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. SYSTEM COMPLIANCE

The compliance system in place in the Group encompasses regulatory and organisational solutions, which jointly make up an internally integrated compliance management system. Compliance regulations adopted in the Group, which are compliance system components, are as follows:

The Code contains the most essential features of ethics, anti-corruption and anti-discrimination policy as well as principles of respect for diversity and tolerance towards a fellow human being. It also defines procedures for reporting irregularities and non-compliance with legal obligations, threats to occupational health and safety, health of customers and bystanders, unfair competition practices, environmental safety and other violations. The Code is also a reflection of the Group’s commitment to acting in a manner minimizing the negative impact on the natural environment and local communities, and calls for respect for all materials, resources and energy.

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 purpose of the Policy is to prevent and mitigate the consequences of any irregularities occurring in the Group by regulating governance structures for this area of activity.

The Procedure is part of the compliance system, and is aimed to introduce uniform rules for reporting all irregularities irrespective of their nature.

The Policy sets out the rules and responsibilities of employees in the corruption prevention area. The purpose of the Policy is to ensure that the Group conducts its business in compliance with the law, including, in particular, with the provisions on counteracting corruption, and that the environment in which all companies operate is free of any abuse.

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.

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.

This policy defines persons closely associated and relatives, it defines the principles for hiring and cooperating with persons closed 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. The clauses adopted in the policy are applicable to all employees and management board members and pertain 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 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 they duties entrusted to them.

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.

2. RESPECT FOR 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.

VALUES STANDARDS

  • respect for other human beings;

  • diversity and tolerance;

  • occupational health and safety;

  • respect and openness in relations with customers,

  • environmental awareness;

  • effective management through, among others, involving stakeholders and building trust in relations with customers and suppliers,

  • corporate governance through adaptation to the best standards in this respect,

  • relations based on transparent principles, in particular through no acceptance of any actions contrary to law or principles of social coexistence,

  • building good relations with the public sector,

  • elimination and avoiding unethical actions,

  • impartiality, competencies and reliability,

  • fair competition;

  • protection of the Group’s and its business partners’ information;

  • confidentiality;

  • avoidance of conflicts of interests;

  • reliability and integrity in relationships with suppliers and customers;

  • rejecting all forms of corruption and unfair influence,

  • child labor, slave labor or any other form of forced labor is unacceptable;

  • attaching particular importance to good relations with local governments of the municipalities and cities where we conduct our operations,

  • ensuring an appropriate level of diversity, including respecting all differences between employees,

  • freedom of association.

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.

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.

Work was begun in 2021 on drafting a distinct Human Rights Policy that will set forth the detailed methods of how Group companies act in this area. In particular, the Parent Company will strive to obligate suppliers and subcontractors to adhere to human rights and improve internal mechanisms for the purpose of mitigating the risk associated with violating the human rights of employees, members of local communities and all other stakeholders.

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.
Having regard to the present dangers related to extractive activities, JSW conducts these operations in dialogue with local communities in a way that minimises surface damages and the risk of damages that could result in construction disasters, which would endanger human life and health (see:

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.

3. DIVERSITY POLICY

In 2021 the Parent Company endorsed a document entitled JSW S.A.’s Diversity Management Policy. The aim of this Policy 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. In 2021 the Parent Company trained approximately 5,000 employees - representatives of various organizational units in JSW on managing diversity.

Starting with the employee recruitment process, through the entire term of their employment, up to the moment when they end their career, the Group observes the principles of equal treatment and equal opportunity for employees, regardless of their skin color, race, gender, religion, origin or social situation.

DIVERSITY IN MANAGEMENT BOARDS AND SUPERVISORY BOARDS OF GROUP COMPANIES 2021 2020
WOMEN MEN TOTAL WOMEN MEN TOTAL
MANAGEMENT BOARDS 6 34 40 8 39 47
age 30-50 3 16 19 3 21 24
age over 50 3 18 21 5 18 23
of which foreigners - - - - -
SUPERVISORY BOARDS 22 58 80 24 61 85
age under 30 - - - - -
age 30-50 11 31 42 12 30 42
age over 50 11 27 38 12 31 43
of which foreigners - - - - -

Workers’ professional qualifications are an important value in the Group’s organizational culture. One of the main values in its binding Code of Conduct is to observe the prohibition against any discrimination, while guaranteeing freedom of expression, conscience and religion and freedom of belief and speech. Having regard for the distinct nature of the Group’s business, men represent the predominant percentage of its workers. Group companies pursue an antimobbing and antidiscrimination policy through constant development of employee awareness in this respect.

4. JSW's anti-harassment and anti-discrimination policy

Group companies pursue an antimobbing and antidiscrimination 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, the document entitled JSW S.A. Anti-Mobbing and Anti-Discrimination Policy was amended.Not all Group companies have separate document devoted to 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 Group companies are required to provide JSW with annual reports on the scope of reported violations of the policy. In 2021, the Parent Company trained approximately 400 employees on prevention of mobbing.

NUMBER OF REPORTED INCIDENTS 2021* 2020**
MOBBING 7 7
EMPLOYEE DISCRIMINATION 1 -
*As a resulted of the commission’s work: 1 case was classified as mobbing, in the remaining 6 cases no mobbing was identified. Also, the work conducted by the commission did not confirm any case of discrimination.
** As a resulted of the commission’s work: 1 case was classified as mobbing, in 6 cases no mobbing was identified.

5. REMUNERATION POLICY FOR MEMBERS OF JSW'S GOVERNING BODIES

In December 2021, JSW Group adopted the "Remuneration Policy for the Governing Bodies of Subsidiaries of Jastrzębska Spółka Węglowa S.A.," covering the remuneration of members of the management boards and supervisory boards of subsidiaries. The document, taking into account the requirements of the applicable legal acts, in particular the Act of 9 June 2016 on the principles of shaping the remuneration of persons managing certain companies, expanded the scope of information received by JSW from other JSW Group companies. At the same time, JSW's supervision over the remuneration of members of the JSW Group companies' governing bodies covered by the aforementioned Policy was strengthened.

6. REMUNERATION POLICY FOR JSW'S MANAGEMENT BOARD AND SUPERVISORY BOARD

The remuneration policy for members of the Management Board and Supervisory Board of Jastrzębska Spółka Węglowa S.A. was introduced pursuant to the binding provisions of the Act on public offerings and the terms for introducing financial instruments to an organised trading system and on public companies and is applied starting from its adoption by the General Meeting, i.e. from 31 August 2020. It sets out the basic rules for determining, calculating and paying remuneration to members of the Management Board and members of the Supervisory Board. The Company pays remuneration to members of the Management Board and members of the Supervisory Board in accordance with the above Policy, General Meeting resolutions and Supervisory Board resolutions. The Policy aims to support the achievement of the Company's expected business results. The existing KPIs (including statutory ones) and tasks for Management Board members are intended to advance the business strategy, long-term interests (including long-term investments) and ensure the Company's stability. Objective and tangible criteria for implementing and settling the KPIs serve as motivation for Management Board members.

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. DISPUTES

In 2021, the Group companies took part in court and administrative proceedings related to their activities. According to the best knowledge of the Management Board, the Group companies are not at risk of proceedings that could materially affect its financial position and profitability, other than the proceedings mentioned in the description below. Below is a list of material pending proceedings and mediation:

Action brought by JSW KOKS against a counterparty

On 30 November 2015, a lawsuit began before the Regional Court in Katowice for payment of contractual penalties for a failure to meet the completion deadline for an investment project on the area of the Przyjaźń Coking Plant. In view of the course of litigation, in June 2017 JSW KOKS established a financial provision for PLN 9.5 million. In 2018, the company asked the insurer to pay the amount due in the amount of PLN 4.3 million under the insurance guarantee. The insurer refused to pay the requested amount. On 31 July 2020, a statement of claim was filed with the Regional Court in Gdańsk against the insurer for payment of PLN 0.7 million in connection with defective anticorrosive protection of a ventilation cooling tower. A statement of claim against the contractor for payment is being prepared as a result of the power unit not achieving the guaranteed availability factor during the first year of the guarantee period. Originally, the expert retained by JSW KOKS calculated the loss to be PLN 3.5 million. During the work on the draft version of the statement of claim, the foregoing amount was checked and subsequently reduced to PLN 2.1 million. This case is still pending.

In the proceedings on the abovementioned case, a judgment adverse for the company was handed down in December 2020 by the Court of first instance. JSW KOKS increased the provision recognized in December 2019 for awarded litigation costs and interest, which amounted to PLN 2.1 million as at 31 December 2021. An appeal was filed with the Court of Appeals in Katowice. In June 2021, the JSW KOKS Management Board gave directional approval to enter into mediation covering all pending disputes with the contractor. Mediation did not produce a result. The case is pending. The total amount of provisions as at 31 December 2021 is PLN 11.7 million.

Lawsuit brought by JSW against Wonam Serwis Sp. z o.o. and DSI Schaum Chemie Sp. z o.o.

On 13 December 2019, JSW filed with the Regional Court in Katowice a lawsuit against Minova Ekochem S.A., A. Weber Sp. z o.o. and DSI Schaum Chemie Sp. z o.o. The claim seeks a joint and several award from the defendants of indemnity for JSW on the account of a price pact in the mining chemicals market in 2005-2011. The total value of the dispute is PLN 118.7 million. In the lawsuit the Parent Company is represented by the General Counsel to the Republic of Poland. The defendants filed replies to the statement of claim submitted by JSW, challenging their legal liability and motioning for the 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 applied for a justification for that ruling, and after its receipt an appeal will be submitted.

Lawsuit filed by Elektrometal S.A. against JSW

On 19 April 2021, a court procedure was initiated before the Regional Court in Gliwice, filed by Elektrometal S.A. against JSW. The statement of claim pertains to payment for the completion of the investment project “Reconstruction and modernization of the Foch II shaft hoist installation”” in KWK Knurów-Szczygłowice and to the return of performance by Elektrometal S.A. to JSW without legal grounds (delivery of further ropes). The total value of the dispute is PLN 5.7 million. In the lawsuit JSW is represented by the General Counsel to the Republic of Poland.

Lawsuit filed by JSW against Trans-Jan Sp. z o.o., Katarzyna Rucińska-Marzec Deltamet, Maksymilian Marzec partner in Deltamet, Carbon Sp. z o.o., MGM Mining & Construction Sp. z o.o.

On 10 August 2021, proceedings were initiated by JSW against: Trans-Jan Sp. z o.o., Katarzyna Rucińska-Marzec Deltamet, Maksymilian Marzec partner in Deltamet, Carbon Sp. z o.o., MGM Mining & Construction Sp. z o.o. The dispute relates to the payment of contractual penalties imposed by JSW in connection with the delay in performance of the contract for "Construction of mine workings in seam 403/1 in KWK Knurów-Szczygłowice". The value of the dispute is PLN 3.2 million.

At the same time, JSW is unaware of any non-compliance on its part with laws or regulations concerning the issues described in disclosure 419-1 (Lack of compliance with law or regulations in social and economic area).