2020 ESG

At Allegro, we don’t shy away from responsibility and are aware of the scale of our company’s impact. We combine our major influence on the development of the Polish economy with social and environmental impact.

Marta Mikliszańska Head of Sustainability & Public Affairs

Our CSR and sustainability strategy

Our CSR and sustainability strategy for 2020-2023 builds on our most important social and educational initiatives. We also put a strong emphasis on environmental issues. The motto of our strategy, #SustainableAllTogether, reflects our conviction that by working with our customers, sellers, business partners, employees and other stakeholders, we can contribute to the Sustainable Development Goals.


The strategy covers 86 initiatives to support our responsible and sustainable growth. For each pillar of the strategy, we have set specific goals and benchmarks that are monitored regularly.

The pillars of our CSR and sustainable development strategy

The Group’s CSR & Sustainability Strategy comprises 4 pillars:

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Approved and adopted by the Board of Directors, the strategy is regularly monitored and presented to management for review. We also include the results in our ESG report.


Allegro’s long-term sustainability goals are to help our customers to make responsible choices through:

  • exposure and promotion of sustainable products by optimising Allegro.pl product search based on fair and transparent criteria.
  • We are working on a dedicated space for those looking for sustainable products to make it easier for buyers to find certified offers and to promote sellers in this market segment.

We aim to raise awareness of the best practices in sustainable packaging and logistics giving both sellers and the buyers knowledge and tools to promote circular-economy principles to their value chains.

We intend to encourage more merchants to use sustainable packaging.

We focus on educating our merchants and customers on our new e-learning platform Allegro Academy.

The Group introduces annual GHG (greenhouse gas) emissions monitoring and agenda to reduce average GHG emissions per GMV.

value of eco trade online on Allegro in 2024
2.5 milion
items shipped in eco-friendly packaging monthly by 2022
of GHG emissions
at a minimum of
employee Engagement Index

SDGs implemented within our CSR and sustainability strategy

Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all

Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all

Build resilient infrastructure, promote inclusive and sustainable industrialization and foster innovation

Ensure sustainable consumption and production patterns

Take urgent action to combat climate change and its impacts

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At the Agenda 2030 Stakeholder Forum held in October 2020, Allegro.pl joined the Partnership for the SDGs, an initiative of the Ministry of Economic Development, Labour and Technology. It is a platform for substantive debate, experience sharing and networking between different communities. It aims at sustainable development and disseminating knowledge in this area. The Partnership for the SDGs was established in 2017, and every year new institutions, businesses and organisations join this initiative, with over 140 signatories to date.

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In 2020, Allegro.pl joined the UN Global Compact, an initiative of the Secretary-General of the United Nations that brings together companies and institutions for which sustainable development is important. By joining the UN Global Compact, the company pledged to implement policies and global UN initiatives, focusing on environmental protection and counteracting the climate crisis. It is also a commitment to the Sustainable Development Goals as defined by the United Nations within its Agenda 2030.

Joining the UN Global Compact proves our genuine commitment to our CSR & Sustainability strategy and our environmental pledge. We educate sellers on sustainable development and implement the climate agenda in our supply chain.

Learn more about the UN Global Compact

Global Compact brings together over 12 thousand companies and 3 thousand institutions from 160 countries. This means that Allegro is joining a large international community for which the conversation about sustainable growth is an extremely serious one.

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Ethics and values

At Allegro, we comply with the highest ethical standards and operate in a transparent manner. From the formal perspective, our ethical ecosystem consists of policies, procedures and regulations that all Allegro employees are familiar with. A special Ethics Committee oversees compliance with the Code of Ethics, which includes reviewing and settling any reported cases of possible violations.

  • HR Director or HR Business Partner
  • Head of Legal or a designated lawyer
  • Manager of the division the reported violation concerns
  • Representative of employees selected by the Employee Representation (if necessary)
  • CSO
  • Transparency Policy
  • Policy against discrimination and workplace harassment
  • Antitrust Compliance Policy
  • Anti-money laundering and countering terrorism financing policies
  • Security policy
  • Whistleblowing procedures

The Code of Ethics is periodically reviewed and always available for employees.

In practice
Stay Safe / Stay Fair

The Allegro Group has introduced training programs to ensure compliance and ethical standards called Stay Safe / Stay Fair. All new employees learn about our policies during their obligatory onboarding training. We have also developed an additional plan of training and communication on ethics and ensuring compliance with norms, recommendations and current practices. Once a year, all our employees undergo training on our Code of Ethics and personal data protection. We use multiple channels to build awareness of how important ethical conduct is in our company: e-learning sessions, emails, our Intranet, meetings, posters, competitions and other forms of communication.

Being an ethical company is also about operating in compliance with the law. At Allegro, we comply with the law and we stay abreast of all relevant changes and industry regulations. We keep adjusting our services, policies and processes accordingly.

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At Allegro, we have a whistleblowing system for reporting violations. It guarantees confidentiality and safety of the whistleblowers, including protection from retaliatory action. Our system is open and accessible for everyone in the company (reports can also be submitted anonymously via a special form available online). It is based on the guidelines for reviewing complaints and grievances against Code of Ethics violations. We have launched a special online platform, a dedicated online form and a special email address. Every case is reviewed and addressed where appropriate.

In 2020, we had two reports about our Transparency Policy. We investigated both thoroughly and found no policy violations.

We quickly respond to your questions and requests for advice.

Reporting complaints and grievances 2020 2019
Policy on anti-money laundering and combating terrorist financing and export control, and financial sanctions manual 0 0
Transparency policy 2 2
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We have introduced a system for corporate governance, risk management and compliance across all Allegro operations. It covers operational standards, preventing corruption, compliance with the competition law, preventing conflict of interest, information and data protection, preventing unlawful discrimination and protection of the company property and know-how.

Our system applies to not only the regulations relevant to Allegro but also the terms of cooperation with suppliers: the purchasing policy and additional requirements for suppliers, including the Code of Conduct and the Questionnaire for Suppliers and Business Partners for every Key Supplier (i.e. a supplier whose yearly contract exceeds PLN 100,000). In line with the guidelines of the Ministry of Finance, Group companies have introduced a complex verification process when choosing suppliers. The verification of financial documents, registration documents and validity of bank accounts makes it possible to eliminate those service providers whose credentials raise concerns.

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All employees undergo obligatory training for all of the most important policies during their onboarding session. They also sign a declaration by committing to comply with the rules listed in those policies. Additionally, every year we perform obligatory training for all our employees.

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At Allegro, we are fully aware of the fact that the procurement process can create corruption risks. This is why the operations of the departments responsible for purchasing are reviewed against corruption risks and subject to anti-corruption supervision. In 2020, not a single case of corruption was discovered.

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Compliance with anti-corruption and anti-monopoly regulations as well as regulations guarding collective consumer interests

We ensure the highest quality and safety of products offered on Allegro, as well as service and delivery quality. We cooperate very closely with UOKiK and local consumer ombudsmen. In response to their specific needs, we have set up a dedicated email address that makes it easier for them to contact our employees.

In 2020, Allegro was not awarded a single financial penalty or sanction on account of legal non-compliance or violating the rules governing supplies, the use of products and services.

Being an ethical company also means acting in accordance with the law. At Allegro, we abide by the law and constantly monitor legislative changes, as well as changes in industry regulations to adjust our services, policies and processes accordingly.

Michał Wierucki "Zip" Chief Security Officer

Allegro.pl was named the Ethical Company of 2020, a title awarded by “Puls Biznesu” and PwC Legal to companies that stand out for their business integrity. In the seventh edition of this prestigious competition, Out of 116 submissions, 12 companies received special recognition. The demanding criteria of the competition included compliance with both legal and ethical norms, respect for business partners, fair competition practices, creating a culture of trust and good relations between employees, counteracting fraud and wrongdoing and finally, commitment to the needs of various stakeholder groups. The competition was audited by an external company, PwC Legal.

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Management of non-financial risks

At Allegro, we like specifics. Wherever possible, we measure the effect of our ESG activities and openly report the results. We understand how fundamental this is for the trust of stakeholders and the evaluation of our company.

We closely monitor the legal and social environment, defining risks and counteracting their possible negative consequences for our organisation.

Risk type Risk description
Environmental risk Although the environmental impact of the e-commerce sector is lower than that of traditional forms of commerce, we are aware that Allegro’s activities have a negative impact on the environment (e.g. CO2 emissions, packaging waste). Growing our business without implementing programs to reduce carbon dioxide emissions and energy consumption, and without taking initiatives for sustainable development, could result in negative environmental effects. The new regulatory framework related to the EU’s Green Deal as well as the environmental transformation may impose further obligations on retail companies and possibly other entities as well. The climate change we are currently seeing has the potential to lead to significant changes in the way we do business, as well as in revenues and costs. Initiatives aimed at reducing carbon dioxide emissions and technological solutions in line with the principles of sustainable development, such as sustainable packaging, can translate into an increase in the costs of our operations.
Social risk The deterioration of Allegro’s public image or reputation as a result of negative publicity may adversely affect its brand. Product recalls, product liability claims, violations of corporate social responsibility rules, counterfeit goods that violate Allegro’s User Agreement, or other fraudulent activities on our e-commerce platform that will not be detected by anti-fraud technology tools, may significantly harm Allegro’s reputation and business. User complaints or negative opinions about Allegro websites, products, delivery times, return processes, working conditions of its employees (or employees of its subcontractors or suppliers), user data processing and security or customer service practices, including online platforms, such as blogs, internet rankings, review websites and social networks, can have a significant negative impact on Allegro’s reputation and the popularity of our websites.
Risk associated with human rights The control and prevention mechanisms used as part of Allegro’s compliance structure may prove insufficient to provide adequate protection against any human rights violations, such as unequal treatment of employees (e.g. in the case of recruitment, remuneration, training and promotion, etc.) or other violations that may be the case for external partners and suppliers.
Labour practices Loss of qualified employees, high turnover, or persistent difficulties in filling vacancies with the right candidates or applicants can have a significant negative impact on Allegro’s ability to compete effectively in its business ecosystem. Moreover, we may lose a significant part of expert knowledge or this know-how may become available to competitors. Furthermore, in order to recruit or retain qualified employees, Allegro may be forced to offer higher pay packages and other benefits, which may lead to increased personnel costs. Inability to recruit, train, motivate or retain qualified employees without incurring excessive costs can have a material adverse effect on the business, financial condition and operational results.

Work-related hazards and situations, as well as the risk of work-related injuries or health loss, including occupational accidents and diseases, may also have a significant negative impact on Allegro’s operations.

The COVID-19 pandemic has far-reaching consequences for employees who need to continue working in their workplace (especially in a warehouse). Those workers who work remotely may not have ergonomic and adequate working conditions at home.

The risk of corruption and other violations Allegro may be exposed to cases of corruption or bribery (bribes, illegal gratuities, extorting payments, digital crime), conflicts of interest or other abuses, as well as the lack of adequate protection of ccustomers' personal data.
Risk related to cybersecurity and personal data breaches The Allegro Group mainly runs web portals that may suffer from a cyber attack. Cybersecurity, personal data management and ensuring an adequate level of security of our infrastructure are important elements of our business.


For more information please see the chapters of the Allegro.eu Consolidated Annual Report (page 152 and following).

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We work with reliable partners

In 2020, we cooperated with over two thousand reliable companies that provided us with products and services necessary for the efficient operation of Allegro. Choosing a supplier for Allegro is a multi-step process that allows us to find the best offer and make sure that we are using the service of a reliable supplier.

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Allegro supplier selection:

99% of suppliers were assessed

At Allegro, we distinguish between two groups of suppliers: those who provide products that are retailed as part of the Official Allegro Store, 1P (Oficjalny Sklep Allegro 1P) and suppliers whose products and services we use as part of our business (administrators of buildings where our offices are located, media and software suppliers, IT systems, data centres, technological and advisory solutions, advertising and marketing services and other services and products). In the case of our suppliers, we want to make sure that they follow principles similar to ours. If the total value of contracts with a supplier exceeds PLN 100,000, the supplier is covered by the program of constant monitoring and evaluation and is obliged to accept and sign the Code of Conduct and the Questionnaire for Suppliers and Business Partners, as well as submit a written declaration of compliance with the Allegro Code of Ethics (Kodeks Allegro) and the Principles of the UN Global Compact initiative. This allows us to verify their ethical, social and environmental behaviour. In 2020, 99% of suppliers meeting these criteria were assessed. They accounted for 9.7% of all new contractors (the data doesn’t include eBilet.pl). Details on Allegro’s supply chain and supplier characteristics are internal information of the company.

The obligations of suppliers and business partners are based on the 10 principles of the United Nations Global Compact.

Also, in accordance with the recommendations of the Ministry of Finance, the group companies have introduced a complex verification process when selecting suppliers. Verifying financial documents, registration documents and the accuracy of bank accounts should make it possible to eliminate unsuitable service providers. We have also introduced a purchasing policy, tendering procedures, controlling procedures and legal procedures aimed at minimising any unlawful practices, violations of the law, corruption and fraud as well as other negative consequences of non-compliance within the Group. In addition, all purchasing processes at Allegro.pl and Ceneo.pl are based on integrated IT systems that ensure full transparency of compliance with the procedures.

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Allegro may each time be a party to various claims and legal proceedings related to claims arising from its activities. Below, you will find information about ongoing proceedings, including in the twelve months preceding the date of the Allegro.eu Annual Report (i.e. as of March 6, 2021), and about pending proceedings or those that, to our knowledge, may be initiated and may have a significant impact on our business:

Legal action taken in relation to anti-competitive behavior or behavior violating collective consumer interests 2020
Number of legal proceedings pending in the reporting period regarding anti-competitive behavior in which the organization was a participant 2
Number of legal proceedings pending in the reporting period regarding behavior violating collective consumer interests, where the organization was a participant 3
Number of legal proceedings concluded legally in the reporting period regarding anti-trust and monopoly behaviors 0
Number of legal proceedings concluded legally in the reporting period regarding behaviors violating collective consumer interests, where the organization was a participant 0
Key results of legally concluded proceedings, including issued decisions or judgments 0


Proceedings before the President of UOKiK

  • Antitrust proceedings in connection with alleged abuse of a dominant position by favoring own sales activity on the platform. On December 6 2019, the President of UOKiK initiated antitrust proceedings against Allegro.pl, accusing the company of abusing its dominant position by favoring its own sales activities on the Allegro.pl platform. We answered the questions submitted by the President of UOKiK and presented to the President of UOKiK the arguments and economic analysis proving that we do not have a dominant position and we did not favor our own sales activity on the Allegro.pl platform. The proceedings are pending.
  • Explanatory proceedings regarding Allegro.pl’s cooperation with sellers. On September 3 2020, the President of the Office of Competition and Consumer Protection announced in a press release that he initiated an explanatory procedure regarding the principles of Allegro.pl’s cooperation with sellers, in order to determine whether Allegro.pl is receiving unjustified benefits at the expense of its customers. According to the press release, the President of UOKiK will analyse, in particular, the conditions for collecting and reimbursing fees and the rules for determining their amount. As part of the explanatory proceedings, the President of UOKiK will also analyse the principles of operation of the SMART! program. On September 14 2020, we received a formal notification from the President of the Office of Competition and Consumer Protection on the initiation of an investigation aimed at preliminary determination whether, given the principles of Allegro’s cooperation with sellers on the Allegro.pl platform, there may have been a breach of the provisions of the Competition and Consumer Protection Act, which would justify the initiation of antitrust proceedings. We answered the questions of the President of the Office of Competition and Consumer Protection submitted to us to date. The proceedings are pending.
  • Proceedings against Allegro.pl to look into whether Allegro.pl’s regulations contain abusive clauses. On September 15 2020, we received a formal notification from the President of the Office of Competition and Consumer Protection on the initiation of proceedings against us in a case for recognizing the provisions of the standard contract used by Allegro as prohibited. We answered the questions of the President of the Office of Competition and Consumer Protection and presented arguments proving that the provisions of the standard contract in use are legal. We also included some specific commitments. The proceedings are pending.
  • Explanatory proceedings regarding the procedure of returning tickets used by e-Bilet.pl during the COVID-19 pandemic. On February 22 2021, we received a formal notification that the President of the Office of Competition and Consumer Protection had initiated an investigation to determine whether eBilet.pl violated the collective interests of consumers. In the same document, the President of UOKiK asked eBilet.pl about the rules for returning tickets during the COVID-19 pandemic, in particular the proposal to hand over vouchers instead of cashback. The proceedings are pending.
  • Appeal against the decision of the President of UOKiK regarding the alleged Allegro.pl failure to include in the regulations a detailed description of the rules for blocking the buyer’s account(s) in a situation where the seller is seeking a refund due to the buyer’s fault. On February 9 2016, the President of the Office of Competition and Consumer Protection issued a decision No. DDK 1/2016, with a determination that Allegro.pl’s practice of not including in the regulations information on the rules for warning consumers and suspending their accounts as a result of sellers seeking a commission refund due to failure to perform the contract concluded via the Allegro.pl platform, constitutes a violation of collective interests of consumers and ordered its abandonment. The President of UOKiK did not impose a fine. Allegro.pl appealed against this decision. The court of first instance did not uphold the appeal. We appealed.
    In connection with the final outcome of the proceedings concluded with the judgment of the Court of Appeal of 2 June 2021 concerning the decision of the Office of Competition and Consumer Protection (UOKiK) ref. DDK 1/2016 (the decision was found to be fully valid), a link to the decision of the President of UOKiK of 9 February 2016 ref. DDK 1/2016 was posted on the Allegro.pl website on 16 June. In the decision, the President of the Office of Competition and Consumer Protection stated that one of Allegro’s practices violates collective consumer interests. The violation consists in failing to inform in the Allegro Terms & Conditions about the circumstances for giving warnings to consumers and suspending their accounts when merchants seek a refund of commission due to non-performance of a contract concluded via the Allegro.pl website. The decision became final as a result of the judgment of the Court of Appeal of 2 June 2021. Allegro hereby informs that with the update of the Allegro Terms & Conditions on 24 March 2020, the Company permanently ceased to warn consumers and suspend their accounts in the situations referred to in the decision of the President of UOKiK, and sanctions consisting in suspending consumers' accounts in such circumstances have not been applied since 11 September 2016. Allegro hereby also informs that it is considering submitting a cassation appeal to the Supreme Court against the judgment of the Court of Appeal.

In all of the above cases, Allegro fully cooperates with the Office of Competition and Consumer Protection, providing the necessary information and documents. We are convinced that the proceedings will confirm the high standards of our business.

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