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The Information Disclosure Policy

KDPW Disclosure Policy

I Purpose of the disclosure policy
The purpose of this Policy is to define the standards of effective disclosure of information, the mechanisms of communication with the shareholders and participants of Krajowy Depozyt Papierów Wartościowych S.A. (KDPW), with organisations of the participants, and with other participants of the financial market, and to ensure adequate transparency of the activity and functioning of KDPW by publishing information and documents required in accordance with the legislation including Regulation (EU) No 909/2014 of the European Parliament and of the Council of 23 July 2014 on improving securities settlement in the European Union and on central securities depositories (CSDR) and Regulation (EU) No 648/2012 of the European Parliament and of the Council on OTC derivatives, central counterparties and trade repositories (EMIR) and their delegated acts (RTS).

II General principles
1. KDPW follows a transparent disclosure policy by means of both traditional methods and state-of-the-art technologies and tools of communication ensuring speed and security.
2. In pursuit of the purpose of this Policy, KDPW publishes information about the organisation of the Company and the provided services.
3. KDPW publishes on the website information and documents required under CSDR and RTS including:
1) information about the prices of provided services, including information about discounts and rebates, presented so as to facilitate the comparison of prices of other service providers;
2) information containing a description of the key legal implications of the offered levels of segregation, including under the applicable insolvency law;
3) information about the target for the representation of the under-represented gender in the Management Board and the Supervisory Board and the strategy of its achievement and implementation.
4. KDPW publishes on the website information and documents required under EMIR and RTS including:
1) information about the prices of provided services, including information about discounts and rebates;
2) required scope of data in trade reports;
3) aggregated derivative data maintained in the Trade Repository.
5. KDPW makes reasonable efforts to ensure the highest quality of information, its transmission and presentation.
6. Information published by KDPW does not include personal data within the meaning of personal data protection regulations.

III Disclosure policy recipients
The Policy recipients include without limitation:
1) KDPW shareholders,
2) participants, i.e., entities which are participants or members of the depository system, the compensation scheme or the trade repository operated by KDPW, as well as pension fund companies and open-ended pension funds,
3) organisations which represent participants,
4) supervisory authorities,
5) other participants of the financial market and individuals interested in the business of KDPW.

IV Methods and time limits of the publication of documents and information and provision of replies to shareholders and participants

1. Participants are informed about the content of rules issued by KDPW and any amendment thereof and the content of other regulations issued under the rules concerning the rights and obligations of participants in accordance with the provisions of such regulations. Such regulations are published on the KDPW website.
2. Information is provided to the shareholders in accordance with the Code of Commercial Companies. All KDPW shareholders are offered the same scope and terms of access to information.
3. KDPW replies to questions concerning the business of KDPW without undue delay, taking into account the applicable legislation, in particular provisions which limit access to specific types of information.

V Communication tools
1. KDPW communicates by means of tools aligned with the needs and expectations of specific groups of recipients of information. The tools include without limitation the following:
1) letters,
2) communiques,
3) meetings with participants,
4) information materials including: presentations, information brochures, videos,
5) public statements and positions of the Management Board,
6) presentations and contributions at domestic and international industry events,
7) the website (,
8) contact forms and e-mail addresses of employees, available on the website and addressed to specific groups of interested parties.
2. Information and documents, including information and documents required under CSDR, are published by KDPW on the website in dedicated thematic tabs.
3. Information and documents required under EMIR are disclosed by KDPW without limitation in the dedicated Trade Repository service.
4. The content of documents and information published in the KDPW online service is developed and published with due diligence and immediately updated when amended.
5. The English language version of documents and information available in the online service is published in the service as soon as possible after the publication of the documents or information in the Polish language.

VI Approval and publication of the Policy

1. The Policy is approved by the KDPW Management Board.
2. The Policy is regularly reviewed in order to ensure its adequacy and compliance with the generally applicable legislation, other regulations applicable to KDPW, as well as internal legislation.
3. The Policy is published on the KDPW website.
Last modified:16-05-2018 Go up