Compliance and our policies
JSW heavily emphasises corporate responsibility, respect for human rights, environmental protection and combating corruption and abuses both within the Group and in its business environment.
Every effort is made to operate and build our market position on respect for the rule of law, good commercial practices and the highest ethical standards. JSW's market position and reputation are the effect of consistency in doing business in the country and abroad in line with our values. Protecting and strengthening all JSW Group companies in these areas are one of the priority targets of the regulations we are implementing throughout the Group.
1. COMPLIANCE SYSTEM
Guaranteeing compliance with international standards is the Group's established compliance system, which includes regulatory and organizational solutions that together comprise an internally integrated compliance management system. The compliance standards adopted in the Group cover all its participants and remain uniform in the full scope. The compliance regulations adopted in JSW, which are compliance system components, are as follows:
Code of ethics
It includes a declaration promoting ethical commitments and prevention of corruption. As of January 2018, an ethics clause was introduced for use in contracts with contractors, which imposes certain obligations on participants in the Group's value chain to comply with ethical principles. Currently, a Business Partner, its subcontractors and all other persons with whose assistance it performs a contract are required to review the JSW Group’s Code of Ethics and adhere to the standards laid down thereunder.
HUMAN RIGHTS POLICY
It complements the Code of Ethics and elaborates on the respect for fundamental human rights underlying the Group's sustainable development. The Policy is based on key values aimed at respecting human rights and preventing the Group's actions from directly or indirectly violating human rights.
COMPLIANCE POLICY
The Policy is the key document regulating the manner in which the compliance function is implemented. It provides a division of the related responsibilities and powers among individual organizational units and presents the procedures and methods for examining notifications and conducting investigations. The main objective of the Policy is to prevent and limit the consequences associated with the occurrence of irregularities in the Group by regulating the management structures of this area of business, as non-compliance with laws and other regulations can have far-reaching negative consequences for the Company.
IRREGULARITY REPORTING PROCEDURE
The procedure defines the rules for reporting violations or abuses by Group employees, associates and others in order to prevent damage to Group companies and ensure a prompt response to the violation or abuse, and embodies the law, accepted market standards and rules of conduct.
Anti-Corruption Policy
The Policy defines the rules and obligations of employees related to the prevention of the occurrence of corrupt phenomena and constitutes an unequivocal condemnation of corruption, which is defined in the adopted policy. Contractors of JSW and other Group companies declare their rejection of corruption, bribery and any other form of influence that may be contrary to the law or good morals. The Group has anti-corruption clauses in place, which are a declaration of rejection of all forms of corruption, as well as sanctioning certain ways of dealing with suspected corruption.
CONFLICT OF INTEREST MANAGEMENT POLICY
The Policy contains guidance for resolving conflicts between interests of the Company and personal interests of its employees and other obligated entities. The Policy also defines the methods in place to prevent and manage conflicts of interest and sets out the rules to mitigate, to the maximum extent practicable, any possibility of such conflict occurring
BUSINESS PARTNER VERIFICATION POLICY
The Policy governs the cooperation with clients/ business partners and sets out the minimum requirements with regard to verifying business entities with which business relations are to be established.
POLICY ON THE HIRING OF PERSONS CLOSELY ASSOCIATED AND RELATIVES
The policy is applicable to all employees and management board members and pertains to the reciprocal relations between persons employed in a given company. The clauses of the policy supplement the principles in force in the company pertaining to hiring, bonuses, promotions, penalties, meting out sanctions to workers and establishing and termination cooperation. This policy defines persons closely associated and relatives, it defines the principles for hiring and cooperating with persons closely associated and relatives, the relations between employed persons, the duty of reporting irregularities and the consequences ensuing from a failure to apply a given policy.
GIFT POLICY
This policy lays down the principles and conditions to fulfill when presents are received or given, solely in circumstances when this is related to the performance of entrusted tasks. The established principles specify the limits for gifted items and presents received and the reporting dues related to them. Moreover, this policy bans gifting any presents or invitations to public officials in any instance in which they could be deemed to be a form of exerting pressure on the integrity with which they perform the duties entrusted to them.
CHARITABLE AND PROMOTIONAL POLICY
This policy contains information on the conditions and rules for promotional and charitable activity conducted by Group companies. The policy specifies the guiding principles that must be followed to avoid allegations of fraud, corruption or preferential treatment. At present, this policy is being revised to adjust its clauses to the other internal regulations, and also on account of the necessity of strengthening control over these areas from JSW’s vantage point.
The components of the Compliance System that prevent and brand corruption as a negative phenomenon in the Group include the following: JSW Group’s Code of Conduct, Anti-Corruption Policy of the JSW Group, JSW Group’s Gift Policy, Whistleblowing Procedure in the Group, which have been described in the Compliance System. The Anti-Corruption Policy defines the rules and obligations of employees related to the prevention of the occurrence of corrupt phenomena and constitutes an unequivocal condemnation of corruption, which is defined in the adopted policy. The principles described therein apply to each of the Group companies. All Group companies were required to implement the Policy with respect to their management board members, employees, associates, contractors, agents and representatives and their subordinate entities with whom they have a direct relationship (obligated entities). In order to combat corruption, companies apply internal procedures, which are both organizational and financial in nature. They are used among others to monitor and review the practices in the business partner selection area, signing of agreements, accounting and storage of documents. Every obligated entity is required to report any irregularities and other circumstances that may raise concern, in particular that may raise a suspicion of corruption.
As of 2021, ethics and anti-corruption clauses have been made mandatory in contracts to which Group companies or units are parties.
2. RESPECT FOR HUMAN RIGHTS
The position of JSW and the overall Group entails a major ethical obligation. This in particular results from the obligation of shaping responsible and ethical patterns of conduct in internal relations and in relations to which Group companies are parties. As a Group, we want to join the world leaders in corporate social responsibility, observance of human rights, environmental protection and prevention of corruption and fraud in the Group and in its environment.
The Parent Company and its subsidiaries undertake to respect human rights as laid down in the Universal Declaration of Human Rights with special emphasis on all people being born free and equal in terms of dignity and their rights and not accepting any forms of differentiation or discrimination of people, and as a result, on ensuring equal opportunity regardless of race, skin color, gender, language, religion, political views or other convictions, nationality, social background, assets, birth or any other differences. The Group feels obligated to take special care with regard to the risks associated with violations of any of these laws in the operations of both the Group and the industry in which it operates.
In 2022, the JSW Management Board adopted the Group's Human Rights Policy for application, which elaborates on issues concerning respect for fundamental human rights underlying the Group's sustainable development. The Policy is based on key values aimed at respecting human rights and preventing the Group's actions from directly or indirectly violating human rights. The human rights policy is manifested in, among other things:
- Compliance with principles relating to the protection of human rights,
- Enabling the reporting of irregularities, including those involving human rights,
- Taking into account human rights in relations with business partners,
- Public involvement in activities that are directly or indirectly part of the realization of human rights.
STANDARDS AND NORMS OF CONDUCT
We impose high requirements on ourselves and we expect that both our employees and customers, suppliers, subcontractors and third parties with which we cooperate will undertake this effort together with us through recognizing the principles and complying with the standards.
| The Group is committed to the following values: | The Group operates in accordance with the following standards: |
|---|---|
|
|
The issues related to the respect for human rights in the Group many be divided into the following categories:
- respect for rights, including in particular personal freedoms, of persons working for the Group,
- respect for the freedom of association and the right to take part and organize peaceful demonstrations.
Link between JSW Group activity and human rights
|
Human rights 1 |
Link with courage and JSW Group's response |
|---|---|
|
„All human beings are born free and equal in dignity and rights." (Art.1) "Everyone is entitled to all the rights and freedoms […] without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status." (Art. 2) |
JSW Group is not merely committed to respecting this approach but also, through its Compliance System, including the Code of Ethics, it provides additional mechanisms that guarantee a response to violations: from training, whistleblowing system to treating violations as breaches of employment contracts (with all that this entails). |
|
Citizens' rights and political rights |
|
|
"Everyone has the right to life, liberty and the security of person." (right to life) (Art. 3) |
JSW Group is aware of the risk to life and health that is associated with mining and the further processing of coal with regard to employees, the personnel of external entities working at JSW Group's sites and third parties. To radically reduce this risk, the Group has a proven occupational health and safety management system, which is continuously being improved. These solutions often go beyond the minimum standards. A particular example were donations of plasma by our miners, thanks to which it was possible to develop a Polish drug (Biomed Lublin) saving the lives of people having a hard time going through the disease. Out of the 150 litres of plasma collected in the country, 100 litres were donated by JSW employees. Conducting practically every type of economic activity is related to direct or indirect impact on the natural environment, the state of which affects human health in both local and global dimensions. JSW Group is aware of its considerable impact on the natural environment and is taking steps to minimise it, including by embracing the target of low-emission economy, additional utilisation of raw materials and the circular economy model, as well as minimising the emission of pollutants and protecting local biodiversity. It should be mentioned that all new solutions are not only compliant with the law but often go beyond what is required under administrative permits, the best example of which is the desalination of mine waters at the facility in Dębieńsko. In 2019, JSW Group also decided to close down one of its coking plants ahead of schedule as it was controversial for the local community specifically due to health concerns. At the same time, it is worth remembering that JSW Group's products are indirectly used in a way that contributes to human life and health protection. Without these products, it would not be possible to produce steel with specific parameters that, for example, ensure the safety of vehicle passengers (collision energy absorption by crush zones) or surgical steel, which is essential in modern medicine. The carbon-related products supplied by JSW Group also constitute a raw material in numerous industries, including pharma. "Health and safety" is also a pillar of JSW Foundation's charity work. |
|
No one shall be held in slavery or servitude; slavery and the slave trade shall be prohibited in all their forms (personal freedom and safety) (Art. 4) |
JSW Group does not accept slavery, forced labour, child labour or human trafficking in any shape or form, as reflected in JSW Group's Code of Ethics. At the same time, risk associated with these issues in JSW's business is marginal. |
|
No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment (prohibition of torture) (Art. 5) |
JSW Group does not accept cruel, inhumane or degrading treatment in any shape or form. Suspicions can and should be reported using the tools available as part of the Compliance System. |
|
"Everyone has the right to recognition everywhere as a person before the law." (Art. 6) "All are equal before the law and are entitled without any discrimination to equal protection of the law. All are entitled to equal protection against any discrimination in violation of this Declaration and against any incitement to such discrimination. (Art. 7) |
These mechanisms are provided by the Compliance System, which includes the JSW Group Code of Ethics and JSW Group's Procedure for reporting irregularities. |
|
"Everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights granted him by the constitution or by law." (Art. 8) "Everyone is entitled in full equality to a fair and public hearing by an independent and impartial tribunal, in the determination of his rights and obligations and of any criminal charge against him." (Art. 10) (right to fair trial) "Everyone charged with a penal offence has the right to be presumed innocent until proved guilty according to law in a public trial at which he has had all the guarantees necessary for his defence." […]” (Art. 11) |
This is not applicable, although by analogy to courts, this right is available through the tools available in the Compliance System, especially JSW Group's Procedure for reporting irregularities. |
|
"No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks."(Art. 12) (right to privacy) |
JSW Group respects the privacy of third parties, including employees and their families. The right to protection and privacy of personal and family life is listed in JSW Group's Code of Ethics. Potential actions by superiors that interfere with an employee's family or are degrading for the employee will be treated as a violation of the adopted rules. JSW Group has an information security system, including safeguards for personal data the disclosure of which could be considered as a privacy breach. |
|
"Everyone has the right to own property alone as well as in association with others. No one shall be arbitrarily deprived of his property." (Art. 17) (right to ownership) |
JSW Group respects the property of third parties, especially in situations where mining operations cause or might cause damages to third-party property. This is manifested in work planning, which is accompanied by dialogue with the community, and in rectifying damages and paying out appropriate compensation to persons who have suffered damages due to operations. JSW Group's activities in the past year and in the previous years did not necessitate the forced relocation of anyone. |
|
"Everyone has the right to freedom of thought, conscience and religion; this right includes freedom to change his religion or belief, and freedom, either alone or in community with others and in public or private, to manifest his religion or belief in teaching, practice, worship and observance."(freedom of conscience and religion) (Art. 18) "Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers." (freedom of speech) (Art. 19) |
These rights are guaranteed in the Code of Ethics. However, it should be noted that this applies to private views, and their presentation should not suggest that the person is speaking on behalf of JSW Group. At the same time, the right to speak on behalf of JSW Group is reserved for Management Board members and people delegated by them (e.g. spokesperson). Any attempts to limit these freedoms or discriminate on the grounds of views or religion in relations between employees will be met with a response by the management in accordance with the mechanisms included in the Compliance System. It should also be noted that JSW Group has for years been supporting various churches and religious associations (e.g. funding for renovations), thus supporting the exercise of this right by employees and other local community members. |
|
"Everyone has the right to freedom of peaceful assembly and association. No one may be compelled to belong to an association. (freedom of assembly and association) (Art. 20) |
JSW Group does not interfere in whether and how its employees participate in public life to express their world-views. The only stipulation is that the employees should not suggest that they are acting in a capacity other than as a private person, i.e. as someone representing JSW Group. Another restriction involves the apolitical stance of JSW Group and applies to members of its governing bodies. Any person who: is a member of a body representing a political party externally, is authorised to incur liabilities for a political party or is employed by a political party; has been elected for a trade union position at any of the Group companies; serves as social associate or is employed at the office of a parliament member, senator or MEP; engages in social or paid activity that gives rise to a conflict of interests with the company's activities, may not be a member of the Management Board. This restriction is intended to remain apolitical and in consequence protects the freedom of world-view for the employees. |
|
"Everyone has the right to take part in the government of his country, directly or through freely chosen representatives. […] (right to free choice)(Art. 21) |
Although this is not applicable, JSW Group extends to its employees the right to actively and passively select a Management Board member and Supervisory Board members to represent them. |
|
"Everyone, as a member of society, has the right to social security […]” (Art. 22) "Everyone has the right to work, to free choice of employment, to just and favourable conditions of work and to protection against unemployment. Everyone, without any discrimination, has the right to equal pay for equal work. Everyone who works has the right to just and favourable remuneration ensuring for himself and his family an existence worthy of human dignity, and supplemented, if necessary, by other means of social protection. Everyone has the right to form and to join trade unions for the protection of his interests. (Art. 23) |
JSW Group wants to be the employer of choice for its employees, offering them both fair pay and friendly working conditions. In the case of the restructuring of the KWK Krupiński mine that took place in recent years, the Group strived to protect jobs (in effect, every worker at KWK Krupiński received an employment offer from another JSW mine). JSW Group also strives to monitor and eliminate any instances of wage discrimination and comprehensively approaches dialogue with its employees, fully respecting the rights of trade unions and their members. |
|
"Everyone has the right to rest and leisure, including reasonable limitation of working hours and periodic holidays with pay." (Art. 24) |
JSW Group not only respects the existing laws concerning holidays but also has vacation sites that can be used by its employees. It also tries, in as far as budget allows, to extend and enhance the offering of sports and cultural events for employees. JSW Group has for years been promoting active leisure and sport activity, both professional and amateur, including competitions for kids. JSW Group also finances summer holidays for children from a Jastrzębie-based orphanage, which constitutes one of the pillars of JSW Foundation's charity work. |
|
"Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control." Motherhood and childhood are entitled to special care and assistance. All children, whether born in or out of wedlock, shall enjoy the same social protection." (Art. 25) |
JSW Group strives to offer fair employment terms so that employees can ensure a good level of life for their families. Further, JSW cares for the families of miners who have died at work (psychological help, financial aid, employment). Special care is reserved for children from a Jastrzębie-based orphanage, with a view to offering them better conditions as they proceed into adult life. JSW has been implementing its own social programme "JSW for Kids" for several years. |
|
"Every human has the right to education. Education is free, at least on a primary level. Primary education is mandatory. Technical and professional education shall be made generally available and higher education shall be equally accessible to all on the basis of merit." (Art. 26) |
JSW comprehensively supports employees in their development. It is also active in education within the mining profession in schools throughout the region. It has established long-term relationships with a range of universities. It also is involved in research projects with universities. JSW has for years been implementing its own project "JSW Mine of Knowledge," which is addressed to children. At the same time, the "Science and education" area is one of four segments continuously supported by JSW Foundation. |
|
„[...] and is entitled to realization, through national effort and international co-operation and in accordance with the organization and resources of each State, of the economic, social and cultural rights indispensable for his dignity and the free development of his personality." (Art. 22) "Everyone has the right freely to participate in the cultural life of the community, to enjoy the arts and to share in scientific advancement and its benefits. Everyone has the right to the protection of the moral and material interests resulting from any scientific, literary or artistic production of which he is the author." (Art. 27) |
By joining R+D+I projects with multi-million budgets, JSW Group makes a contribution to the development of practical solutions and implementations of scientific achievements and thus also to the fact that citizens can benefit from scientific accomplishments. It also tries to act in a way that makes it possible to pass tangible and intangible heritage related to the areas where it operates onto the future generations. This is often heritage of the latest history, for example the Jastrzębie Accord, which is so strongly related to the mines in Jastrzębie-Zdrój. This is also remembrance about times past and special concern for mining craft tradition, including the Chamber of Tradition at KWK Knurów, established in 1997, and the virtual exhibition. "Culture and tradition" is one of four areas continuously supported by JSW Foundation. |
*The list below presents individual human rights listed in the Universal Declaration of Human Rights adopted on December 10, 1948 by the United Nations Assembly. It omitted individual articles/rights that are not relevant and do not find direct analogies for business activities, i.e. Article 9 (prohibition of arbitrary arrest, detention or exile), Articles 13-16 (free movement and choice of place residence, right to asylum, citizenship, marriage).
3. DIVERSITY POLICY
Since 2021 the Parent Company has had in place JSW S.A.’s Diversity Management Policy. Its aim is to communicate the commitment of the JSW Management Board and the management team to ensuring equal treatment, promotion of equal opportunity and guaranteeing diversity, to create a diversified work environment for employees, which will ensure the Company’s efficient and innovative operation. The key areas for implementing this Policy are as follows:
- openness to diversity,
- recruitment, selection and development of employees,
- development of future managers and ethical standards,
- countering mobbing and discrimination,
- solving problems and conflicts.
In its activities the Parent Company applies clear employment rules and strives to ensure diversity in terms of gender, area of education, age and professional experience for all its employees with a special focus on JSW’s governing bodies and its key managers. The selection process does not in any way disqualify candidates on account of any of the diversity policy elements specified in this principle. With reference to members of the JSW governing bodies, i.e. Management Board and Supervisory Board, the persons discharging Management Board Member functions are selected by the Supervisory Board, and Supervisory Board Members, with the exception of the situations described in the Articles of Association, are appointed and dismissed by the Shareholder Meeting.
| DIVERSITY IN MANAGEMENT BOARDS AND SUPERVISORY BOARDS OF GROUP COMPANIES | 2022 | 2021 | ||||
|---|---|---|---|---|---|---|
| WOMEN | Man | Total | WOMEN | Man | Total | |
| MANAGEMENT BOARDS | 5 | 32 | 37 | 6 | 34 | 40 |
| age 30-50 | 1 | 17 | 18 | 3 | 16 | 19 |
| age over 50 | 4 | 15 | 19 | 3 | 18 | 21 |
| of which foreigners | - | - | - | - | - | - |
| SUPERVISORY BOARDS | 18 | 63 | 81 | 22 | 58 | 80 |
| age under 30 | - | 1 | 1 | - | - | - |
| age 30-50 | 11 | 30 | 41 | 11 | 31 | 42 |
| age over 50 | 7 | 32 | 39 | 11 | 27 | 38 |
| of which foreigners | - | - | - | - | - | - |
It is the professional qualifications of employees that are seen as important in the Group's organizational culture. The Group has in place the Code of Ethics, which reflects the ethical values that the JSW Group follows and wishes to respect. One of the main values is to observe the prohibition of any discrimination, while guaranteeing freedom of expression, conscience and religion and freedom of belief and speech. Due to the distinct nature of the Group’s business, men represent the predominant percentage of its workers. Group companies pursue an anti-mobbing and anti-discrimination policy through constant development of employee awareness in this respect.
4. JSW's anti-harassment and anti-discrimination policy
The Group promotes the culture of freedom from any negative behavior that might contribute to the occurrence of factors leading to workplace mobbing or discrimination. Group companies pursue an anti-mobbing and anti-discrimination policy through constant development of employee awareness in this respect.
In the Parent Company, to fine-tune the regulations, with special focus on adding issues associated with discrimination and sexual harassment, in 2020 the document entitled JSW S.A. Anti-Mobbing and Anti-Discrimination Policy was amended. Not all Companies have a separate document devoted to the prevention of mobbing, but this issue has been described in the Work Bylaws. None of the undesirable phenomena are prevalent in the Group.
In 2021, the Parent Company introduced another amendment to the Anti-Mobbing Policy in cooperation with the Foundation for the Support of Anti-Mobbing Measures and Organization Development and instructed the Group companies to implement the aforementioned document as well. In connection with the amendment of the Anti-Mobbing Policy, from 2021 the Group companies are required to provide JSW with annual reports on reported violations of the policy.
| Group JSW | 2022 | 2021* |
|---|---|---|
| MOBBING | 3 | 7 |
| EMPLOYEE DISCRIMINATION | 0 | 1 |
| *As a result of the commission’s work: 1 case was classified as mobbing, in 6 cases no mobbing was identified | ||
5. COMPENSATION SYSTEM FOR MEMBERS OF THE MANAGEMENT BOARDS OF GROUP COMPANIES
Since 7 December 2021, the Compensation Policy for Corporate Bodies of JSW’s Subsidiaries has been in force in the Group, which updates prior regulations pertaining to the compensation of the corporate bodies of JSW’s subsidiaries. This update was associated with implementing different regulations pertaining to JSW’s key employees (a distinct Compensation Policy for JSW’s Management has been adopted in this respect) from the regulations pertaining to the compensation of the corporate bodies of JSW’s subsidiaries. The JSW Management Board’s control over the compensation paid to members of the subsidiaries’ corporate bodies has been extended in addition to specifying hitherto solutions in greater detail.
6. REMUNERATION OF SUPERVISORY BOARD MEMBERS OF THE GROUP COMPANIES
The rules governing the determination of compensation of the Supervisory Board Members of the Group companies have been adopted by way of resolutions of the General Meeting or Shareholder Meeting of the respective company in accordance with the regulations laid down in the Act on the Rules for Shaping the Compensation of Persons Managing Certain Companies of 9 June 2016. Moreover, the Compensation Policy for Corporate Bodies of JSW’s Subsidiaries which regulates the compensations of, inter alia, the Supervisory Board Members of the Group companies has been in effect since 7 December 2021.
7. JSW Group's enterprise risk management policy and procedure
The aim of enterprise risk management is to identify potential events and risks that may have an impact on the organisation, to maintain risk within set boundaries and to reasonably ensure that business objectives are achieved. This is a continuous process, subject to modifications in response to the changing economic environment, the Group's operations and the impact of specific risk on the Group's business objectives. Enterprise risk management is one of the tools used to support the achievement of strategic and operating objectives and to provide information on risks and risk management performance.
In accordance with the existing internal regulations, for identified risks a risk owner is designated, who is responsible for that risk, risk sheets are prepared, risk parameters are determined and mitigation activities and risk response plans are put in place. By taking responsibility for a risk, every risk owner manages the key risk factors within an ERM system. Identifying risks and implementing tools for limiting them make it possible to take effective preventive action in the face of a threat. Risk management is a process that methodically resolves issues related to threats to the organisation's operations, such as occurred in the past, are currently present and are the most likely to appear in the future.
8. Corporate Governance Regulations
The objective of the Corporate Governance Regulations adopted in 2019 is to set consistent and transparent operational standards and procedures at JSW Group. The Corporate Governance Regulations address the exercise of shareholder oversight as part of management of JSW Group and are intended to increase the effectiveness of managing the Group and the functioning of its companies and to implement shareholder oversight forms and procedures that go beyond the existing laws.
9. DISPUTESE
ANTI-COMPETITIVE BEHAVIOR AND VIOLATIONS OF ANTI-MONOPOLY REGULATIONS
In 2022, a lawsuit related to anti-competitive behavior and violations of anti-monopoly regulations was pending in the Group. In its action, JSW is seeking a joint and several award from Minova Ekochem S.A., A. Weber Sp. z o.o. and DSI Schaum Chemie Sp. z o.o. of damages to JSW on account of price-fixing on the mining chemicals market in 2005-2011. The value of the dispute is PLN 118.7 million. The lawsuit was filed on 13 December 2019 with the Regional Court in Katowice. In the proceedings, JSW is represented by the General Counsel to the Republic of Poland. In JSW’s view, the pursuit of this claim is well-founded. Each one of the defendants has filed a statement of defense, challenging its legal liability and applying for dismissal of the claim. JSW filed a rejoinder to the response to the statement of claim submitted by the defendants. The Regional Court in Katowice dismissed the lawsuit in the first instance on 15 December 2021. The General Counsel to the Republic of Poland has filed an appeal against the judgment of the court of first instance.