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Human Rights

We care about the highest ethical standards and emphasize the importance of acting in accordance with applicable law, internal regulations and external codes that we are obliged to comply with.

5 - Gender equality
5 - Gender equality

Gender equality

  • effective counteracting of discrimination on the grounds of sex
  • promoting gender equality and a zero tolerance policy against all forms of violence at work
10 - Reduced inequalities
10 - Reduced inequalities

Reduced inequalities

  • effective counteracting of discrimination and introducing a policy of equal treatment in all aspects of employment, regardless of: gender, age, disability, health condition, race, nationality, ethnic origin, religion, denomination, non-denominational, political belief, trade union membership, psychosexual orientation, gender identity, family status, lifestyle, form, scope and basis of employment, other type of cooperation and other premises exposed to discriminatory behavior
8 - Decent work and economic growth
8 - Decent work and economic growth

Decent work and economic growth

  • care for respect for human rights, including the fight against mobbing and harassment in the workplace
16 - Peace, justice and strong institutions
16 - Peace, justice and strong institutions

Peace, justice and strong institutions

  • implementation and observance of the Code of Ethics and due diligence in respecting human rights
  • an effective ethics and compliance system ensuring efficient prevention of all forms of abuse
  • counteracting corruption and bribery and maintaining due diligence in cooperation with the environment system of reporting and monitoring fraud, protection of whistleblowers
  • ETHICS AND THE COMPLIANCE SYSTEM
  • HUMAN RIGHTS
  • JOURNALISTIC ETHICS

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Ethics has always accompanied us in our everyday work and we follow it in internal relations. Observance of human rights, such as: dignity, freedom, equality, solidarity is natural and indisputable for us, that is why we fully support the assumptions of the Universal Declaration of Human Rights and of the Charter of Fundamental Rights of the European Union, and we implement them by systematically setting appropriate standards of conduct and introducing appropriate internal regulations.

Currently, the compliance system consists of the following elements:

  • internal regulations, in particular the “Agora’s Code of Ethics”,
  • the Compliance Officer and the compliance team,
  • periodic assessment of a compliance risk, as well assessment and update of the implemented compliance system,
  • a whistleblowing system,
  • Compliance Risk Charter, i.e. monitoring of compliance of activities in key business areas,
  • training and communication.

AGORA

AGORA

The “Agora’s Code of Ethics” is an internal document addressed to all employees and collaborators of the Company. It indicates what attitudes and rules of conduct are expected at Agora and what are deemed by the company as inappropriate or unacceptable. This condensed set of guidelines and values is an expression of a responsible and transparent approach in the following seven areas, which are also titles of the “Code of Ethics” chapters:

  • Diversity in the workplace – describes the main workplace principles: cooperation, equal treatment of all employees and associates, as well as mutual respect,
  • Fair external relations – specifies what constitutes 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 of information about the company and proper commitment to its reputation,
  • Information security – outlines the handling of confidential information, trade secrets and personal data protection.

This document includes also:

  • the principles to be followed by employees and collaborators in their relations with all of the company's stakeholders,
  • a list of key documents governing specific issues in detail,
  • a whistleblowing scheme in force in Agora,
  • contact information of persons who can help with ethics-related issues,
  • prompts and a glossary of terms.

For general definitions, situational examples and practical rules for dealing with suspected or confirmed conflicts of interest, see “Agora's Code of Ethics” (page 12). These mechanisms apply to the same extent to the management staff, employees and associates of the Agora Group as well as their relations with suppliers, contractors or other external entities.

Training on the “Agora Code of Ethics” is available on Agora’s internal training platform and is mandatory for all employees.

The Management Board of Agora S.A. recommended that all companies in the Agora Group adopt the “Code of Ethics”.

The “Agora's Code of Ethics” is supplemented by:

  • Agora's internal and external policies and regulations, in particular: "Anti-discrimination and anti-mobbing policy in Agora", "Diversity policy of the Agora Group", "Policy of receiving and giving gifts and other benefits by Agora SA employees", "Policy of social and sponsorship activities in Grupa Agora ”,“ Code of good practices in customer service of Agora Group ”,“ Environmental policy of Agora SA ”;
  • external industry codes adopted as binding in Agora, in particular: "Media Ethical Charter", "Code of Advertising Ethics", "Code of Best Practice for Press Publishers".

Based on the "Code of Ethics" of Agora, the "Code of Conduct for Agora's Suppliers and Subcontractors" has also been developed, which is provided to contractors for reading and compliance, with which the company obliges all its suppliers and subcontractors.

 

AGORA

Agora has a whistleblowing system in place. Its implementation is an expression of the company's commitment to promoting a culture supporting behaviour that is ethical, consistent with laws, internal procedures and regulations, as well as external codes adopted by the company. The aim of the system is to provide secure channels for reporting unethical activities or practices that are contrary to applicable laws or the company’s rules that have been observed by employees. It also provides support in the case of questions or concerns that may arise.

The following whistleblowing channels are available:

  • internal – with confidentiality maintained (contact with the Compliance Officer or the anti-discrimination and anti-mobbing representative),
  • external – with confidentiality and anonymity maintained (contact via Linia Etyki).

Violations are reported internally by contacting the Compliance Officer directly, to the anti-discrimination and anti-mobbing representative, or externally through a dedicated reporting channel – Linia Etyki. The reporting rules are described in the Code of Ethics in the field of AML in the "Procedure for counteracting money laundering and terrorist financing".

In 2021, a total of 11 notifications were received under the Ethics Line and the anti-discrimination and anti-mobbing representative. Some of them required examining the case and considering the notification for possible irregularities, while some were questions that were answered. At the same time, reports and questions were sent directly to Agora's Compliance Officer, as well as to the anti-discrimination and anti-mobbing representative. None of the reports concerned violations of regulations related to the prevention of discrimination or counteracting corruption.

In 2021, as part of the development of the compliance system in the Agora Group, in particular, work was carried out to adapt to the draft act on the protection of persons reporting breaches of the law (the so-called whistleblower act) and work on a uniform repository of procedures, and a project for mapping organizational procedures was launched. It is worth noting that an important change in Agora's compliance area in 2021 was the change in the position of the Compliance Officer and the separation in the organizational structure of the compliance team from the legal department and reporting it directly to the company's Management Board.

As part of communication activities in the compliance area in the discussed year, a monthly Compliance Newsletter was created, sent to all employees of the Agora Group, containing information on, i.a., information system about irregularities, violations and threats to the company or the rules of personal data protection. In addition, Agora's employees could also find content on the ethics and compliance system in the internal newsletter and a special section on the company's intranet.

AGORA

PREVENTING CORRUPTION AND FRAUD

In 2020, the Management Board of Agora adopted the “Policy for receiving and giving gifts and other benefits at Agora S.A.”. That document specifies in particular:

  • what gifts and other benefits are;
  • the rules for receiving and giving gifts and other benefits;
  • the obligation for the company’s employees and collaborators to document gifts and other benefits and the amount thresholds subject to reporting.

The “Policy for receiving and giving gifts and other benefits at Agora S.A.” is closely related to the “Agora’s Code of Ethics” and applies to all employees and collaborators of Agora S.A.

A report on the implementation of the Policy is submitted to the company's Management Board on an annual basis.

ANTI-MONEY LAUNDERING AND COUNTERACTING TERRORIST FINANCING

In 2019, the Management Board of Agora adopted the “Procedure for counteracting money laundering and terrorist financing at Agora S.A.”, which aims at defining the rules and procedures for counteracting money laundering and terrorist financing. In this way, Agora fulfils its obligations arising from the law.

The procedure applies to all persons participating in the activities related to the provision of services involving the maintenance of accounting books for customers. The use of the procedure is mandatory and applies to relationships with all customers. Each employee and collaborator needs to be familiar with this procedure.

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One of the values underlying Agora is respect for human rights. These rights are understood very broadly, both as ensuring a responsible workplace offering decent work, and as preventing all forms of discrimination and mobbing and ensuring equal treatment of all employees. This approach was reflected in the introduction of the “Anti-discrimination and anti-mobbing policy” and the “Diversity Policy”.

AGORA

AGORA

One of the values underlying Agora is respect for human rights. These rights are understood very broadly, both as ensuring a responsible workplace offering decent work, and as preventing all forms of discrimination and mobbing and ensuring equal treatment of all employees. This approach was reflected in the introduction of the “Anti-discrimination and anti-mobbing policy” and the “Diversity Policy”.

The “Anti-discrimination and anti-mobbing policy” is in force in Agora and several subsidiaries of the Agora Group (AMS, Agora Radio Group, Helios, Yieldbird) and serves to create a comfortable workplace that supports diversity.  Its key elements are: 

  • introduction of the function of an anti-discrimination and anti-mobbing representative. Any team member working or cooperating with Agora may contact the representative to consult any concerns or report an undesirable situation;
  • expanding the possibility of reporting concerns, questions or irregularities. With the introduction of the “Agora’s Code of Ethics”, we have launched an anonymous, confidential and secure external channel of communication operated by Linia Etyki– an external expert company;
  • emphasising the role and responsibility of management, who should closely monitor the situation in teams and respond to behaviours and events that involve discrimination or mobbing;
  • examples of undesirable behaviourwhich may be indicative of discrimination or mobbing, and a model notification form. 

In 2019, the Policy was updated in line with the changes introduced in the Labour Code. The information and education activities concerning the “Anti-discrimination and anti-mobbing policy” implemented in 2019 were complemented by a training course in this field, which was made available in 2020 on HCMDeck – an e-learning platform of Agora. The training is mandatory for all employees.

 

The “Diversity policy” is based on overcoming barriers such as age, gender or health. Employees of the Agora Group come from different backgrounds and cultures, exhibit various skills and talents, represent diverse viewpoints and have different life and professional experience. We believe that a diverse team is a driver of creativity, innovation and ingenuity. That is why we appreciate diversity within the organisation so much.

The “Diversity Policy” is the result of the commitment made by the Agora Group in 2017, by joining the signatories of the Diversity Charter as the first media group in Poland. We have thus joined a group of employers from all over Europe who advocate and promote workplace diversity. 

No risks related to child labour, forced labour or other violations of human rights were diagnosed in the activities of the Agora Group. Agora exercises due care in this respect, in accordance with the UN Guiding Principles on Business and Human Rights and the ILO Declaration. At Agora Group, we also understand respect for human rights as respecting the right to freedom of association, the right to privacy, with particular emphasis on the protection of personal data and compliance with the principles of fair competition. We write more about these issues in the Workplace section and in the Relations with the environment section in this Report.

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Due to Agora's scope of activity and its longstanding traditions, journalistic ethics and media ethics are of particular importance to the company. Freedom of expression, independence and reliability are the principles that have been guiding Agora's editors in their day-to-day work for years. Any content created in Agora's media is based on a fair and true message. Reliable sources and operational transparency are crucial.  

In this area, the internal codes of the Agora Group apply, mainly concerning the journalistic profession (Agora's Charter). They set the directions and rules for the work of journalists and publishers employed in the Agora Group's media. Additionally, at Agora S.A. internal regulations concerning the publication of advertisements and announcements have also been implemented.

External industry codes:

The Agora Group also complies with industry self-regulations related to media and advertising activities. These are in particular: 

  • The Media Ethics Charter is a Polish document containing the basic principles of journalistic ethics. As a leading media concern in Poland, we are aware of our responsibility and the impact on the market environment, as well as the role of the media in human life and civil society, which is why we follow the principles set out in the Charter on a daily basis.
  • "Code of good practices of press publishers", i.e. a set of standards in the form of an internal self-checking act of the publishers’ community associated in the Polish Chamber of Press Publisher, as well as other publishers who will join it in subsequent years.
  • "Code of ethics for advertising", which is a generally applicable standard of marketing communication in Poland. It forms a set of principles to be followed by entrepreneurs, in paricular advertisers and other legal and natural persons and organisational units without legal personality engaged in advertising activities.

The Agora Group makes every effort to ensure that the above principles are implemented as expected by the stakeholders. It makes sure that advertisements broadcast by the Group's media are compliant with applicable laws and good practices. Also, advertisements of products/industries that are questionable or associated with increased risk are additionally accepted by lawyers.

Moreover, we undertake all our activities in accordance with the legal order in force in Poland. As a company listed on the Stock Exchange, we also comply with the principles contained in the "Best Practices of WSE Listed Companies" published both in 2016 and 2021, which affect our relations with the market environment.