OUR RESPONSIBILITY TOWARDS  THE MARKET ENVIRONMENT

Our ethical and responsible attitude is manifested not only in internal relations, but it is also a standard in our relations with the market environment, including in particular customers, suppliers of goods and services, business partners, shareholders and capital market participants.

Transparency towards shareholders is understood as clarity, openness and equal access to information. Agora, as a public company, is required to inform the market of any event concerning Agora or its capital group companies which may influence the investment decisions of the existing and potential shareholders. Our priority is to ensure that all interested parties have easy and non-discriminatory access to information through a variety of communication channels.  

The main communication channel is the Agora.pl – corporate website, where all information required by the law and other materials which familiarise the stakeholders with the Agora Group's business profile, are published on an ongoing basis. Additional tools supporting ongoing access to information are: a mobile version of the investor relations service and the Agora press office, as well as Twitter and LinkedIn accounts.

Regular meetings are also held for shareholders, investors and representatives of the media, during which the financial results achieved by the Agora Group in a given quarter are presented. The form of such meetings provides for the possibility to ask questions to the Management Board of Agora. Due to the limitations related to the pandemic in 2020, these meetings were held only remotely.

Apart from the quarterly meetings devoted to the presentation of the financial results, ordinary and extraordinary General Meetings of Shareholders are being held in a similar form, and the market is being informed in advance to enable shareholders to prepare for such meetings.

For its activities in the area of communication with the market in 2020, Agora was awarded for the third time in the competition organised by the Polish Association of Listed Companies. It won the category of “Best IR Service” among medium-sized companies (belonging to the sWIG80 index).

Agora Group companies take responsibility for relations with suppliers and contractors, as well as for the projects, products and services they offer, as well as for marketing communication. For this purpose, regulations were created specifying the terms and conditions of using products and services for customers, and substantive criteria and clear rules applicable to the entire supply chain were developed.

When planning and implementing CSR activities, we take into account the importance of a given problem and its compliance with the Agora Group's strategy and UN Sustainable Development Goals (SDGs). What is also important for us is the voice of our market environment, that is information and opinions provided by the Group's stakeholders as part of various forms of dialogue.

Directness and reciprocity are the principles of dialogue adopted by the Agora Group. We also strive for regular contacts with all stakeholder groups. However, the cyclicality and formalisation of the tools used to learn about the needs and opinions of the groups we are interested in, remain challenging.

Agora wants to actively shape the market environment in which it operates on a daily basis. Therefore, its brands and companies are active participants in organisations bringing together specialists from the industries relevant to its activities. The main organisations attended by the representatives of the Group companies are*:

POLISH ORGANISATIONS

• PKPP Lewiatan/Polish Confederation Lewiatan
• Polish Association of Listed Companies
• Polish Chamber of Press Publishers
• Polish Reading Studies (PBC)
• ReproPol Publishers' Association
• IAB Polska – Internet Advertising Bureau Polska 
• IGRZ – Outdoor Advertising Chamber of Commerce
• IAA Polska – International Advertising Association Poland
• Advertising Agency Association (SAR)
• ZPAV – Polish Society of the Phonographic Industry
• KIPA—Polish Audiovisual Producers Chamber of Commerce 
• Polish Chamber of Books
• Copyright Polska Association of Authors and Publishers
• Polish Association New Cinemas 
• Polish Internet Research

FOREIGN ORGANISATIONS

• IAB Europe 
• INMA – International Newsmedia Marketing Association 
• EPC – European Publishers Council 
• LENA – Leading European Newspaper Alliance
• The Magazine Media Association (EMMA)
• EGTA – Association of television and radio sales house  
• UNIC – International Union of Cinemas 
• World Association of Newspapers and News Publishers (WAN – IFRA) 
• American Chamber of Commerce in Poland

(*data as of 31.12.2020) 

The Agora Group, through its companies and brands, operates on the advertising, press, cinema, film, Internet, radio and catering markets. We regularly monitor data and information about our market environment and competition. When dealing with competitors, we are committed to transparency, integrity and compliance with the applicable laws. Preventing any breaches of fair competition, monopolistic practices and other unfair market practices is one of our key principles included in the “Agora Code of Ethics”.

INVESTIGATIONS CONDUCTED BY THE SUPERVISORY AUTHORITIES, PENALTIES AND SANCTIONS:

In 2020, the President of the Office of Competition and Consumer Protection (UOKiK) initiated an investigation procedure under Article 48 of the Act on Competition and Consumer Protection in order to preliminarily determine whether the actions of AMS and Ströer Poland on the outdoor advertising market could lead to a breach of the provisions on competition and consumer protection. The investigation procedure initiated by the Office of Competition and Consumer Protection (UOKiK) in 2019 aimed at determining Agora's obligation to notify to UOKiK the intention to acquire a minority stake of 40% in Eurozet Sp. z o.o. was also continued. The President of UOKiK has not yet found any violations of the Act in the actions of Agora; however, the investigation procedure has not yet been formally completed by the end of 2020.

No financial penalties were imposed on any of the Agora Group companies for violating the provisions on competition and consumer protection.

While respecting our individual customers' right to privacy and bearing in mind the high sensitivity of these issues, we in the Agora Group pay special attention to matters related to the protection of personal data. The organisation respects the generally applicable laws and observes the principles set out in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – General Data Protection Regulation (hereinafter referred to as GDPR).

The Agora Group companies instilled a number of procedures and processes to ensure compliance with the GDPR provisions, in particular those concerning the rules on the processing and protection of personal data. The aspect of personal data protection is also taken into account in the process of submitting new business initiatives and in the process of selecting suppliers. 

The Agora Group conducts regular training on personal data protection, in particular on the following subject areas: processing of data of employees and job candidates, ICT security, carrying out balancing tests, risk assessment and data protection impact assessment, cooperating with and verifying contractors, carrying out marketing activities, concluding entrustment agreements, fulfilling information obligations and constructing consent clauses, identifying and assessing breaches, agreements on joint controlling, transfers of personal data.

The Group also pursues activities aimed at raising employee awareness of personal data protection issues, including whistleblowing, notification of new business projects or rules on remote work.

Supervision over all issues related to the protection of personal data, in particular compliance with the GDPR provisions and internal regulations, is being carried out by the Data Protection Officer appointed in the following companies: Agora S.A., Agora TC Sp. z o.o., Doradztwo Mediowe Sp. z o.o., GoldenLine Sp. z o.o., Grupa Radiowa Agory Sp. z o.o., IM40 Sp. z o.o., Manfred Sp. z o.o., NEXT FILM Sp. z o.o., Next Script Sp. z o.o., HRlink Sp. z o.o. and Yieldbird Sp. z o.o.

INVESTIGATIONS CONDUCTED BY THE SUPERVISORY AUTHORITIES, PENALTIES AND SANCTIONS:

In 2020, the Agora Group did not report any incidents of leakage, theft or loss of personal data, and no financial penalties were imposed for the violation of personal data protection regulations. There was one reprimand (referred to Agora company) and one complaint from the President of the Personal Data Protection Office, to which the company (it referred to Domiporta Sp. z o.o.) responded within the prescribed time limit and the case is currently pending.

Apart from the correspondence concerning the above-mentioned cases, the President of the Personal Data Protection Office does not conduct any proceedings against the Agora Group companies. 

In 2020, Agora submitted one complaint to the Provincial Administrative Court against the decision of the President of the Personal Data Protection Office which ordered the company to make personal data of users of the Gazeta.pl portal available to entities other than the authorised state authorities.