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AGORA

ETHICS AND COMPLIANCE

Agora Group is committed to observing the highest ethical standards, operating in accordance with the law, our internal regulations and external codes of conduct adopted by Agora S.A. as well as other entities of the group.

Sustainable Development Goals

See Agora Group's Sustainable Development Goals (SGDs)

Ethics and compliance - Peace, justice and strong institutions
Ethics and compliance - Peace, justice and strong institutions

Peace, justice and strong institutions

  • effective ethics and compliance systems preventing any forms corruption and fraud
  • prevention of corruption and bribery and due dilligence in dealings with the business environment
  • whistleblowing and monitoring systems, protection of whistleblowers
  • Ethics
  • System of ethics in Agora
  • Agora’s code of ethics
  • Protection of whistleblowers
  • Advertising and journalism ethics
  • Preventing corruption and fraud

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Any activities that might be construed as compromising to the company and its public image are strictly forbidden. These include: corruption, offering or accepting bribes and other misconduct. In 2018 Agora S.A. adopted a comprehensive system of ethics including Agora Code of Ethics, and implemented an internal whistleblowing protocol.

Etyka w agorze - tabela alternatywna typ 2

Key goals in 2018 r.
  • to organize anti-corruption regulations, procedures and policies into Agora Code of Ethics, including monitoring mechanisms
  • to implement Agora Code of Ethics and whistleblowing system protocol in Agora Group
Results in 2018 r.
  • introduced comprehensive system of ethics and Agora Code of Ethics
  • introduced the whistleblowing protocol and the position of Compliance Officer
  • delivered ethical audit, analysis of gaps and launched development of the compliance management system in Agora Group
Key goals in 2019 r.
  • to implement a comprehensive compliance system in Agora Group
  • to continue ethics training and communication activities addressed to all employees of Agora Group
  • to implement Polityka otrzymywania i wręczania prezentów i innych korzyści w Agora S.A. (Policy of Accepting and Offering Gifts and Other Benefits in Agora S.A.)

The process of implementing the system of ethics in Agora was launched in 2017, with the establishment of Ethics Committee. Ethics Committee held regular meetings and consultations and included representatives of Legal Council, Human Resources and Corporate Communications departments. Its activities were supplemented by the process of dialogue with employees.

DIALOGUE WITH EMPLOYEES

  • As part of the dialogue with employees, already in 2017 we launched a survey among the employees of Agora S.A. asking them about the topics that should be covered by Agora’s Code of Ethics.
  • In 2017 and 2018 workshops and meetings were held, with the employees, representatives of the trade unions, Employee Council and managers, with in-depth discussions of specific aspects. Another element of the project is a dedicated e-mail address for sending in comments and suggestions, and a special section on company intranet, with information about the project.
  • Throughout March 2018, Management Board of Agora presented the project of Agora Code of Ethics and its progress to all employees of the group.
  • The crowning element of employee involvement in the process were consultations and discussion sessions during which all major reservations were reviewed. The process also included consultations with the company’s managers and an expert company specializing in external whistleblowing systems.

 

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In 2018 a comprehensive system of ethics was adopted by Agora S.A., comprising: Agora Code of Ethics, internal policies and regulations, external industry codes, Compliance Officer and a whistleblowing system. Communication and education of employees are two other elements crucial for maximum effectiveness system of this aspect.

An important element of Agora’s ethical system is Code of Conduct for Suppliers and Contractors of Agora, published on agora.pl, with key rules of cooperation for suppliers and contractors. Contractors of Agora have been obliged to read and observe the regulations listed in the document.

The document specifies codes in the following areas:

  • responsible relations with stakeholders
  • respecting human rights
  • fair competition
  • environmental impact and sustainable growth
  • ethics and transparency standards in relations with suppliers, contractors and business environment
  • compliance and anti-corruption

Code of Conduct for Suppliers and Contractors of Agora is available online: https://www.agora.pl/en/responsible-business#slide-ethics

Download the infographic

relations-suppliers_1

 

Communication about Agora Code of Ethics was released in October 2018, with each employee receiving a letter from Management Board of Agora, introducing the new code. Also, a copy of Agora Code of Ethics was delivered to every employee.

 

2,000

copies of Agora Code of Ethics were distributed among the employees and collaborators of Agora

The communication campaign included: e-mailing, posters displayed in the workplace, newsletters and a dedicated section in company intranet with key information, e.g. FAQ on the system of ethics in Agora.

EDUCATING EMPLOYEES

Two webinars were conducted in 2018 as a part of the educational activities addressed to the employees:

  • All you want to know about whistleblowing in Agora
  • All you want to know about anti-discrimination and anti-mobbing policy in Agora

The recording and all necessary materials from the webinars are available online.

87

employees attended the webinars

The educational campaign included regular releases of Ethics Newsletter covering the main elements of Agora’s Code of Ethics - 7 newsletters have been prepared and sent.


Additionally, the employees of Agora could watch a film about the mechanisms of Ethics Line and how the whistleblowing system can be used.
New employees are introduced to Agora’s Code of Ethics at Welcome to Agora orientation sessions. Thirty new employees in the period form October to December 2018 participated in the orientation session.

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Agora’s Code of Ethics is an internal document, addressed to all employees and collaborators of Agora. While the document summs up all previously adopted internal and external regulations in the areas of ethics and anti-corruption, its main role is to describe all principles and behaviours encouraged and expected by Agora and those the company deems wrong or unacceptable.

Presented below values, is a manifestation of a responsible and transparent approach and each represents a consecutive section of the document:

  • DIVERSITY IN THE WORKPLACE – describes the main workplace principles: cooperation, equal treatment of all employees and collaborators as well as mutual respect

  • FAIR EXTERNAL RELATIONS – specifies what constitues fair external relations and high ethical standards in dealing with clients, suppliers and contractors

  • RELATIONSHIPS TRANSPARENCY – covers transparency in the workplace, including in relations with business partners, suppliers and contractors, as well as employment in Agora in the context of other professional and political activities

  • COMPLIANCE AND ANTI-CORRUPTION – indicates methods for preventing fraud and corruption in the company

  • COMMITMENT TO THE REPUTATION OF AGORA ­– outlines the principles of communication and presentation o information about the company and proper commitment to its reputation

  • INFORMATION SECURITY – outlines the handling of confidential information, trade secrets and personal data protection.

Agora’s Code of Ethics applies to all: employees, collaborators, executives of Agora S.A., regardless of their function or position.

It specifies all prinicples that should be observed by Agora’s employees and collaborators in relations with all stakeholders; compiles key documents with detailed instructions for specific areas; describes the whistleblowing system, including the contact details of relevant individuals who can offer assistance in ethical matters as well as advice on who can help in determining whether an action is in line with the codes an values of the company, plus a glossary of key definitions.

Management Board of Agora S.A. issued a reccommendation according to which all entities of Agora are advised to adopt Codes of Ethics.

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WHISTLEBLOWING SYSTEM

As a part of the ethics system, in 2018 Agora introduced Whistleblowing System Protocol in Agora S.A. and Whistleblowing Processing Protocol. The documents specify that every report is approached as confidential and a whistleblower is provided special protection, as well as that every report is important and shall be processed, and addressed as quickly as possible. However, in especially sensitive cases the processing might last 30 or more days. whistleblower is provided special protection, as well as that every report is important and shall be processed, and addressed as quickly as possible. However, in especially sensitive cases the processing might last 30 or more days. 

In 2018, new whistleblowing channels and possibilities for submitting questions and reporting on the misconduct of employees or collaborators were introduced. 

The following channels and forms of reporting cases related to workplace discrimination and mobbing are currently available in Agora:

  • internal – confidential:
    • contacting the in-house anti-discrimination and anti-mobbing officer (e-mail)
    • contacting Agora’s Compliance Officer (e-mail, phonecall or personal contact)
  • external – confidential and anonymous
    • contacting an external Ethics Line (online platform, e-mail, telephone available between 7:00 and 18:00)
Download the infographic

Relacje_strona_6_EN

Any report, question or suggestion, submitted via the portal, e-mail or Ethics Line, reachers relevant experts who remain in contact with the whistleblower. The system ensures the whistleblower’s anonymity and the correspondence is encoded and only the experts of Ethics Line can access it. The information can be passed to Agora’s Compliance Officer upon the whistleblower’s express permission. Ethics Line provides assistance to Agora in solving reported cases.

5

number of cases registered through Ethics Line in 2018

In the period October – December 2018 five cases were registered by the Ethics Line. Some brought about the introduction of new solutions. Some were reports that required verification and checking as a potential cases of corruption, others were questions to which relevant answers were provided. Simultaneously, each case was directed to Agora’s Compliance Officer and those relevant to workplace relations were described in the human rights and the workplace section of this report.

In 2018, there were 5 cases, including 3 concerning the employee-superior relationship.

3

number of cases regarding employee-supervisor relations and

2

number of cases regarding the employee-employee relationship

5

number of cases reported and considered in 2018, including

 

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In the case of Agora Group, advertising ethics is related to our role as an advertiser as well as media publisher. This renders the issue particularly important for all our operations.

Agora Group adopted the following external codes of conduct:

Self-imposed regulations are particularly important in Agora’s core business, its media operations and responsibility in the advertising sphere. Agora makes every effort for the above codes and regulations to be upheld to the stakeholders’ satisfaction.

We take every effort to ensure that the advertisements we publish comply with the law (including a ban on advertising gambling, alcoholic and tobacco products) and principles of good conduct. Any advertisement, its form and content, should comply with relevant laws, rules of good conduct, programme line and / or the type of publication and with the codes observed by Agora as a publisher: Code of Ethics in Advertising and Code of Good Practice for Press Publishers.

In addition, advertisements for products/ brands with a high risk and those that are questionable are accepted by lawyers.

 

CODE OF ETHICS IN ADVERTISING

Agora has signed Code of Ethics in Advertising – a standard of marketing communication recognized universally across Poland. The Code offers a set of principles that should be followed by entrepreneurs, especially advertisers, and other legal and natural persons as well as organizational units without legal personality offering advertising services. The code is based on universally adopted ethical principles and on good practices, in particular on business ethics standards and ethical norms in marketing communication recommended by The European Advertising Standards Alliance (EASA).

LINK .

  

CODE OF GOOD PRACTICE FOR PRESS PUBLISHERS (PUBLISHERS’ CODE)

The code was developed by the Polish Press Publishers Chamber (Izba Wydawców Prasy - IWP) as a set of internal standards for the purpose of self-regulating publishers allied in IWP as well as other publishers that would join the organization in the future. The main idea behind the document is to protect the interests of readers and publishers against unfair market practices that go against recognized good practice code.

LINK .

STANDARD ADS.TXT

In 2017, Agora was Poland’s first publisher, through our Yielbird team, to introduce ads.txt standard. The ads.txt solution, developed by IAB Tech Lab, offers the answer to two increasingly more widespread problems in programmatic advertising: domain spoofing and unfair resale of ad space in programmatic open auctions. The project is an example of the online publisher’s responsibility as it follows relevant recommendations of IAB. More information

As a brand with a long journalistic tradition, Agora is committed to journalistic and media ethics. Freedom of speech, independence and reliability are important principles we uphold in our daily operations. Any content we develop is based in reliable and true communications. Reliable sources and transparency are crucial to us. We act in accordance with the codes of Media Ethics Charter.

 

MEDIA ETHICS CHARTER

The document specifies 7 principles:

  • truth,
  • objectivity,
  • distincion between information and commentary,
  • honesty,
  • respect and tolerance,
  • primacy of recipient’s good,
  • freedom and responsibility.

LINK .

  • To supplement the industry code of values, Agora adopted self-imposed internal codes that focus mostly on journalism as a profession (Code of Journalistic Ethics and Code of Journalist) They are internal commandments for journalists and editors working in Agora’s media.
  • Agora has also adopted Principles for the selection of advertisements accepted for publication in 'Gazeta Wyborcza', magazines: 'Wysokie obcasy Extra', 'Książki. Magazyn do czytania' and in digital publications (applications) and internet services of Wyborcza.pl group.
  • The document lists all binding laws and internal regulations of Agora SA relevant to the selection of advertisements published in our media.
  • The document is further complemented by a list of procedures and rules applicable to specific aspects such as: ban on gambling advertising, election adverts, etc.
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  • Our priority is to conduct operations respecting the law and due diligence. We take every precaution to prevent situations that might lead to corruption, bribery or fraud.
  • In 2018 Agora introduced Agora Code of Ethics outlining the company’s main ethics principles and proceded to build a compliance system in Agora Group. The system aims to introduce regulations aligned with the standards recommended for compliance systems in preventing corruption and protection of whistleblowers in WSA listed companies.
  • In 2019 Agora will adopt Procedures for Preventing Money Laundering and Financiing Terrorism.
  • No incidents of corruption or fraud were observed in Agora in 2018.
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