Ethical business

Ethical business

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ETHICAL BUSINESS DEVELOPMENT

Given the scope of Agora's activities and its long-standing traditions, journalistic ethics and media ethics are of particular importance to us. Freedom of speech, independence, and credibility are principles that have guided Agora's editorial teams for years in their daily work. All content produced by Agora's media is based on reliable and truthful reporting. Reliable sources and transparency are important.

DUE DILIGENCE

CODE OF ETHICS AND COMPLIANCE SYSTEM
CORPORATE CULTURE
MEDIA ETHICS

Agora's Code of Ethics is a key document indicating the set of values and principles of conduct expected at Agora and defining those which the company considers inappropriate or unacceptable. It is addressed to all employees and associates of the company, regardless of their function or position in the company.

In particular, the document includes:

The principles to be followed by employees, associates and management in their relations with all the Company's stakeholders.
A summary of the most important internal regulations covering areas relevant to the Company's operations and the values indicated in the ‘Agora Code of Ethics’.
Information on channels and ways to report irregularities at Agora.
Contact details for persons who can provide information and clarification on ethics-related topics.
Communication of our values and principles to business employees and all stakeholders.
Education of employees and colleagues.
Cyclical monitoring of ethical risks.
Inclusion of ethics considerations and compliance with the Code of Ethics in the annual employee appraisal system.
Persons responsible for coordinating the implementation of the ethics system, including the compliance officer.

Agora's Code of Ethics is supplemented by:

Agora's internal procedures, in particular: Agora Group Diversity Policy, Policy on Receiving and Giving Gifts and Other Benefits at Agora S.A., Policy on Social and Sponsoring Activities at Agora Group, Code of Good Practices in Customer Service at Agora Group, Environmental Policy at Agora S.A., Compliance Policy at Agora S.A.
External industry codes adopted as applicable at Agora, in particular: Media Ethics Charter, Code of Advertising Ethics, Code of Good Practice for Press Publishers.

Training on Agora's Code of Ethics is available on Agora's internal training platform and every employee, associate and executive is required to be familiar with its content.

SYSTEM FOR REPORTING INFRINGEMENTS

As of May 2023, Agora has two procedures in place to regulate the whistleblowing system: The Procedure for ReportingInfo rmation of Violations and the Procedure for Conducting Investigations. The first of these documents
The first of these documents contains content relevant to a person considering making a report - there is information about reporting channels, the principle of confidentiality and general information about the process of recognising a report. The Investigation Procedure, on the other hand, regulates the process of investigating a case through to its conclusion, i.e. the production of a report and the monitoring of the implementation of recommendations. This procedure ensures that every whistleblowing report is investigated fairly, based on transparent principles.

At Agora, the whistleblowing system does not limit reporting to employees and co-workers only. Business Partners and value chain representatives can also report. If there are suspicions or signals of violations or other irregularities on the part of the Agora Group or persons acting on its behalf, of which an employee from a given value chain has become aware in connection with cooperation with one of the companies in the organization, he or she may report anonymously through the external Ethics Line channel (e-mail: agora@liniaetyki.pl, website: agora.linieetyki.pl), or contact directly the Chief Compliance Officer of the Agora Group ( e-mail: etyka@agora.pl).

Agora fully supports the tenets of the Universal Declaration of Human Rights and the Charter of Fundamental Rights of the European Union and systematically implements them by setting appropriate standards of conduct and introducing relevant internal regulations. These documents are in line with international conventions and guidelines, taking into account, among others:

UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental
principles and rights at work, the principles and rights set out in the International Bill of Human Rights and the United Nations Convention against Corruption.
OECD Guidelines for Multinational Enterprises.
10 Principles of the UN Global Compact.
Good practices of the WSE 2021.
UN Global Compact principles and the UN Sustainable Development Goals (SDGs).
Task Force on Climate-Related Financial Disclosures (TCFD).

As of 2023. Agora is a member of the UN Global Compact.

Given the scope of Agora's activities and its long-standing traditions, journalistic ethics and media ethics are of particular importance to Agora. Freedom of speech, independence, and credibility are the principles which have guided Agora's editorial teams for years in their daily work. All content produced by Agora's media is based on reliable and truthful reporting. Reliable sources and transparency of operations are important, and internal regulations on the publication of advertisements and announcements are also implemented.

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

Media Ethics Charter, a document containing the basic principles concerning journalistic ethics. As a leading media concern in Poland, we are aware of our responsibility and of the impact and influence we have on our surroundings, as well as of the role of the media in the life of people and civil society, which is why we are guided by the principles set out in the Charter on a daily basis.
The Code of Good Practice for Press Publishers, which is a set of norms in the form of an internal act of self-control for the community of publishers associated with the Chamber of Press Publishers, as well as other publishers who will join it in the coming years.
The Code of Ethics for Advertising, which is a generally applicable standard for marketing communication in Poland. It constitutes a set of principles to be followed by entrepreneurs, including in particular advertisers and other legal persons, 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 in accordance with stakeholder expectations. It ensures that advertisements broadcast by the Group's media comply with the applicable law and good morals. In addition, advertisements for high-risk and questionable products or industries are subject to legal review.

ESG STRATEGY
AREAS OF IMPACT
VALUE CHAIN
STAKEHOLDERS

In setting the business directions of all segments, the company's management has set its sights on the growth of the entire Agora Group conducted in a sustainable, socially responsible manner. Therefore, in May 2023. Agora has developed the first strategy for sustainable development in its history, namely the Agora Group ESG Strategy for 2023-2027.

The document takes into account the principles and recommendations referring to, among other things, actions towards the set goals, adherence to current standards, as well as the implementation of the UN's Agenda 2030 and the demands set out in the Paris Agreement.

Agora integrates sustainability issues into its business model through activities such as:

Investing in pro-environmental projects.
Engaging in social issues.
Promoting innovation and responsible business practices in all areas of operations.

The basis for setting Agora's strategic goals in the area of sustainability was the analysis of the elements of the value chains of the various operating segments during the study of climate risks and opportunities, and the scenario analysis performed during the materiality study.

Integrating sustainability issues into its business model, Agora focuses in particular on social and labor aspects by, among other things, promoting popular science, news and cultural content that builds public awareness of ESG issues, joins social and philanthropic initiatives with projects for media education, freedom of speech and media pluralism, among others. In addition, it promotes issues of diversity and inclusiveness both in society and in the workplace, and continuously undertakes activities for gender equality and the reduction of social inequalities, among others.
In relations with the environment, it focuses on practicing ethical standards in its relationships with customers and business partners.

Detailed goals in all three areas, with indicated values and benchmarks, are presented in the Agora Group's full ESG Strategy for 2023-2027, which can be found here - LINK.

An integral part of the ESG Strategy for 2023-2027 is the AMS Environmental Strategy for 2023-2027 - the first document of its kind in the OOH industry.

Key stakeholders of the Agora Group - purpose and methods of communication

Stakeholder category	Method of engagement	Purpose and topics covered
Users, readers, subscribers, listeners, viewers and individual customers	Mailing. Direct meetings and cultural events. Surveys and opinion polls.	Access to information. Valuable and independent content, promotion of local creators and authors.
Business partners, including corporate clients	Direct meetings.	Business plans, performance indicators.
Suppliers and subcontractors	Ongoing contact and cooperation throughout the year.	Terms of business and timeliness of payment.
Employees and associates	Agora Group's internal communication system. Internal meetings and special events. Intranet, newsletter and Teams app. Participation in the ESG materiality study and the climate risk study.	Working conditions and professional development.
Trade unions	Contact and cooperation on an ongoing basis throughout the year.	Staff issues.
Regulator	Corporate website, Current and periodic reports.	Timeliness and quality of corporate documents reported.
Shareholders and investors	Corporate website. Face-to-face meetings and teleconferences. Outcome conferences. Annual General Meeting of Shareholders.	Agora Group's business strategy, including ESG strategy. Financial performance.
Financial institutions	Corporate website. Face-to-face meetings and teleconferences. Outcome conferences.	Agora Group's business strategy, including ESG strategy and compliance with the EU taxonomy. Financial performance.
Local communities	Mass media and social media. Local events and/or for selected local communities. Activities carried out in collaboration with partners.	Identification of social problems. Creating business value for society.
Intermediaries and dealers	Ongoing contact and cooperation throughout the year.	Terms of business and timeliness of payment.

DOUBLE MATERIALITY
MANAGMENT OF ESG ISSUES
SIGNIFICANT ESG RISKS
ESG/CSR REPORTING

When defining material ESG issues for the Agora Group for 2023-2027 in the fourth quarter of 2021, a materiality survey process was conducted for the first time, as required by the EU CSRD.

In October 2023, through a process conducted with the organization's management, the survey was updated and fully aligned with the requirements imposed by the EU ESRS reporting indicator. Originally, the survey was conducted using an extended questionnaire method for different groups of company stakeholders. ESG issues were examined in terms of five parameters in two perspectives (double materiality principle): four impact parameters - the strength of impact, the extent of impact, the likelihood of impact and the possibility of remedying the impact, and one parameter of financial materiality, i.e. the impact of the ESG issue on the development, performance and business situation of the Agora Group. In addition, a study of the materiality of ESG issues from the perspective of the company's external stakeholders (financial institutions, representatives of Agora S.A.'s shareholders and external experts in the ESG area) was conducted, with whom in-depth and structured interviews were also conducted

The survey included financial materiality, i.e. analyzed the impact and risk that Agora Group has on the environment and society, and impact materiality, i.e. analyzed the impact that Agora has on environmental and social issues. The results of the various stages of the study were presented to representatives of the Agora Group's Board of Directors and senior management during a validation workshop, and were subsequently consolidated. The study considered the following sources of information, among others:

Analysis of source data

Comprehensive survey conducted on a group of 25 representatives of the Board of Directors and senior.
Company and group executives and a group of 4 external experts.
Structured interviews with 7 representatives of external stakeholders from the Company's environment.
Comparative analysis of 16 companies in the industry.

Matrix analysis of the results

The study included components of analysis of risks related to a particular area, as well as multidimensional impact within the areas mentioned. The materiality study was accompanied by the process of developing the organization's value chain, and the analyzed impacts and risks were then related to the processes carried out in that area.

The strength of the Agora Group's influence (direct or indirect) on an issue

The strength of the impact determines how serious the effects of the impact can be. In the case of environmental issues, it is about environmental damage. For social issues, it is about the negative effects on individuals or groups of individuals.
The scope of the impact determines how widely the effects of the impact can reach. In the case of environmental issues, it will be a geographic area. For social issues, the scope can be understood as the number or percentage of people affected.
Likelihood of impact determines whether the impact is currently occurring or is likely to occur in the future.
Remediability determines whether it is possible to remediate the impact of the Agora Group's impact on an issue, and if so, how complicated, time-consuming or resource-intensive it is.

Financial materiality in relation to the issues studied was assessed on the following scales:

While the three parameters of impact materiality examined how the Agora Group directly or indirectly influences the issue in question, in this case it examined how the issue affects today and may in the future affect the operations of Agora's business segments. Among other things, this impact may relate to the current or future value of the company's assets or liabilities (e.g., to an extent that is not recorded in the financial statements).

It may also concern how financial flows will develop; whether the issue will cause the company to record greater or lesser positive or negative financial flows in the future. Finally, it may concern the types of capital that the company uses, but which are not recorded in financial statements (e.g., natural, human, intellectual, social or relational capital).

ESG issues for which impact materiality or financial materiality reached the level of important or higher were considered significant. The survey and interviews with external stakeholders confirmed the overall results of the materiality assessment and brought additional insight into some ESG topics.

In turn, the results of the materiality survey were taken into account in the process of developing the Agora Group's ESG Strategy 2023-2027, which is an integral part of the Agora Group's strategic directions for 2023-2026.

The management team, realizing the impact of Agora's operations on the environment, local communities, employees and the market environment, has incorporated sustainability issues into the organization's management process. Therefore, as part of the order issued by Agora's CEO in November 2022. On September 7, 2022, an ESG department was established in the Agora Group.

The head of the department directly reports the effects and status of projects at least once a week to the member of the Board of Directors responsible for managing ESG issues in the Agora Group. In order to obtain additional knowledge and support in the area of sustainability, he uses substantive training and the services of external advisors, whose conclusions and recommendations he presents to the management and supervisory bodies. In this way, it ensures that administrative, management and supervisory bodies are regularly informed about, among other things, legislative changes and best practices in the area of building an ESG management process throughout the organization.

Sustainability issues are regularly raised at meetings of the board of directors, supervisory boards or other decision-making bodies to ensure that these topics are continued and considered in business and management decision-making, taking into account, among other things.business and management decisions, taking into account efforts to achieve the stated goals of Agenda 2030 and the objectives of the Paris Agreement.

In 2023. Agora developed its first-ever ESG Strategy for 2023-2027, which lays out a concrete action plan for achieving sustainability goals across all business segments, led by the head of the ESG department. The designated member of Agora S.A.'s Board of Directors is directly responsible for overseeing its work and making strategic decisions. In doing so, the Board strives to ensure compliance with the highest standards of corporate governance, minimize risks related to social and environmental aspects, and build a positive image as a responsible market participant.

In conducting the materiality test in the formula applied to ESG risks in 2021, terminology was used in accordance with the methodology adopted by the ISO 31000 family of risk management standards.

Risk factor/trend: the cause of a risk that can cause it to occur. Risk factors are trends and phenomena external to the organization and it has no control over their occurrence.
Risk: the effect of uncertainty on an organization. Risk is a situation in which there is uncertainty about the effect of a certain process and as such is neutral to the organization. Risks can have different effects: they can be positive (opportunities) or negative (threats) - the same risk can also have both positive and negative effects. Risks are measured in two dimensions: their severity (strength of potential effects) and probability.

As a result of the materiality study, the following risks were identified:

Report CSR 2016 Report CSR 2017 Report CSR 2018 Report CSR 2019
Report CSR 2020 Report ESG 2021 Report ESG 2022 Report ESG 2023

Would you like to report a irregularity or discuss the ethics system at Agora?

Contact us

RESPONSIBLE BUSINESS

ESG Department
Agora S.A.
Czerska 8/10 Street
00-732 Warsaw

esg@agora.pl

Justyna Przybył

Head of Sustainability & ESG

justyna.przybyl@agora.pl

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Company data

Ethical business

ETHICAL BUSINESS DEVELOPMENT

DUE DILIGENCE

SYSTEM FOR REPORTING INFRINGEMENTS

Key stakeholders of the Agora Group - purpose and methods of communication

Stakeholder category

Method of engagement

Purpose and topics covered

Users, readers, subscribers, listeners, viewers and individual customers

Business partners, including corporate clients

Suppliers and subcontractors

Employees and associates

Trade unions

Regulator

Shareholders and investors

Financial institutions

Local communities

Intermediaries and dealers

Analysis of source data

Matrix analysis of the results

The strength of the Agora Group's influence (direct or indirect) on an issue

Financial materiality in relation to the issues studied was assessed on the following scales:

Would you like to report a irregularity or discuss the ethics system at Agora?

Contact us

RESPONSIBLE BUSINESS

Justyna Przybył

Social impact