecological strategy and quality management, the Company puts particular emphasis on:

  • implementation of production and technological processes in accordance with legal regulations and based on modern recipe and technical solutions;
  • acting with respect for the environment, from the initial design of products and their entire life cycle to issues related to the protection of water, air, soil, noise, raw materials and energy;
  • conducting proper energy management through continuous monitoring of consumption and implementation of the EMS energy management system;
  • achieving energy efficiency by reducing the energy consumption of technological processes, which is confirmed by obtaining energy efficiency certificates (white certificates);
  • taking into account environmental protection requirements and the conditions for the proper use of its resources;
  • applying high quality components only from qualified suppliers;
  • research and development operations aimed at laboratory, experimental verification of assumptions for new industrial technologies in the areas of introducing new or improved environmentally friendly technologies and pro-ecological products;
  • strict control of each level of processes, permanent supervision over the ownership of raw materials and finished products in terms of meeting the requirements necessary for “ecolabelling”;
  • thorough studies of the final product, taking into account its impact on the natural environment;
  • applying high standards in the area of health and safety at work;
  • raising awareness of employees and other stakeholders in the area of environmental aspects of operations (on the risk of possible failures adversely affecting the environment, economic and ecological effects of waste generation and pollution, and the benefits of their reduction, including impact on the Group's prestige and competitive position);
  • rational waste and packaging management, considering recycling.

While conducting its operations, the Śnieżka Group endeavours to act in accordance with all applicable regulations.

Environmental policy of the Group

Due to the production nature of operations of the companies comprising the Śnieżka Group - which has a direct impact on the natural environment - the Group is required to hold operating licenses. The Group's production facilities in individual locations are strictly dependent on the permits, which set out specific conditions for using the environment.

The Śnieżka Group has obtained the necessary environmental decisions, regularly pays its environmental fees and fulfils its reporting obligations. The Group’s companies monitor their impact on the environment on an on-going basis, keeping records of energy and water consumption, emissions of pollutants, generation of waste and packaging. In addition, they conduct research on emissions of generated and discharged pollutants, they participate in developing a system for collecting, transporting, recovering or neutralizing packaging waste, and are involved in conducting educational campaigns.

The environmental policy of the Śnieżka Group applies to the entire Group, including all subsidiaries. Compliance with environmental policy provisions is monitored on a regular basis. The Group, expressing its commitment to complying with environmental policy provisions, at the same time ensures that if necessary it undertakes to immediately define and implement corrective actions.

FFiL Śnieżka SA in cooperation with subsidiaries will regularly assess any discrepancies between the provisions of its environmental policy and new applicable national regulations and other norms.

Description of policy and due diligence policies and procedures applied by the Company in reference to anti-corruption

From the perspective of anti-corruption activities, the most important values include: “People”, “Cooperation, respect and trust” and “Responsibility and commitment”, which mean that we all behave in a manner that shows how to create an atmosphere that favours cooperation and development of a culture of high engagement. Each member of our team accepts personal responsibility for actions taken and the manner of taking them. In business relations, we rely on fairness, honesty and transparency.

The Anti-Corruption Policy adopted by the FFIL ŚNIEŻKA SA is performed through:

  • training employees and informing them about issues connected with this policy;
  • spurring employees and associates to report violations of the organization’s policy and unethical behaviours;
  • notifying law enforcement authorities about any violations of applicable law.

We guarantee that none of the employees who report a detected or purported corruptive activity or actions connected with other economic malpractices cannot be for this reason dismissed from their jobs, relegated or suspended in their duties.

An employee with respect to whom explanatory actions are conducted and who is accused of taking corruptive actions or other economic malpractices will be guaranteed to have an opportunity to present his or her position. The Anti-Corruption Policy was prepared based on the principles of due diligence in force applicable at the Company to the extent to which such procedures are included as: Procurement, or manuals, including: The Manual on Selecting a Supplier of Investment Orders with Values Over PLN 25,000. A good practice with regard to the above is also the internal recommendation to compare price offerings of vendors of services commissioned between at least three entities. In addition, the Company develops solutions supporting anti-corruption activity, such as, e.g., the Procurement Platform referred to in the introduction to this chapter.

Description of policy and due diligence policies and procedures applied by the Company in reference to social issues

As far as the Social Commitment Policy is concerned, the key values for us are: “Responsibility and commitment”, “People” and “Cooperation, respect and trust”. Designing local and nationwide social projects in Poland and engaging in various initiatives, we take care that they correspond in a coherent manner to the values held by our organization.

In the Śnieżka Group, we understand the Social Commitment Policy as a document which describes precisely the areas and directions of the Group’s Companies involvement in this area. The overriding aim of all the actions taken is to design them in such a way that they are vehicles of the actual support and assistance in the selected areas, in accordance with the principle of equalling opportunities and sustainable development.

Social activities are performed by the Śnieżka Group’s Companies at two levels:

  • Nationwide – here the axis of the performed undertakings are authorship cyclic programs and social projects. These are supplemented by the support given by the Śnieżka Group Companies to nationwide projects and other pillars of social activity coherent with those defined in the Social Commitment Policy.
  • Local – here the axis of the performed undertakings are local authorship cyclic projects and social programs implemented by the Śnieżka Group Companies in their surroundings. These activities are supplemented by participation in local project, coherent with the pillars of social activity as defined in this policy. In the event of actions supported locally, the Śnieżka Group Companies follow also the principle of being open to the needs of local units and institutions, provided that these needs are not in conflict with the Group’s strategy and mission.

The policy defines principles of selecting supported initiatives at the nationwide and local levels and indicates that the selection is made on the basis of criteria adopted by the Companies, in compliance with the Community Activity Policy and well in advance, making it possible to include a given project to the quarterly activity plan of each Company. It is also allowed to have the Group Companies participate in local initiatives performed outside the area of their direct activity, provided that they correspond, in a distinguishing manner, to the main pillars of the Group’s social involvement.

What is regarded as due care procedures with regard to social issues, apart from internal regulations about reviewing applications, inquiries and requests, are published rules and regulations of initiated social activities that describe precisely the principles of support and define beneficiaries.

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