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. These intense development processes take place in the atmosphere 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?

General assumptions in the area of sustainable development

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 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.

In 2017, a materiality assessment identified key areas of operations, which – after the selection of relevant ratios – have been discussed in detail herein and in Non-Financial Report for 2017.

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

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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

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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

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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

The HR policy of the Śnieżka Group is the basic document that regulates the matters related to employment. It is based on the assumption that the success of an organization depends on the people who work for its benefit. The employees are our most valuable resource. Thanks to their commitment, passion, skills and attitudes supporting organizational values, we have been able to set ever more ambitious objectives and, by achieving them, become a benchmark for the competition. As a continuously learning organization, we put emphasis on making sure that both our achievements and possible failures build up our experience and provide energy for walking the road to success.

Our HR policy is strongly connected with the organizational values which determine the conduct of the employees and form a basis for all business relations. As far as HR management is concerned, the most important values include “People”, “Cooperation, respect and trust” as well as “Responsibility and commitment” which mean that we are all committed to development of ourselves and of other people, we set ourselves ambitious goals and behave in a manner that shows how to create an atmosphere that favours cooperation and development of a culture of high engagement. Each of us takes personal responsibility for his/her actions and how they are undertaken.
As the HR policy is an integral and inherent element of the Company’s policy and development strategy, the Śnieżka Group has included in this document the undertaking to formulate it with a view to:

  • establishing the position of the Śnieżka Group as an attractive employer, and thus ensuring attraction and maintenance of valuable employees;
  • permitting development of the employees’ attitudes and skills, contributing thereby to the development of a culture of high engagement;
  • motivating and inciting the employees to provide quality and efficient work so as to build an effective and innovative organization;
  • ensuring establishment of long-term relationships between the employees and the specific Companies as well as the entire Group.

ZIn the area of HR management, the due diligence procedures include the documents such as, inter alia,: The Labour Bylaws, the Compensation Bylaws of FFiL Śnieżka SA, and the Organizational Bylaws, which pertain to the basic issues related with employment by the Company. All the activities concerning the human resources management are conducted in accordance with the applicable law, pursuant to the Labour Code. At the Company, this area is also regulated more precisely by the Human Resources Management procedure. Furthermore, the employee matters are defined in other internal bylaws and documents, such as e.g. the Bylaws of the Company Social Benefit Fund.

Transparency and clarity of HR activities are a priority for us. We believe that it is essential to clearly and precisely define the roles and responsibilities of the specific divisions and positions, by reason both of the expected process improvement and the resulting foundation for the construction of an efficient payroll policy, where the approach to rules and amounts of remuneration is kept up-to-date. This provides a basis for the implementation of further initiatives including advanced development and incentive solutions that support efficient leadership and long-term career prospects for the present and future employees. Transparency of principles is applied also with respect to termination of employment contracts which is always carried out in accordance with the provisions of the Labor Code.

According to the Group’s payroll policy, the remuneration paid to an employee should be appropriate to his/her position, responsibilities and skills. The Company’s remuneration systems are based on benchmarks, and data from reports and market payroll information. The median for the whole of Poland is the main factor taken into account. Comparison of positions and data in the reports is performed on the basis of position mapping and valuation which makes it possible to ensure consistency and relevance of the decisions concerning wages and salaries. The remuneration amounts are not affected by gender. While assessing the remuneration amount, we take into account the evaluation of the scope of responsibilities assigned to a given position and the skills of the person working on such position.

The HR policy is carried out on the basis of appropriate plans, programs and tools used in the staff-related and HR processes. These include, inter alia, evaluation of staffing needs and annual employment planning, defining training needs and formulating the annual training plan, adjusting the ongoing training and development projects to the needs of the specific areas, a non-wage compensation program as well as incentive systems, pay raises and promotions.

The Company has a predominant role in the achievement of the Śnieżka Group’s HR Policy objectives. The proposed solutions are implemented in the subsidiary companies gradually which makes it possible to transfer the Polish market models abroad on a regular basis.

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

As far as the Diversity policy is concerned, the “People” and “Cooperation, respect and trust” values are the key ones. In our day-to-day operations, we show our appreciation to every person and treat every person with appropriate dignity. We establish trust in ourselves and our company by respecting our commitments and acting fairly.

The Diversity policy of the Śnieżka Group is understood as the actions aimed at:

  • preventing any discrimination based on: sex, racial origin, national or ethnic origin, religion, denomination or lack of denomination, belief, degree and type of disability, health, age, psychosexual orientation or gender identity, as well as family status, lifestyle or any other reasons for discrimination (equal treatment policy);
  • establishing the diversity management through the development of strategies, policies and programs which shape the work environment in which every employee may feel appreciated, which ultimately contributes to the success of the entire Śnieżka Group.

We consider the equal treatment policy to be the first step on the path to build the diversity management within the Śnieżka Group.

We believe that thanks to ensuring the employee diversity we create a work environment which improves the employees’ creativity, efficiency and loyalty, and gives the capacity to expand our markets and the customer portfolio. It also increases our opportunities of attracting new talents and stimulating the team’s innovative approach which translates into the Group’s business effectiveness. The objective of the Śnieżka Group’s diversity policy is to fully deploy the employees’ potential, skills, experience and talents in an atmosphere of respect and support.

The performance of the actions promoting the culture of diversity is supported by the activities of the Anti-Harassment Commission of the Company. Information on this body is presented later in this document.

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

We understand a good company management as creation of safe jobs, compliance with the corporate governance principles, respect for the environment and dialog with local communities. While implementing the business strategies, we do not forget the global idea of sustainable development and corporate responsibility which are built on respect for human rights in the entire value chain.

An efficient performance of the assumptions for the Group’s strategies is possible only in an environment of trust and respect, based on respect for human rights. The Group endeavours to ensure respect for human rights in a universal dimension, pursuant to the fundamental legal norms. In accordance with Polish law, the key legal acts that address the issues of respect for the employee diversity include the Constitution of the Republic of Poland and the Labor Code (Journal of Laws of 1974 No. 24 Item 141). The internal documents regulating the work of the specific companies were created on the basis of these two acts. 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 Policy of Respect for Human Rights is the most important document that regulates the issues of respect for human rights at the Śnieżka Group. It is understood as a presentation of due diligence principles with respect to violation of rights of other persons, preventing such violations and counteracting any adverse impact on execution of human rights (remedial measures) in the case of a potential violation of such rights, directly or indirectly, by any of the Group companies.

As far as the Policy of Respect for Human Rights is concerned, the “People” and “Cooperation, respect and trust” values are the key ones. the “People” and “Cooperation, respect and trust” values are the key ones. In our day-to-day operations, we show our appreciation to every person and treat every person with appropriate dignity. We establish trust in ourselves and our company by respecting our commitments and acting fairly.

We are aware that the Group’s potential negative impact on human rights may be caused not only directly by our operations, products or services, but also as a result of the business relations we enter into. We undertake to take remedial measures in the case of a violation (either directly or indirectly) of human rights provided for in the international, generally binding documents by any of the Group Companies.

We acknowledge that responsibility for respect for human rights is a global standard to be applied by all entrepreneurs regardless of the place of operations. It applies irrespective of the state ability and/or willingness to perform its obligations in the area of human rights and does not result in any limitation of such obligations.
This responsibility exists beyond and regardless of the obligation to comply with the domestic laws and regulations on human rights protection (United Nations Guiding Principles on Business and Human Rights).

  • With respect to employees – we undertake to respect human rights of our employees and to enhance their awareness of such rights on an on-going basis.
  • With respect to business partners – we take any and all efforts to respect and promote human rights in the relations with our business partners.
  • With respect to local communities – we endeavour to respect human rights and take efforts to understand the needs, culture, customs and values of the local communities in which we conduct our operations, either directly or indirectly.

The Book of Organizational Values is an important document setting out the principles of due diligence in reference to human rights and diversity. The Book devotes a lot of space to the values such as “Cooperation, respect and trust” which refer to the respect of rights of persons within an organization, as well as the respect for such rights with reference to the persons cooperating or related with the Group.

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

The Group’s “Quality, Environment and Safety and Health Policy” is the document encompassing the issues of environmental protection and quality. With this respect, the following values are considered to be the key ones: “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 ongoing 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 Environment Quality 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.

Environmental protection

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.

Ecological activities in the Parent Company are carried out in accordance with the applicable legal requirements and developed procedures and instructions of conduct.

As part of the integrated ecological strategy and quality management, FFiL Śnieżka SA places particular emphasis on:

  • implementation of production and technological processes in accordance with legal regulations and based on modern recipe and technical solutions;
  • applying high quality components only from qualified suppliers;
  • 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.

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.

The Śnieżka Group has obtained the necessary environmental decisions, regularly pays its environmental fees and fulfils its reporting obligations. FFiL Śnieżka SA monitors its impact on the environment on an on-going basis, keeping records of energy and water consumption, emissions of pollutants, generation of waste and packaging. Also, it participates in creating a system for the collection, transport, recovery and disposal of packaging waste and participates in conducting educational campaigns.

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 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” as well as “Responsibility and commitment” which mean that we all behave in a manner that shows how to create an atmosphere that favors 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;
  • encouraging employees and collaborators to report violations of the organization’s policy and unethical behaviours;
  • notifying law enforcement authorities about any violations of binding laws.

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 care in force at the Parent Company to the extent to which such procedures are included as, among others, Procurement, or instructions, including: The Instruction on Selecting a Bidder of Vendor 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 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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