13.12.2022

To our stakeholders:

I am pleased to confirm that Ciech Group reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Dawid Jakubowicz
President of the Management Board of CIECH S.A.

Code of conduct of the CIECH Group

Since 11 May 2021, the new Code of Conduct of the CIECH Group has been in force. The Code, based on 4 fundamental values: responsibility, reliability, team and development, describes patterns of behaviour that are addressed to all employees and associates of our Group - regardless of the form of the concluded contract. The provisions of the Code are also addressed to our business partners and shareholders, because we are convinced that common values and principles constitute the foundation for effective cooperation and sustainable development based on respect for law and honesty. The Code is a guideline for all decisions made at each level of our Group. Accordingly, internal policies and procedures are based on the provisions of the Code, creating a unified system of corporate documents.
Below our code of conduct in the Human area is presented:
We care about our PEOPLE

We observe and safeguard human rights
The human being is of essence to us. Therefore, we attach great importance to business ethics, which is permanently inscribed in our strategy and everyday work. We are proud to be a signatory of the United Nations Global Compact declaration. We adhere to internationally recognised human rights and labour standards. Within our Group and in relations with the market environment, we support and promote freedom of association. We support the elimination of all forms of slavery, forced labour, child labour and the actual abolition of juvenile labour.

Safety at work is the highest priority to us
We care about the health and safe working conditions of our employees, customers, suppliers and subcontractors providing us with their services or staying on the premises of our plants. We are guided by the following two fundamental principles:
1. zero tolerance for people who violate occupational health and safety regulations and standards, and
2. ensuring high OHS standards.
We are continuously improving our activities in the area of occupational health and safety, among others, by modernising our production technology, taking into account, first of all, our employees’ safety. We systematically raise the awareness and qualifications of our employees in work safety, striving to eliminate accidents/injuries at work and occupational diseases. We promote the participation and involvement of employees in the continuous improvement of our occupational health and safety system, as well as in preventing potentially accidental events. The high health and safety standards that we have put in place apply not only to our employees, but also to our suppliers, subcontractors and any other individuals staying on our premises.

We ensure a friendly work environment, free from mobbing and other forbidden behaviour
Together, we build friendly relations based on partnership principles. We have the common responsibility for professional behaviour to ourselves and others. We listen to and appreciate our associates, we respect their opinions and decisions, even if they differ from ours. We create a work environment free from any mobbing, humiliating, ridiculing or isolating behaviour. We promote the principles of equal treatment in the recruitment, employment, remuneration and promotion processes in which our employees are involved. We take care of the dignity and friendly working environment for each employee, showing them due respect regardless of their religion, skin colour, beliefs, gender, sexual orientation or age.

We have zero tolerance for alcohol and intoxicants in the workplace
Work requires conscious thinking and the ability to respond quickly as the safety of other associates or our business partners depends on it. We do not tolerate alcohol or drugs in the workplace, either their consumption or being under their influence at the time and place designated for carrying out official duties.

1. The “Safe CIECH” project
In the second half of 2021, we launched a wide-ranging „Safe CIECH” project, which is to reflect our focus in the coming years on developing a safety culture, both in the area of the work environment and employee behaviour at every level of the organisation. As part of the project, so far, among others:
• We have updated the Health and Safety Policy to meet the requirements of ISO 45001. One of our companies, Ciech Sarzyna S.A. was the first company in the Group to receive a certificate of compliance with this standard in 2021. By 2024, we plan to raise the certification level of our production companies to 50%.
• We refreshed 10 safety rules of the CIECH Group, which are the basis for talks on safety, from which, among others, we are now starting internal meetings.
• We changed the structure of the Team responsible for safety and increased the number of its employees in the Head Office and in individual Companies by almost 50%.
• We have started a series of trainings on risk perception and reacting to dangerous situations (See? React!). In 2021, 50 people in managerial positions from two companies completed them in the form of a pilot programme, and in 2022 the programme will cover our other entities, a total of about 150 people. The next step will be to train all employees, including previously selected internal trainers in this process.
• We have developed a new, comprehensive procedure for reporting and analysing accidents with a focus on finding the system root cause.
• We conducted several health and safety competitions among our employees.
• We also try to celebrate our achievements in creating safe working conditions, which is why at the beginning of 2022 we distinguished several companies that did not report any „recordable” events throughout 2021.

Due to further improvements in the coming years, we also plan the following:
• introduction of consistent software supporting the reporting and analysis of accidents and the implementation of all improvement actions,
• development of the training system, including the competences of leaders in the field of safety,
• introduction of a coherent system of internal inspections and audits,
• introducing regular visits of managers in production areas,
• further modernisation of production plants in the area of infrastructure,
• structuring of the H&S Management System and certification of other companies according to ISO 45001.

We started many activities to strengthen our communication in the H&S area, including:
• regular meetings of OHS employees from all companies, aimed at exchanging good practices, learning from each other from mistakes in case of incidents, updating strategic directions for the Ciech Group and key activities related to the H&S area,
• periodic communications in the form of emails, posters and in each case other surprises in the form of quizzes for employees, which are to strengthen the communication of our 10 Safety Rules,
• periodic mutual visits of employees of OHS employees at individual plants of the Group, aimed primarily at the exchange of good practices and facilitating the unification of standards while maintaining the diversity of our production profiles.

2. Health& Safety Trainings

The competences of our employees in the area of occupational safety are of key importance to us, as they are a guarantee of safety for themselves, co-workers, contractors, and therefore our entire organisation. That is why we do not stop at mandatory initial and periodic training required by law. We are developing a system of training in the area of health and safety by:
• including the scope of responsibility in the field of occupational safety for people managing employees to the company’s overall development programme for management,
• involvement of our employees to perform the role of internal trainers, for example training in the “See? React!” series,
• introducing periodic first aid training for all employees,
• continuous improvement of the health and safety part during the introductory programme so as to communicate
• our safety expectations to our employees from the beginning of employment.
The largest training project for 2021-2022 in the area of OHS Management is the „See? React!”, Which is, first of all, to develop the competence to perceive risk, despite working sometimes for many years in the same place, similar conditions and threats. Secondly, it is to make the managers of employees aware of their responsibilities in the field of occupational health and safety and develop their competences in conversations with employees focused on responsibility for the workplace, activities in the sphere of influence and developing their own solutions to improve work. For employees, it is to strengthen the feeling that all activities in the area of health and safety serve them themselves, so that they can return home safely and in full health every day.

3. Health & Safety Risk Assessment

We believe that risk assessment means a comprehensive approach that allows us to minimise the risks to the health and safety of our employees and stakeholders. It is an integral part of our processes, including purchasing or investment. An important part of this systemic approach is occupational risk assessment, the purpose of which is to determine the type and level of hazards accompanying particular tasks. It helps to estimate the potential losses resulting from it, but above all, support the selection of adequate protection means, using the hierarchy of control measures (ERICPD). In our organisation, we use the Risk Score method, where at the risk assessment stage, the following are considered: the potential effects of exposure to people’s health and life, the time of exposure to threats and the likelihood of such negative effects. We carry out occupational risk assessment periodically, at most once every two years, and in each case of changes that may affect the health and safety of employees.
In addition, we continuously monitor the risks in the work environment through regular inspections carried out not only by OHS services, but also as a team, with the participation of area owners (managers of organisational units) or representatives of the Maintenance Department. Noticed threats or irregularities are prioritised and appropriate corrective actions are carried out by designated persons. The degree of implementation of such activities is tracked as one of the numerical indicators in the H&S area.
As a pilot, in one of the companies, we introduced software to support the performance of the rounds with the possibility of taking photos, audio and video recordings at the observation site and adding a short note. Data from such inspections are collected in one place, which allows you to track the performance of the inspections themselves and the implementation of recommendations resulting from them. After the test period, we will decide to use this tool in other companies. One of the crucial rights, and in the Ciech Group, also one of the duties of employees, is to refrain from work if the working conditions are so dangerous that any individual’s health or life could be at risk. We expect that after the supervisor has been notified of such conditions, employees in this type of situation will withdraw from their work. The hazard will then be discussed and, following the risk assessment, appropriate risk minimisation measures will be taken so that the work can be performed safely. Reporting identified hazards, dangerous situations and behaviours by employees is one of the important obligations that we present during introductory and initial general health and safety training. We also remind them about these issues during the aforementioned training sessions “See? React!”, convincing the participants that it not only serves our statistics supporting decisions on priority areas and activities, but above all, it aims to improve their safety in daily work.

4. Reporting violations

The CIECH Group has implemented and maintains a Procedure for reporting violations of law, internal regulations and ethical standards applicable within the CIECH Group.
The procedure describes the rules for reporting any violations of law, internal regulations/procedures and ethical principles prevailing within the CIECH Group, in particular those contained in the Code of Conduct of the CIECH Group. Violation is understood as an actual or potential activity contrary to the law, regulations/procedures or ethical standards as in force within the CIECH Group. The CIECH Group provides fully anonymous and open communication channels for reporting such violations. Such fully anonymous reporting channel is provided by: Linia Etyki Sp. z o.o. This reporting channel enables contact with the whistle-blower, while maintaining the anonymous nature of the notification report and any correspondence.
Each employee or associate, intern, volunteer, individual participating in the recruitment process, customer, shareholder and member of governing bodies of companies of the CIECH Group may report a violation in any matter which, in the whistle-blower’s opinion, constitutes or may constitute a breach. The CIECH Group ensures protection and anonymity of the whistle-blower. In special cases, the CIECH Group protects the whistle-blower who is an employee of the CIECH Group against the action of the management, employees or any other persons violating the employee’s rights, privacy or any other forms of retaliation. The process of reporting violations and providing information related to the examination of a violation report, analysis of violations and carrying out the explanatory proceedings shall be strictly confidential.
Explanatory proceedings in cases of Violations of laws and regulations are carried out by the Compliance Officer of the CIECH Group, and in cases of violations of ethical principles and conflicts of interest – by the Ethics Committee of the CIECH Group, and when it comes to mobbing/discriminatory behaviour by the Committee for Counteracting Unlawful Conduct.

5. CIECH Quality Standard (CQS)

In 2021, the CIECH Quality Standard (CQS) programme was effectively implemented in all companies. As part of the programme, the CIECH Group implemented its own quality standards, based on the international ISO 9001: 2015 standard, which provide the Group with a uniform approach in the area of quality, as well as optimisation of quality costs, continuous improvement of the quality of the finished product, reduction of the number of complaints from key customers, organisational improvement and development of personnel qualifications and skills.

W measure and report in our non-financial report figures and ratios regarding injuries in the CIECH Group including LTIF - lost time injury frequency rate - the number of injuries at work with loss of working time standardised to 1 million hrs worked by employees.

The CIECH Group has implemented and maintains a Procedure for reporting violations of law, internal regulations and ethical standards applicable within the CIECH Group. We report data on violations in our non-financial report.

1. Observance of human rights

Within the CIECH Group, we place emphasis on promoting ethical values and behaviour aimed at observance of human rights among our stakeholders, predominantly our employees and counterparties. Accordingly, all companies of the CIECH Group joined the Declaration of Adoption of the Standard of the United Nations Ethical Program, thus committing themselves to comply with internationally recognised human rights and labour standards, according to which they shall, in particular, support and promote the freedom of association within the CIECH Group and relations with the market environment, support the elimination of all forms of slavery and forced labour and contribute to the effective abolition of work by adolescents under the age of 18.
• We comply with all applicable laws in terms of working hours, overtime, pay and other employer’s benefits. Wages and salaries are paid in a timely manner, in accordance with the applicable “Remuneration Regulations”.
• We give our employees the freedom to join or withdraw their membership in trade unions and/or employee representation of their choice.
• We appreciate a diverse, inclusive work environment, and do not discriminate against, or tolerate any discrimination, on the basis of gender, age, race, religion, disability, sexual orientation, origin or any other characteristic protected by law.
• We do not use any type of forced labour. Employees have control over their identity documents and do not pay any fees related to obtaining or maintaining their employment.
• Using any physical and/or mental force, including mobbing, is prohibited.

1. Development and unification of the remuneration policy
In 2021, we continued the process of evaluating newly created jobs in individual companies. In order to unify the remuneration policy, we updated the basic salary table and the job grading table in key Polish companies of the CIECH Group. The resulting changes were introduced to the Remuneration Rules. At the same time, as a result of the implementation of the ABCD Model, we increased the base salaries for employees in operational positions. Afterwards, in December 2021, we updated the salary tariff table again to take into account the increase in the minimum wage for 2022. As part of the adopted framework, we have adjusted the base salaries as of 1 January 2022 to the level of at least the minimum salary specified at individual levels of the tariff table. In addition, we have defined basic salaries for operating employees at individual skill levels (ABCD Model) and introduced new provisions regarding the seniority entitling to calculate the retirement pension - currently the internship in all companies of the CIECH Group is considered.

2. Clear principles of recruitment
Recruitment processes within the CIECH Group are based on the adopted standards. We belong to the “Friendly Recruitment” Coalition, which means that we comply with the provisions of the Code of Good Recruitment Practices.
The recruitment process is standardised for the entire Group and involves meetings in the presence of an HR Employee and a business representative. Depending on the grade of the position, the recruitment processes consist of one or more stages.
A competency interview is conducted with candidates, and their substantive knowledge and knowledge of foreign languages are also checked. Additionally, if necessary, competency tests and knowledge tests are carried out. An important element of the recruitment process is the feedback for persons applying for a given position, which is provided to each candidate, regardless of the recruitment result. In communication with candidates, we are supported by the recruitment system, thanks to which the flow of information exchanged with candidates is monitored.
In order to meet the changing conditions, we have introduced the standard of recruitment conducted, in its entirety, remotely. In the case of positions for which recruitment cannot be carried out remotely (e.g. production area), the recruitment is carried out with the preservation of all safety measures.
The CIECH Group cares about continuous improvement in the recruitment process. Just like in the previous years, we collect valuable feedback from candidates participating in recruitment processes using an anonymous online survey. The information obtained helps the organisation to continuously improve its recruitment standards.
All available job offers at the CIECH Group can be found on the corporate website in the career tab at https://kariera.ciechgroup.com.

We monitor and report in our non-financial report:
- Employment in the CIECH Group by gender
- Employment in the CIECH Group by age
- GPGR (Gender Pay Gap Ratio):
GPGR - percentage difference between the average monthly remuneration (including bonuses, awards and other allowances) of women and men. The ratio does not take into account the remuneration of the Management Board of the Company. The GPGR is calculated as a percentage as the absolute value of the difference between the quotient of the average monthly salary of women, divided by the average monthly salary of men, and the number 1.
- Employment in the CIECH Group by type of contract (indefinite / definite period)
- Employment in the CIECH Group by full and part-time contract
- Newly engaged employees
- Newly engaged employees
- Employment in the CIECH Group by position and age
- Employment in the CIECH Group by work area

1. Our impact on the environment
For the CIECH Group, an important issue in the area of environmental protection is maintaining the technology regime and high quality of products, but also minimising negative impact on the environment by limiting emission of pollution to the atmosphere, waters and soil, rational waste management and optimisation of energy consumption.
Environmental issues are a priority for the CIECH Group, which was reflected in the development and implementation of a Uniform Environmental Policy in 2016. Pursuant to the Policy, all companies of the Group are required to comply with applicable environmental law regulations, reduce air emissions and the amount of wastes produced, utilise natural resources in a rational manner and combat climate changes through CO2 reduction, and to maintain good social relations in communities where business activities are conducted.
Production plants of CIECH Group operate under required permits and administrative decisions. The majority of production companies within the CIECH Group have implemented environment management systems in conformity with ISO 14001 regulations.
Reducing CO2 emissions to the atmosphere is one of the main goals and challenges we face. We are aware of our responsibility to slow down and ultimately halt greenhouse gas-related climate change. In the ESG strategy „Chemistry for a Better World” we have committed ourselves to the following:
• to reduce Scope 1 and 2 greenhouse gas emissions by 33% by the end of 2026 compared to the base year 2019 (2020, burdened with the effects of economic disruptions caused by the pandemic, is not appropriate for comparison),
• to completely eliminate coal from energy production by 2033,
• to become net climate neutral by 2040.

2. ESG Strategy in the Environmental Area
Commitments of the CIECH Group in the Environmental Area:
We speed up on the path to carbon neutrality.
Our main long-term goal is to achieve climate neutrality* by 2040. In the first phase, we intend to reduce CO2 emissions by 33% by the end of 2026 compared to the base year 2019. We have also committed to completely eliminating coal from electricity and heat generation for production processes by 2033.
A 1/3 reduction in emissions by 2026 is part of our energy strategy. We will achieve this by gradually reducing the use of high carbon fossil fuels. Together with our partners, we are working on the construction of a thermal waste treatment installation in Inowrocław. We are considering the use of biomass as a fuel and we are analysing the possibility of using natural gas, although due to economic and political changes this fuel has lost much of its attractiveness. In addition, we are continuously working on our energy and process efficiency.
Achieving complete climate neutrality will require the use of technologies that have not yet been implemented on an industrial scale, and the selection of the most appropriate solution is subject to analysis. An important issue in the transition phase towards climate neutrality is also limiting the use of coal as an energy raw material.
* Climate neutrality means that if we emit greenhouse gases, we will remove them from the atmosphere or apply an adequate balancing mechanism.
We decouple growth and energy consumption.
A priority for the CIECH Group is to reduce the energy consumption ratio per unit of revenue or production each year. Until we have introduced solutions that allow the use of only renewable energy, reducing the energy consumption of our production is an important element in restricting our impact on the natural environment. Since 2019, our energy intensity, measured by the amount of energy consumed per unit of revenue, has decreased by 14%.
We see circularity as a key efficiency lever.
As we move towards a circular economy, we strive to improve our processes by reducing waste and using fewer raw materials. Our objective is to systematically reduce the use of water in our production processes, to introduce solutions to increase the use of production waste in the manufacturing of soda and salt and more recyclable materials such as glass cullet in the manufacturing of silicates and packaging. We also plan to start the production of polyurethane foams from recovered or natural raw materials. Additionally, we intend to increase the share of environmentally friendly and recyclable packaging.

3. Code of conduct of the CIECH Group
Below our code of conduct in the environmental area is presented:
We care about our WORLD
We respect the natural environment
We are part of the chemical industry, which is of great benefit to mankind, but at the same time, there is some price involved, namely its impact on the environment. This means that while running our business, we remember about responsibility for the fate of future generations and our planet. Accordingly, we strive to eliminate any negative environmental effects of our operations, and where possible, to minimise them. We make every effort to ensure that our actions are fully consistent and harmonious with the idea of environmental protection. We observe generally applicable environmental protection laws and, where possible, adopt more restrictive internal standards. We understand the impact of greenhouse gases on the climate and that is why we are implementing ambitious projects aimed at minimising emissions and full decarbonisation in the future. We minimise environmental protection risks, among others, by reducing the use of natural resources and energy, eliminating or reducing the amount of harmful emissions, by-products of production processes and waste. We use water in a sustainable manner, minimising its consumption and taking care of the quality of local resources.
We support local communities
We care for local communities wherever our production plants are located. We are aware of our importance as an employer and work together with local authorities, NGOs and residents to improve their life quality. Our objective is developing good neighbourly relations based on open dialogue, consultation and collaboration. We engage in employee volunteering for local initiatives, and as a Group, we support socially significant initiatives in our immediate environment.

1. Water resource management and sewage management
The CIECH Group continuously strives to conduct its activities in the field of water and wastewater management in an optimised and sustainable manner. The companies of the CIECH Group make every effort to ensure that the use of water resources is carried out in a responsible manner, thus reducing the negative impact of our operations on the environment.
The production processes of the CIECH Group companies use water directly from natural sources and municipal water supply systems. Water from natural sources in the companies of the CIECH Group is used both for production, social and living, cooling and energy needs. In order to reduce its consumption, the plants operate closed water circuits, which is in line with the implementation of the assumptions of the circular economy. The use of increased water circulation in the technological circuit is aimed at reducing water intake from natural sources.
The companies of the CIECH Group also use and manage rainwater and snowmelt in their own installations, thus reducing the intake of water from natural sources.
Post-production wastewater, after treatment in on-site wastewater treatment plants, is discharged into waters or to the municipal sewage system. The parameters of the waste water do not exceed the specified permissible values in the permits.
To ensure compliance with regulations and minimise the impact on water resources, we regularly monitor the quality of groundwater and groundwater near our plants, especially in terms of salinity and chloride content.
As part of the implementation of measures to improve water quality in the area of Inowrocław (from 2018) and Janikowo (from 2019), work is being carried out, including on cleaning barrier wells, modernisation of pumping stations or modernisation of piezometers used for continuous water monitoring. In the following years, further investment works are planned to improve the condition of the aquatic environment.
In order to improve the water and wastewater management in the companies of the CIECH Group, modernisation, investment and research and development works are planned in order to reduce the negative impact of the activity on the environment.

2. Air quality management
The CIECH Group attaches great importance to reducing air emissions. Due to the tightening of emission standards and new legal obligations, we systematically adjust our installations and strive to continuously reduce the emitted pollutants.
In recent years, the CIECH Group has carried out a number of investments, especially in the soda segment, favouring the protection of the atmosphere, including:
• reduction of dust emissions from the owned CHP plants by modernising electrostatic precipitators,
• reduction of nitrogen oxides from the existing CHP plants by building a flue gas denitrification installation with the use of 3 levels of catalytic elements (in the Inowrocław and Janikowo locations),
• reduction of sulphur dioxide from the existing CHP plants by building a flue gas desulphurisation installation,
• the de-dusting system of the Lime Furnace Installation in Janikowo was comprehensively modernised.
The aforementioned modernisations, in line with the adaptation of the installation to new emission standards, in connection with the very restrictive requirements of the BAT Conclusions for LCP and in connection with the completion of the PPK (in mid-2020), significantly contributed to the reduction of individual types of pollutants into the atmosphere.
Additionally, in order to reduce air emissions, our installations are equipped with various atmospheric protection devices with high pollution reduction efficiency. These devices include, among others wet dust collectors (efficiency at the level of 85.5%), cyclones and scrubbers (efficiency at the level of 99%), multi-cyclones (efficiency at the level of 95%), and bag filters (efficiency at the level of 95% - 99.9%).
Measurements of air emissions in the CIECH Group are carried out in accordance with applicable regulations and the permits held. Gas and dust emissions are monitored by the installed continuous monitoring systems (combined heat and power plants) and by periodic measurements on other emitters. In addition, modern measurement systems have been installed on the emitters, especially those related to the soda segment, thanks to which it is possible to monitor emissions with greater accuracy and precision.

3. Waste and hazardous substance management
The companies of the CIECH Group conduct waste management in accordance with the permits and administrative decisions in their possession. Due to the dynamically changing obligations and regulations in the field of waste management, we continuously adapt to changes in the formal and legal environment and strive to reduce the amount of waste generated, as well as to the sustainable management of waste and raw materials.
The CIECH Group produces waste, the main source of which is production processes in individual plants. Waste storage and storage sites comply with the requirements specified in the permits or administrative decisions in their possession.
All companies of the CIECH Group that are subject to the registration obligation in the Database on products and packaging as well as on waste management have appropriate registrations. Our companies keep current quantitative and qualitative waste records.
We also make every effort to ensure that the entities cooperating with us in the field of waste management are guided by the same values as the CIECH Group, conducting their activities in a sustainable manner. The selection of entities collecting and managing waste generated in the CIECH Group companies is preceded by a detailed analysis of the current permits and administrative decisions.
The CIECH Group implements the principles of a circular economy, using some of the waste it produces as secondary raw materials or materials for the reclamation of areas transformed by human economic activity. Some of the waste we produce is secondary raw material for other industries, for example our waste is used in the production of cement and clinker, which allows to reduce the use of natural aggregates and emissions to the environment.
Reduction targets have also been set for the entire CIECH Group. Reduce the amount of waste generated by 15% by 2025. It is also planned to increase the use of secondary raw materials by searching for new recipients and ways of managing the generated post-production waste. Research and development works are also carried out for this purpose.
As part of initial and periodic training, all our employees receive information on the safe handling of hazardous materials, depending on the specificity of their position. In any case, that is, both if it involves contact during the supply of raw materials, laboratory tests, production processes or activities related to hazardous waste. Moreover, these types of risks are also taken into account in the occupational risk assessment.
Also, trainings for guests and subcontractors cover the subject of possible hazards from substances, mixtures or hazardous materials in a given location and at a specific job.

4. Restoration of degraded areas - Reclamation
A number of reclamation works are carried out in the companies of the CIECH Group, aimed at minimising our impact on the environment. Reclamation is a process of restoring utility and natural values to areas that have been transformed as a result of human economic activity or natural factors.
The CIECH Group, on the basis of its administrative decisions, carries out reclamation works in landfills where in the past were stored, among others, still sludge.
The works are carried out in accordance with the schedule, in which an important role is played by the sequence of actions related to the technical closure of the pond with a technical mixture, and then biological reclamation with the use of an agrotechnical mixture. The area prepared in such a way is finally left to self-purification through natural succession.
As part of the formation of the technical layer, ash and slag, ash-slag mixtures and lime 09 produced in one of the CIECH Group companies are used on the surface of the ponds. For the agrotechnical layer, the ratio of the ash-slag mixture to sewage sludge is 2: 1. Stabilised sewage sludge is collected from the Municipal Sewage Treatment Plant and from the Municipal Water and Sewage Company. The physicochemical properties of the sewage sludge used are controlled by accredited laboratories in terms of meeting the requirements for their use in reclamation works.
By the end of 2021, 775,808.4 m3 of waste (except sewage sludge) from the CIECH Group’s own plant was used for the rehabilitation of the ponds.
The reclamation, according to the schedule resulting from the administrative decision, will be completed by the end of 2022.
Another example of reclamation carried out is the restoration of the site after the post-production sewage retention reservoir. Reclamation is carried out with the use of processed sewage sludge from the Municipal Biological Sewage Treatment Plant. Ultimately, the result of reclamation works is the creation of a forested post-retention area.

We monitor and report in our non-financial report data on:
- CO2 emissions (Scope 1 and 2)
- Air emissions
- Water and wastewater
- Waste and hazardous waste
- Energy consumption

1. Code of conduct of the CIECH Group
Below our code of conduct in the anti-corruption area is presented:
We ensure compliance
We proactively learn about and comply with applicable laws, internal regulations as well as industry and ethical standards – both in social and professional relations. Compliance with legal requirements and ethics in all areas of our Group’s operations has a positive effect on our work, regardless of the tasks performed and the place in the structure of our Group.
We do not tolerate any fraud or corruption
We clearly and consistently apply a zero-tolerance policy to all fraud and corruption. We show honesty in our business operations and in our daily duties, in relations with our business partners and state and local government officials, in all countries in which we operate. We also expect honesty and compliance from our business partners, with whom we work together to develop best practices to protect the trust, value and reputation of our Group.
2. Code of the Business Partner of the CIECH Group
The CIECH Group companies place special emphasis on sustainable development and responsible business issues. We are aware of our role in the local environment and the impact we have on the activities and lives of our stakeholders. We are also aware of our impact on the natural environment. Products manufactured by the CIECH Group contribute to the implementation of the UN Sustainable Development Goals, and our objective is to focus on strengthening positive, and reducing negative, effects of our operations. We strive towards the long-term, sustainable development of the CIECH Group, which will benefit all our stakeholders: employees, customers, suppliers, neighbours, owners, as well as future generations. We collaborate with people, institutions and organisations that share our approach to doing business. Accordingly, we expect our business partners to help us achieve our sustainable development and responsible business conduct objectives and to identify with the values and principles we have adopted.
The Code of the Business Partner of the CIECH Group (the “Code”) sets the minimum standards of conduct for business partners of the CIECH Group companies, in particular: suppliers, contractors, distributors, recipients, sellers, service providers, other counterparties and entities with the help of which business partners perform business tasks in relation to the companies of the CIECH Group (“Partners”). The condition for starting and continuing the business relationship of a CIECH Group company with Partners is confirmation by the Partners and adoption of the principles set out in the Code. The provisions of the Code apply to the company, members of governing bodies, employees and associates of our Partners.
Conducting economic activity – CIECH Standards regarding cooperation with business partners:
Ethical conduct of operations
We expect our Partners to apply the principles of ethical conduct in each area of their business and to strive to implement solutions that build awareness of ethical principles of conduct in the workplace among their employees and associates.
Compliance with law
We expect our Partners to comply with all applicable local and international laws. In the event that the provisions of local law are less restrictive than the principles of the Code, we expect our Partners to apply the principles set out in the Code.
Fair competition and antitrust laws
We expect our Partners to act in compliance with all applicable competition protection regulations, for example, by abstaining from dumping prices, price fixing or other unlawful arrangements.
Compliance with international sanctions
We expect our Partners to comply with international sanctions imposed on countries, economic operators or natural persons, and not to conduct any economic activity violating international restrictions.
Zero tolerance for fraud and corruption
We expect our Partners to apply a zero-tolerance policy to any fraud and corruption, regardless of its form. Our partners may not, directly or indirectly, offer or accept any undue advantage or promise thereof, including material, financial and personal benefits, unauthorised gifts, etc., in exchange for a specific act or omission.
Honesty in commercial activities
We expect our Partners to show honesty in their business activities, and as part of their daily duties, in relations with their customers, counterparties, suppliers and associates.
Information security
We expect our Partners to implement and maintain high information security standards to enable us to effectively protect confidential information, including any trade/business secrets.
Counteracting conflicts of interests
We expect our Partners to avoid and counteract any conflict of interest that could weaken their credibility, or our trust, or the trust of third parties in the CIECH Group companies. We expect our Partners to report any situations that may indicate a conflict of interest and any cases in which employees or individuals representing the CIECH Group companies participate in the Partner’s enterprise or are in any way related to them.

1. KYC (Know Your Customer/Supplier) verification
Starting from 1 October 2021, we verify our suppliers using the KYC Procedure. The KYC verification complements, supplements and at the same time confirms the application of the CIECH Group standards (The Code of the business partner of the CIECH Group). Through the KYC procedure, we verify and confirm that our Partners conduct their activities in accordance with the standards of the of the business partner of the CIECH Group, especially in the area of human rights, environmental protection and ethics. The KYC verification of our partners is the fulfilment of one of the obligations that we included in the CIECH Group ESG Strategy - „we introduce ESG to our purchasing procedures - we will examine the status and ESG risk of suppliers responsible for at least 70% of our expenses by 2023”.
At the Soda Business Unit and the Salt Business Unit, we conduct a KYC verification of Partners with an annual turnover of ≥ PLN 4 million net or with a transaction value of ≥ PLN 4 million net. In other Business Units and companies, we conduct a KYC verification of Partners with an annual turnover of ≥ PLN 2 million net or with a transaction value of ≥ PLN 2 million net.
The condition for introducing the Partner to the Customer Base of the CIECH Group is a positive KYC result. The condition for the conclusion of the contract/order/acceptance of the offer of the Partner entered in the Customer Base is a positive KYC result. The condition for concluding an annex to the contract/order with the Partner entered in the Customer Base is a positive KYC result.
The validity period of the Partner’s KYC verification result depends on the KYC risk assessment and is 6, 12 or 24 months.
In the KYC verification process, we ask Partners to complete the KYC Form, which has been divided into the following parts:
• General issues - in this section we ask, among others, about registration data, industries in which the Partner conducts business, quotations of the Partner’s shares on stock exchanges, composition of the Partner’s group.
• Sanctions - in this section we ask, among others, about the Partner’s activities in the markets cov-ered by international sanctions, conducting business with persons who are subject to international sanctions.
• Ethical conduct of business - in this section we ask about compliance with individual standards of the CIECH Group, specified in the Code of the Business Partner of the CIECH Group.
• Principles of ethical business conduct - in this part we ask, among other things, for the Partner to attach its codes of conduct or its codes of the business partner.
• Target for reducing CO2 emissions - in this section we ask, among other things, to provide a target for reducing CO2 emissions.
• Proceedings related to the ethical conduct of business activity - in this part, we ask for answers to questions regarding the proceedings conducted, among others, against the partner or members of its bodies, regarding, among others, monopolistic practices, prohibited employment practices (mobbing, discrimination, youth labour, slave labour), money laundering and terrorist financing, bribery or corruption.
The result of the KYC verification of a given Partner, within the validity period, is valid for all companies of the CIECH Group.
In the period between October 2021 and the end of February 2022, we verified over 100 Partners, and all Partners received a positive KYC result, with the KYC result valid for 24 months, 12 or 6 months.

2. Internal procedures
The list of internal procedures in regard to anti-corruption includes:
• Code of Conduct of the CIECH Group,
• Code of the Business Partner of the CIECH Group,
• Policy of Compliance with Competition Law within the CIECH Group,
• Policy of Counteracting Conflicts of Interest within the CIECH Group,
• Anti-fraud and anti-corruption policy of the CIECH Group
• Compliance Policy of the CIECH Group,
• Procedure - offering and accepting gifts and invitations within the CIECH Group,
• Procedure for reporting violations of law, internal regulations and ethical standards applicable within the CIECH Group,
• Procedure - rules for monitoring and reporting Compliance Obligations within the CIECH Group,
• Procedure - Regulations of the operation of the Ethics Committee of the CIECH Group.

Rules for reporting violations and data

The CIECH Group has implemented and maintains a Procedure for reporting violations of law, internal regulations and
ethical standards applicable within the CIECH Group.
The procedure describes the rules for reporting any violations of law, internal regulations/procedures and ethical principles
prevailing within the CIECH Group, in particular those contained in the Code of Conduct of the CIECH Group. Violation is
understood as an actual or potential activity contrary to the law, regulations/procedures or ethical standards as in force
within the CIECH Group. The CIECH Group provides fully anonymous and open communication channels for reporting
such violations. Such fully anonymous reporting channel is provided by: Linia Etyki Sp. z o.o. This reporting channel enables
contact with the whistleblower, while maintaining the anonymous nature of the notification report and any correspondence.
Each employee or associate, intern, volunteer, individual participating in the recruitment process, customer, shareholder
and member of governing bodies of companies of the CIECH Group may report a violation in any matter which, in the
whistleblower’s opinion, constitutes or may constitute a breach. The CIECH Group ensures protection and anonymity
of the whistleblower. In special cases, the CIECH Group protects the whistleblower who is an employee of the CIECH
Group against the action of the management, employees or any other persons violating the employee’s rights, privacy
or any other forms of retaliation. The process of reporting violations and providing information related to the examination
of a violation report, analysis of violations and carrying out the explanatory proceedings shall be strictly confidential.
Explanatory proceedings in cases of Violations of laws and regulations are carried out by the Compliance Officer of the
CIECH Group, and in cases of violations of ethical principles and conflicts of interest – by the Ethics Committee of the CIECH
Group, and when it comes to mobbing/discriminatory behaviour by the Committee for Counteracting Unlawful Conduct.
In 2021, there were 2 reports of the aforementioned violations. There were no reports of corruption-related violations.