I am pleased to confirm that Wirtualna Polska reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Jacek Świderski
CEO
Wirtualna Polska Holding S.A.

At Wirtualna Polska, our priority is to ensure the well-being of our employees and self-employed contractors and to foster partnership-based relations, respect and organizational culture. Within our organization, cooperation is based on ethical values and compliance with social norms. We attach great significance to observing all applicable provisions of labor law and to promote equality, civil liberties and universal ethical principles. Our staff members are informed on an ongoing basis about amendments to all applicable regulations, in particular those governing the area of employee rights.

The fundamental right of each and every one of us at Wirtualna Polska is to have our health and safety protected, which is why our company endeavors to ensure the best possible working conditions and adhere to occupational safety and health rules and practices.
At Wirtualna Polska, everyone has the right to his or her own political views, religious beliefs and opinions on social, ideological or other issues. However, it is extremely important that such views, beliefs and opinions must not exert an adverse impact on the relations within our teams or the relations of our staff members with our clients, partners or suppliers.

Before the commencement of work or cooperation:
– Everyone must become familiar with the Ethics Compass and the Procedure for Dealing with Undesirable Behaviors.
– A statement by each staff member about having read and understood this document and the Compass of Ethics is attached to the employee’s personnel file and archived in accordance with the rules adopted by the Company.
– Each staff member is required to participate in training on counteracting workplace harassment and discrimination.

We provide regular occupational safety and health training, preventive medical care by occupational medicine specialists, onboarding and periodic health checkups, specialist examinations for drivers and we take all efforts to prevent the occurrence of workplace accidents.
We endeavor to ensure the highest quality and standard of our work environment by arranging a modern, eye-pleasing and functional office space to provide our staff members with personal comfort and a friendly workplace ambience. We let our staff members to perform their work remotely.

We also offer educational programs in employee wellbeing in the form of webinars and face-to-face meetings with specialists. Our staff members may take advantage of consultations with a psychologist and we also provide them with access to a benefit platform containing various options of care for their physical and mental health.
In November 2021, we ran an in-house campaign called Diversity Month during which our employees participated in a broach range of meetings, webinars and training courses on equality and diversity in the workplace.

Our staff members are required to comply with applicable laws and procedures designed to ensure their safety and protect their health. They are trained to report all accidents, incidents and dangerous situations to their supervisors, the HR Business Partner or the Employee Council. On an annual basis, we also evaluate the involvement of our staff members in the following areas: employee experience, commitment, business agility, engaging leadership, people orientation, work-life balance and the company’s activities during the COVID pandemic.

The Wirtualna Polska Group has a hiring and compensation policy in place.
We shape the rules of employment and cooperation with our self-employed contractors on our own, in consideration of the type and quality of work or services, our needs and possibilities, and the market environment.
We apply in practice the principles of equal treatment, including as part of our hiring and compensation policy. We support the personal and professional growth of our employees and foster the role of women in management.

Due to the nature of our business, we have not adopted any written policies on child or forced labor as such situations never occur in our company. We run our business in compliance with the applicable labor laws of Poland.

The amount of base compensation as well as the award of raises, bonuses and commissions depends on the competences and performance of the pertinent staff member, regardless of gender, religious affiliation, political views, origin, social status, sexual orientation, age, marital status or disability.
We build our internal labor arrangements by pursuing the development and promotion policy within our Group, enabling all employees to participate in our recruitment processes.

With a view to counteracting and preventing undesirable behaviors, WP takes anticipatory and preventive actions, in particular consisting of the following:
(a) promoting desired attitudes and behaviors, in line with the principles of social coexistence, in relations between and among our employees and self-employed contractors, including in their contacts with superiors, for instance through adopting various internal regulations, such as the Ethics Compass, enabling our employees and self-employed contractors to participate in training aimed at promoting proper managerial attitudes and cooperation;
(b) taking preventive action involving the dissemination of knowledge about the phenomenon of workplace harassment, discrimination, bullying and other undesirable behaviors, methods of preventing their occurrence and their consequences;
(c) providing each and every one of our employees and self-employed contractors with access to training aimed at preventing the occurrence of undesirable behaviors and protecting them against such behaviors, in particular in the form of online training, available on an on-demand basis and enabling periodic refreshing of knowledge in this area;
(d) monitoring the workplace for the occurrence of undesirable behaviors and applying procedures triggered by such behaviors as they emerge

In consideration of the broad variety of needs of our staff members, arising, for instance, from their parental and domestic duties, our company provides solutions for the organization of flexible working time that enable the finding of proper balance between our employees’ personal and professional lives.

We offer training programs in various aspects of diversity, such as: age, diversity of communication, interculturality.

In our company, we make efforts to maintain parity in employment. Currently, in percentage terms, our employment figures are as follows:
58% of women
42% of men
28% of women in the management board/supervisory board (target for 2030: 30%)
In 2021, our gender pay gap ratio was 14.5%. Our goal is to reduce it to 10% by 2025 and to 0% by 2030.

The vast majority of our employees (97%) receive compensation higher than the minimum wage.
We have introduced a management-by-objectives program for management and senior executives. In 2022, this program will cover all our staff.

We regularly solicit employee opinions within the framework of our pulse-check survey and calculate the Leadership Trust Index.
On an annual basis, we also evaluate the involvement of our staff members in the following areas: employee experience, commitment, business agility, engaging leadership, people orientation, work-life balance and the company’s activities during the COVID pandemic.
In order to ensure ongoing and transparent communication between management and employees, information meetings are held quarterly on the most relevant topics for our business.

In 2021, environmental focus was at the heart of Wirtualna Polska’s activities.
We continued the process of our transition to green energy launched in 2020. At the beginning of 2021, the plan entered a new stage.
Having launched its first test photovoltaic farm for a server-hosting facility in April, Wirtualna Polska acquired a large solar farm in Lower Silesia. Its total capacity is 3 megawatts. Green electricity generated from actual own production already covers almost half of WP’s power consumption needs for running its server-hosting facilities.
In March 2021, we announced the launch of a new strategic project called WP Naturalnie [WP Naturally], as part of which we have carried out a number of ambitious activities, as described below.

Within the framework of our WP Naturalnie strategic project, we have carried out a number of activities:
On the WP Home Page, we have placed a meter which shows by how much our CO2 emissions dropped in comparison to 2020. Moreover, we have enabled users of the WP Home Page and over 20 of our services to switch to the ‘dark mode,’ which enables energy saving in devices using OLED displays, such as mobile phones.
– We have conducted a nationwide EkoTest – a test to check the knowledge of Poles about the natural environment and the current climate change. The test consisted of three stages and covered such issues as: water saving, electromobility, waste management and air quality. The test was answered by more than 100,000 users and, as promised, we have spent the corresponding amount in Polish zloty on planting a forest and protecting biodiversity in Poland. Our report with conclusions drawn from the answers is available on our website at naturalnie.wp.pl.
– Wirtualna Polska’s Las Na Zawsze [Forrest Forever] has been planted in cooperation with the Las Na Zawsze Foundation in the village of Olędy (near Siedlce). Together, we have planted over 1,600 trees and shrubs: seedlings of deciduous trees, such as maples, oaks and beeches, as well as a variety of shrubs.
– In collaboration with the Las na Zawsze Foundation, we have created a series of videos entitled “Why are Forests Trendy?”, encouraging people to take walks in forests and demonstrating the enormous role played by forests for the benefit of Earth’s climate.
– We have produced a WP Naturalnie commercial encouraging viewers to take active steps in the face of climate change and with the future of our planet in mind. A single gesture will not change the world, but it all starts with a single gesture. Today our approach to climate requires a big change – was the key message of our commercial.
– Wirtualna Polska employees have collected their ideas and good everyday practices to help create our Manual of Environmentally Friendly Practices.

Our offices are located in highly energy-efficient buildings fitted with comprehensive solutions sensitive to the natural environment and enhancing the work comfort and well-being of our staff members. We make use of sustainable services provided by our trusted partners in the fields of security, waste collection, recycling and delivery of utilities.

This second photovoltaic farm in WP’s asset portfolio is located in Lower Silesia and covers an area of over 5 hectares. The total capacity of its three generating units is 3 MW. On 2 July 2021, Wirtualna Polska entered into a contract for the acquisition of a 100% stake in the project. The total value of the deal was PLN 12.4 million.
Green electricity generated from own production already covers almost half of WP’s power consumption needs for running its server-hosting facilities. The aim of these efforts is for us to reach zero emissions and climate neutrality by 2023.

Annually, 1 hectare of forest absorbs approx. 7 tons of CO2 from the atmosphere.
The forest will grow for many years, contributing to the protection of numerous species of living organisms.

As part of the campaign, over 2,000 articles on environmental topics have been published on the wp.pl website.

As a company operating in the media and internet industry, we consider it our duty to contribute to the development of ethical business practices and do our part in creating, promoting and supporting stringent ethical standards. Our Group has adopted the Ethics Compass as a commitment by all WP employees and partners to adhere to rigorous standards of behaviors that guide us in our daily work.
We have in place a defined framework of cooperation with our clients, partners and suppliers as well as relations with our competitors. We observe the rules of fair competition and the proper performance of contracts.
We refrain from cooperating with dishonest or unethical clients, partners or suppliers. We react to any manifestations of unfair or unethical behaviors by our clients, partners or suppliers in the fulfillment of orders.
We do not tolerate any corrupt practices, regardless of their form or purpose.

In line with the Ethics Compass, WP staff keep building, hand in hand, an ethical work environment and a desirable value-based organizational culture.
Our Ethics Compass lays down the following anti-corruption principles:
– Do not garner any personal gains from transactions executed by the Group, either directly or through a relative or life partner.
– Do not offer any gifts, souvenirs or financial benefits to clients, partners or suppliers in connection with or related to your work or cooperation with the Group. This does not apply to situations where occasional or holiday gifts are organized by the Group for larger categories of recipients.
– Do not accept any gifts or financial benefits from clients, partners or suppliers in connection with or related to your work or cooperation with the Group. An exception to this rule may be an occasional acceptance of small gifts (other than money) of a low value which, in generally accepted practice, do not exceed the framework of business integrity in respect of a person in power.

Whenever a staff member encounters a situation exhibiting signs of corruption or bribery, he or she is required to report it to his or her superior, who will then take appropriate steps in this respect. It is also possible to report such irregularities anonymously – the company has a dedicated program in place called Sygnalista [Whistleblower].

Measurements in this area are based on incidents reported by staff members, yet so far we have not dealt with any cases of corruption. Nor have we ever been involved in any investigations, lawsuits or fines related to bribery.