Ethics in the Company

KGHM’s values

KGHM is currently developing its Code of Ethics. Once it has been approved by the Management Board it will be implemented in 2015. The Code will be the main tool to build a new corporate culture. KGHM’s key values are zero harm, teamwork, results-driven, accountability and courage. 

The Company’s value system is based on compliance with the law, integrity and caring for KGHM’s reputation. The Group highly values an atmosphere of mutual trust, and each person is treated with respect.

The KGHM procurement process is characterized by high ethical standards. Operational procedures are set forth in the Code of Ethics, which is an integral part of the Procurement Policy of the KGHM Group. The main purpose of the Code of Ethics is to give assurance to key Company stakeholders about the professionalism of personnel responsible for carrying out procurement procedures. The Code also provides guidelines on counteracting potential conflicts of interest and treating suppliers on an equal footing based on the arm’s length principle.

KGHM staff who are responsible for the proper performance of the procurement process are trained systematically on the organization of the procurement process based on the existing internal regulations and requirements, with consideration given to adhering to business ethics.


In 2014 no legal measures were taken against the Company as there were no identified breaches of free competition principles or monopolistic practices. The Company paid PLN 23 thousand due to environmental fines. In 2014 no cases were discovered of breaching regulations and voluntary codes regulating marketing communication, including promotional advertising and sponsoring.


In 2014 the Internal Audit and Control Department did not identify the existance of any corrupt practices in the Company. Corruption risk was analysed in 11 business units (100 percent) by the Internal Audit and Control Department during planned and ad hoc audits and control measures.