UN Global Compact 2023 Communication on Progress

COMMUNICATION ON PROGRESS QUESTIONNAIRE

Governance
Policies and Responsibilities
What is the time period covered by your Communication on Progress? (MM/YYYY) – (MM/YYYY)
11/2021-12/2022
G1. Does the board/highest governance body or most senior executive of the company:
Linked to: GRI Disclosures 2-12, 2-14, 2-22 (2021)
(Multiple choice -Select all that apply)
Issue an annual statement about the relevance of sustainable development to the company
Issue an annual statement that addresses impacts on both people and the environment
Issue an annual statement highlighting a zero tolerance for corruption
Sign off on organizational sustainability targets
Supervise Environmental, Social, and Governance reporting
Regularly review potential risks related to the business model
None of the above
Please provide additional explanation:
G2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Linked to: GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, and the commitment is focused on our own operations
Yes, and the commitment includes our own operations and suppliers
Yes, and the commitment includes our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
SBTi targets approved https://sciencebasedtargets.org/companies-taking-action#dashboard
Code of Ethics for Raben Group employees_v2.0.pdf
Download
Code of Ethics for Raben Group suppliers _v2.0.pdf
Download
G3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Linked to: NASDAQ G6.1; GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)

No, this is not a current priority
No, but we plan to within the next two years
Yes, focused on employee conduct
Yes, focused on employees and suppliers
Yes, focused on our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
G4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Linked to: GRI Disclosure 2-13 (2021)
(Matrix – Select one answer option per line)
No one is specifically responsible for this topic
Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)
Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)
Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights)
Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
G5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Linked to: GRI Disclosures 2-9, 2-13 (2021)
(Matrix – Select one answer option per line)
No formal structure
Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)
Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)
Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)
Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
To support Raben Group Board in managing ESG-related topics including climate-related risks, opportunities, we have established the Sustainability Committee. The Committee is comprised of the CEO, CFO, and directors of Business Development, HR, Marketing, R&D, Real Estate, Risk, Road Network, as well as the Head of Sustainability, who manages sustainability and ESG issues on daily basis.
Prevention
G6. Does the company have a process or processes to assess risk?
Linked to: GRI Disclosure 205-1 (2016)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G6.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G6.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
ESG risks, including climate risk, are integrated within Raben Group risk management framework. Its foundation is the Group Insurance and Risk Management Policy, which defines the main responsibilities in the area of risk management, methodology of risk identification and assessment, as well as taking risk mitigation actions. The Policy also describes the organisation of the risk management systems. The risk assessment methodology defines risk scales and probabilities which are common for analyses carried out in various areas of the Group’s activities. To ensure that all ESG risks are identified and addressed properly, we have adopted a risk management process, that covers all steps from identification to tracking. A significant aspect of the risk management is business continuity management (BCM). The aim of the BCM is to minimize the risk, including mitigating the risk of disruption to key services, designing appropriate procedures for serious incidents and maintaining efficient communication in crisis situations. Since 2022, the BCM roadmap covers tests directly related to climate risks, such as risks of power outages or risks of extreme weather events. The BCM process is based on the BCM Policy, adopted at the Raben Group level and overseen by the Risk Director.
G6.1 During the assessment of risk, has your company reviewed those suppliers and/or other business relationships where the risk related to human rights, labour, environment and/or anti-corruption may be particularly severe?
(Matrix – Select one answer option per line)
No
Yes
Corruption risks
Please provide additional explanation:
G7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Linked to: GRI Disclosures 2-12, 2-23-a-ii, 3-1, 3-3-d (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G7.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G7.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
G7.1 During the due diligence process, has your company reviewed those suppliers and/or other business relationships where the risk of adverse impacts on human rights, labour, environment and/or anti-corruption may be particularly severe?
Linked to: GRI Disclosures 2-23-e, 3-1 (2021)
(Matrix – Select one answer option per line)
No
Yes
Corruption risks
Please provide additional explanation:
We are currently in the middle of implementing due dilligence process
Concerns and Grievance Mechanisms
G8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Linked to: Reporting Guidance on the 10th Principle Against Anti-corruption – B3; GRI Disclosure 2-26 (2021)
(Radial – Select One)
No, this is not a current priority
No, but we plan to within two years
Yes, we have an informal process (e.g., through supervisors, others) [Prompts G8.1]
Yes, we have a formal process [Prompts G8.1]
Please provide additional explanation:
We provide our employees and other stakeholders with the opportunity to voice their concerns via a whistleblowing platform on our website. The whistleblowing process is also set out in the Code of Ethics for both employees and subcontractors. Wherever they might feel uncomfortable raising the issue through their supervisor or Human Resources Department, they can use the platform which guarantees protection against victimization, harassment or legal steps being taken against them.
G8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Linked to: GRI Disclosure 2-26 (2021)
(Matrix – Select one answer option per line)
No
Yes
Is the process communicated to all employees/workers in local languages
Is the process available to non-employees (e.g., suppliers, consumers, communities, and other business relationships)
Is the process confidential (e.g., whistleblowing process)
Are there processes in place to avoid retaliation
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other
Please provide additional explanation:
The platform is available in eleven languages and allows for anonymous reports either via a telephone hotline or an online application form. By ensuring that the process is fully digitized, all requests are registered. Whistleblowing investigations are conducted by Internal Audit and supervised by the Audit Committee. All reports are presented and discussed during Audit Committee quarterly meetings or, if required, on an ongoing basis between scheduled meetings.
Lessons
G9. How does the company capture lessons regarding each of the following sustainability topics?
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
No lessons are regularly captured
Conducts root cause analyses/investigation of incidents
Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly
Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labor Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
Executive Pay
G10. Is executive pay linked to performance on one or more of the following sustainability topics?
Linked to: CDP W6.4 (2022), CDP F4.3a (2022), CDP C1.3a (2022); Nasdaq G3 2335; GRI Disclosure 2-19 (2021)
(Matrix – Select one answer option per line)
No, and we have no intention to change for this is not a current priority
No, but we plan to within two years
Yes
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
Board Composition
G11. Percentage of individuals within the company’s board/highest governance body by:
Linked to: ISAR D.1.2 (2019), ISAR D.1.3 (2019); GRI Disclosures 2-9 (2021), 405-1 (2016)
(Matrix – Percentage & Radial)
Number (Please input answer as a whole number (e.g., 95% = 95))
Not applicable
Total number of board members (#)
Male (%) Note: Please input answer as whole number (e.g., 95% = 95)
Female (%) Note: Please input answer as whole number (e.g., 95% = 95)
Non-binary (%) Note: Please input answer as whole number (e.g., 95% = 95)
Under 30 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
30-50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
Above 50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
From minority or vulnerable groups (%) Note: Please input answer as whole number (e.g., 95% = 95)
Executive (%) Note: Please input answer as whole number (e.g., 95% = 95)
Independent (%) Note: Please input answer as whole number (e.g., 95% = 95)
Please provide additional explanation:
G12. Do you produce sustainability reporting according to:
Linked to: Nasdaq G9.1
(Select all that apply)
National/local regulation on sustainability
Security exchange regulations
Non-Financial Reporting Directive of the European Union (NFRD)
Global Reporting Initiative (GRI)
Sustainability Accounting Standards Board (SASB, now consolidated into the IFRS Foundation)
International Integrated Reporting Council (IIRC, now consolidated into the IFRS Foundation)
Climate Disclosure Standards Board (CDSB, now consolidated into the IFRS Foundation)
Task Force on Climate-related Financial Disclosures (TCFD)
Other voluntary frameworks (Please specify in text box) [Makes text box mandatory]
No sustainability reporting according to any frameworks nor regulations outside of this Communication on Progress
Please provide additional explanation:
Data Assurance
G13. Is the information disclosed in this questionnaire assured by a third-party?
Linked to: CDP C10.1 (2022); GRI Disclosure 2-5 (2021)
(Select all that apply)
Limited assurance for minority of metrics (e.g., GHG emissions only)
Limited assurance for majority of metrics
Reasonable assurance for minority of metrics
Reasonable assurance for majority of metrics
Other (Please provide additional information) [Makes text box mandatory]
No assurance for any metrics
Please provide additional explanation:
Human Rights
Materiality (including Saliency)
HR1. Which of the following has the company identified as material human rights topics connected with its operations and/or value chain, whether based on their salience (e.g., the most severe potential negative impacts on people) or another basis?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours) [Prompts additional line ‘Working conditions (wages, working hours)’ in Questions L1, L2, L3, L4, L5, L11]
Freedom of expression [Prompts additional line ‘Freedom of expression’ in Questions HR2–HR7]
Access to water and sanitation [Prompts additional line ‘Access to water and sanitation’ in Questions HR2–HR7]
Digital security/privacy [Prompts additional line ‘Digital security/privacy’ in Questions HR2–HR7]
Gender equality and women’s rights [Prompts additional line ‘Gender equality and women's rights’ in Questions HR2–HR7]
Rights of indigenous peoples [Prompts additional line ‘Rights of indigenous peoples’ in Questions HR2–HR7]
Rights of refugees and migrants [Prompts additional line ‘Rights of refugees and migrants’ in Questions HR2–HR7]
Other [Textbox Mandatory]
No human rights topics have been identified as material
Please provide additional explanation:
Commitment
HR2. Does the company have a policy commitment in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 2-23-a-iv, 2-23-b, 3-3-c (2021)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:

Please input the year the relevant human rights policy was last reviewed
Year (YYYY)
Digital security/privacy
Please provide additional explanation:
HR2.1. For each human rights policy commitment, is it:
Linked to: GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international human rights standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and suppliers
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving human rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Digital security/privacy
Please provide additional explanation:
ISO27001
Prevention
HR3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 3-1-b, 3-3-f (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/mitigation of the risks/impacts in question
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:
HR4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights topic?
Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information in the mandatory text box)
No action within reporting period
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:
HR5. Who receives training for the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:
HR6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights topics? Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information in the mandatory text box)
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:
Response and Reporting
HR7. During the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to adverse impact associated with the following human rights topic(s)?
Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d-ii (2021)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Digital security/privacy
Gender equality and women’s rights
Please provide additional explanation:
HR8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021)
(Text Box)
We are currently working on the implementation of German's supply chain due diligence Act in our business in Germany. In 2024 we plan to address DD in all markets.
Labour
Commitment
L1. Does the company have a policy commitment in relation to the following labour rights principles? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-c (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)

No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts L1.1]
Not applicable (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:

Please input the year the relevant labour rights policy was last reviewed
Year (YYYY)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
All topics addressed in Code of Ethics for employees
L1.1. For each labour rights policy, is it:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international labour standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed in consultation with workers and their representatives
Developed involving labour rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
L1.2. Does the existing company’s policy on freedom of association and collective bargaining:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Multiple choice – Select all that apply)
Reference the respect for the right of all workers to form and join a trade union of their choice without fear of intimidation or reprisal and protect workers against acts of antiunion discrimination
Prohibit any acts of interference in trade unions
Facilitate the collective bargaining with the trade union representatives
Provide trade union representatives with information required for meaningful bargaining in the context of bona fide negotiations
Reference the respect for the right of workers to submit grievances without suffering
We do have a policy on freedom of association and collective bargaining, but it does not include any of these details
We do not have a policy on freedom of association and collective bargaining
Please provide additional explanation:
We provide our employees with the opportunity to associate, the right to collective negotiations on terms and conditions of employment, and the opportunity to participate in the Management Board or its representatives. To ensure equal access to negotiation procedures for all employees who are not covered by collective agreement, we also support our employees in the development of substitute dialogue measures. Dialogue is free of any form of discrimination and employees have been informed about the freedom to perform representative and organizational functions in the workplace.
Prevention
L2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced Labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
L3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights topic? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
L4. Who receives training for the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
L5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring on progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Performance
L6. Do(es) the existing collective bargaining agreement(s) provide(s) more favourable rights than those provided in legislation, where appropriate?
(Select all that apply)
Yes, by providing more favourable conditions related to wages
Yes, by providing more favourable conditions related to working hours
Yes, by providing more favourable conditions related to health coverage and/or sick leave
Yes, by providing additional rights not otherwise provided (Please provide additional information) [Makes text box mandatory]
There is (are) no existing collective bargaining agreement(s)
No
Please provide additional explanation:
L7. In the course of the reporting period, what was the percentage of women in managerial positions? (%)
Linked to: ISAR C.1.1
(Matrix – Text Box with option for Unknown or N/A)
Percent women (Please input a whole number e.g., 50% = 50)
Unknown
Managerial position
Please provide additional explanation:
exactly 32,8%
L8. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Linked to: GRI Disclosure 405-2 (2016)
(Matrix – Text Box with option for Unknown or N/A)
Salary ratio (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Women/Men(%)
Please provide additional explanation:
L9. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Frequency of injury (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Frequency of injury
Please provide additional explanation:
Rate of recordable work-related injuries = [Number of recordable work-related injuries divided by Number of hours worked] multiplied by 1,000,000.
L10. In the course of the reporting period, what was the company’s incident rate (injuries per worker)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Incident rate (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose [Makes text box mandatory]
Incident rate
Please provide additional explanation:
Response and Reporting
L11. In the course of the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to the adverse impact associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
L12. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the labour principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Text Box)
Safe and healthy working environment: We build awareness and knowledge of risks among employees using a behaviour management, so-called SUSA, discussions method. SUSA is a process of structured one-to-one on site discussion designed to reinforce safe and discourage unsafe behaviour. The discussion promotes safe behaviour by enabling people to consider all the consequences of risk behaviour. According to research, SUSA discussion is effective if it is done regularly on each process, location and every worker has at least four discussions per year. Therefore, our aim is increasing the number of discussions and reach the recommended level. We also believe that all incidents can be prevented by engaging employees. It is awareness of potential hazards and their consequences, reaction or non-response that may avoid severe accidents. Open communication on health and safety build a truly mature and strong safety culture and, at the end of the day, has an impact on reducing work incidents. As we do every year, in 2022 we also ran a Group-wide Safety Month event. The recent edition followed the theme: Invisible – pedestrians & cyclist, which is in line with our priority to promote road safety. Within the scope of Safety Month, we promoted the new SHE application – EcoOnline, specifically the reporting module for risks, hazards, near-misses and incidents. Road safety is also being promoted by using the 'Don’t Be Wild' award-winning application for professional drivers and other drivers. The application, which is available in English, German, Polish and Hungarian, was launched in Czech in 2022.
Environment
Commitment
E1. Does the company have a policy commitment on the following environmental topics?
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 (2022); GRI Disclosure 3-3-c (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020),GRI 302 (2016)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts E1.1]
Not applicable (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Oceans are not in our business scope
Please input the year the relevant environment policy was last reviewed
Year (YYYY)
Climate change
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Please provide additional explanation:
All three topics are addressed in one document
E1.1. For each environmental policy commitment, is it:
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 2022; GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international environmental standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving environmental expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Climate change
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Please provide additional explanation:
Responsibility for the environment, including climate, is one of the pillars of Raben Group business strategy and, consequently, an integral part of its vision of development. As one of the largest logistics operators in Europe, and also one that is socially responsible, the company is committed to doing everything possible to tackle climate change and its effects. Raben considers it its duty to limit negative impact on the environment. Actions, which bring the company closer to achieving these goals have been set out in the “Sustainability Strategy for 2021-2025” and it is binding for every company of the Group. Environmental and climate actions are planned and implemented in an orderly manner. Within the framework of the implemented Integrated Management System (for example ISO 14001 Environmental Management), priority is given to minimising the impact of the operator's activities on the environment and limiting potential harmful effects by preventing emergency situations. Professional and comprehensive management systems help to define and implement measurable objectives, improve the environmental and climate performance of the organization and its main processes, within both direct and indirect impacts.
Prevention
E2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental topics?
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)

Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
E3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-iv (2016)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
E4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/ goals, track progress over time (internal programmes only) [Prompts E4.1 and E4.2]
Set annual targets/goals, track progress over time (internal and external programmes) [Prompts E4.1 and E4.2]
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
E4.1. For each environmental topic for which the company sets timebound goals/targets, what kind of targets has the company set? Please give a description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Linked to: CDP F6.1 (2022); GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Text Box)
- GHG emissions and energy consumption Raben Group has taken the ambitious decision to reduce CO2e emissions in its own operations as well as the entire value chain. It plans to significantly increase the share of consumption of renewable energy and to gradually transform the means of transport it uses. By measuring, reporting and neutralizing greenhouse gas emissions, Raben Group works for the common good - a safe future, thus fulfilling its commitments to sustainability. Target 1 Raben Group has set the science-based decarbonisation target in line with the Paris agreement pathway well-below. Thereby Raben Group commits to reduce Scope 1 and Scope 2 CO2e absolute emissions by 38.7% by 2030 (compared to the level of emissions in 2020). Target 2 Raben Group commits to engage its regular carriers, collectively responsible for 77% of Scope 3 emissions, in climate action by 2026, and for them to set emission reduction targets in line with scientific knowledge. - Waste management Raben Group is aware the global challenge of over-consumption and unsustainable exploitation of natural resources, which ultimately has a negative impact on climate, planet and every livelihood. The waste produced within the entire value chain is not always recycled and not returned to lifecycle. We believe that the response to this problem is the circular economy, expressed by the phrase “Reduce, reuse, recycle”. Our aim is to support the reduction of waste production and increase the level of recycling of waste resulting from our value chain. Target 3. Raben Group commits to increase the level of recycling to 90% by 2025. - Local and accidental pollution Raben Group is aware that spills of hazardous substances, oils, and fuels, among other substances, can potentially affect soil, water, air, biodiversity, and human health. To prevent any potential negative impact resulting to its operations and achieve ultimate goals which is zero chemical contamination, Raben Group commits to implementing all required safety measures and legally-required procedures, conducting training, and continuously building awareness within the organization. Target 4 Raben Group undertakes to carry out an annual review of the Major-accident Prevention Policy for warehouse classified as lower or upper-tier establishment.
E4.2. For each environmental topic in which the company sets timebound goals/targets, how is progress against target/goal tracked?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select all that apply for each line)
Progress is reviewed against goals annually or more frequently
Progress is reported internally to the most senior level
Progress is reported externally
Other (Please provide additional information in the mandatory text box)
Climate change
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
All data are in annual Raben Group ESG Report
E5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any impacts associated with the following environmental topic(s)?
Linked to: GRI Disclosure 3-3-d-ii (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Yes, remedy provided/enabled
No remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Chapter Environment in our latest ESG Report https://api.raben-group.com/fileadmin/CSR/Raben_Group_Report_2022_final-small.pdf
Climate Action
E6. What were the company’s gross Scope 1 and Scope 2 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Matrix – Select one answer option per line)
Measured Total Emissions (tCO2e)
We did not measure our gross GHG emissions [Please explain in the mandatory text box]
Scope 1 emissions
Scope 2 emissions
Please provide additional explanation:
using market based method
E7. What were the company’s gross Scope 3 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Multiple choice– Select one)
We fully measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below]
We partially measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below] [Prompts E7.1]
We did not measure Scope 3 GHG emissions
Please provide additional explanation:
Scope 3 781 083 tCO2e Category 1 - Purchased goods and services 25 777 2.98% Category 2 - Capital goods 32 419 3.75% Category 3 - Fuel- and energy-related activities 19 768 2.28% Category 4 - Upstream transportation and distribution 682 767 78.89% Category 6 - Business travel 188 0.02% Category 7 - Employee commuting 20 400 2.36%
E7.1. Which Scope 3 categories are included in the organization’s Scope 3 emissions calculation?
Linked to: GRI Disclosure 305-3 (2016); CDP C6.5 2022
(Multiple choice – Select all that apply)
Purchased goods and services
Capital goods
Fuel- and energy-related activities
Upstream transportation and distribution
Waste generated in operations
Business travel
Employee commuting
Upstream leased assets
Downstream transportation and distribution
Processing of sold products
Use of sold products
End-of-life treatment of sold products
Downstream leased assets
Franchises
Investments
Other - upstream
Other - downstream
Unknown
Please provide additional explanation:
E8. What percentage of the company’s revenue was invested in R&D of low-carbon products/services during this reporting period?
Linked to: CDP C4.3c (2022), CDP4.2b (2022); (partially linked to) ISAR A.3.3
(Matrix – Text Box with option for Unknown or N/A)
Percent of revenue (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
R&D for low-carbon products/services
Please provide additional explanation:
we are in the process to implement taxonomy and calculate it. We will be able to disclose this information next year
E9. Has the organization acted to support climate change adaptation and resilience?
Linked to: GRI Disclosure 201-2-a-iv (2016)
(Select all that apply)
We have taken action to increase organization-wide resilience to climate change
We have taken action to increase resilience in our supply chains
We have taken action to increase resilience in the communities in which we operate
We have provided funding for climate change adaptation and resilience initiatives and projects
We have not taken actions to build climate change resilience in the reporting period
Unknown
Please provide additional explanation:
Energy/Resource Use
E10. Please report the company’s renewable energy consumption as a percentage of total energy consumption in the reporting period.
Linked to: ISAR B.5.1; GRI Disclosure 302-1 (2016)
(Matrix – Text Box with option for Unknown)
% of total energy consumption (Please input a whole number e.g., 50% = 50)
Unknown
Renewable energy consumption as % of total energy consumption:
Please provide additional explanation:
Technology
E11. What percent of the company’s revenue came from low-carbon products/services during this reporting period? If applicable, please give a description of the products/services included in your calculation (e.g., relevant certifications)
Linked to: SASB CG-MR-410a.1a; WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Percent of total revenue (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Low-carbon products and services/total revenue for the reporting period
Please provide additional explanation:
Materiality-specific Questions
E12. Which of the following has the company identified as material environmental topics connected with its operations and/or value chain (e.g. the most severe actual or potential negative impacts on people and/or the environment)?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Water [Prompts questions E13 and E14]
Forests/biodiversity/land use [Prompts questions E15, E16 and E17]
Air pollution [Prompts questions E18]
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.) [Prompts questions E19, E20, E21]
None of these topics have been identified as material by the company
Please provide additional explanation:
Material topics for Raben Group: ■ Environment: E1 GHG emissions; E2 Climate change; E3 Energy management;
Materiality-specific: Water
E13. Please provide details regarding the company’s water withdrawal and consumption (own operations) during the reporting period.
Linked to: ISAR B.1.3; CDP W1.2b (2022), CDP W1.2d (2022); SASB CG-HP-140a.1; GRI Disclosures 303-3, 303-5 (2018)
(Matrix – Text Boxes with option for Unknown or N/A)
Volume of water in megaliters
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Total water withdrawal:
Fresh surface water withdrawal:
Groundwater withdrawal:
Brackish surface water/seawater withdrawal:
Produced water withdrawal:
Third-party water withdrawal:
Percentage of water withdrawn in regions with high or extremely high water stress(%):
Total water consumption:
Fresh surface water consumption:
Brackish surface water/seawater consumption:
Produced water consumption:
Third-party water consumption:
Percentage of water consumed in regions with high or extremely high water stress(%):
Please provide additional explanation:
E14. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Linked to: CDP W1.3 (2022); CDP W1.3a (2022 )
(Matrix – Text Boxes with option for Unknown or N/A)
Cubic meter/$ OR cubic meter/product type (Please input a number e.g., 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Water intensity of products
Please provide additional explanation:
Materiality-specific: Forests, Biodiversity, and Land Use
E15. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
Linked to: GRI Disclosure 304-1 (2016); ISAR B6.1, WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Number
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Sites
Hectares
Please provide additional explanation:
E16. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
Linked to: CDP F1.3 (2022); GRI Disclosure 304-1 (2016)
(Matrix – Text Boxes with option for Unknown or N/A)
Area (hectares)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Conversion of natural resources
Please provide additional explanation:
E17. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Linked to: CDP F6.11 (2022); GRI Disclosure 304-3 (2016)
(Matrix – Select one option or input a number per line)
No
No, but we plan to within the next 2 years
Yes, Project(s) area to date (hectares)
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Please provide additional explanation:
Materiality-specific: Air Pollution
E18. Where applicable, please report the company’s emissions of the following pollutants during the reporting period.
Linked to: GRI Disclosure 305-7 (2016); ISAR B.1.4
(Matrix – Text Box with option for Unknown or N/A)
Emissions (t)
Unknown (Please provide additional information in the mandatory text box)
Not applicable (Please provide additional information in the mandatory text box)
NOx
SOx
Volatile organic compounds (VOCs)
Hazardous air pollutants (HAPs)
Particulate matter (PM10)
Persistent organic pollutants (POPs)
Other (Please provide additional information)
Please provide additional explanation:
Materiality-specific: Waste
E19. In metric tonnes, please report the company’s total weight of waste generated during the reporting period.
Linked to: GRI Disclosure 306-3 (2020); (partially linked to) ISAR B.2.1
(Matrix – Text Box with option for Unknown or N/A)
Waste generated (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Solid waste
Please provide additional explanation:
E20. Please report the percentage of the company’s waste that was hazardous waste (e.g., hazardous waste ratio) during the reporting period.
Linked to: GRI Disclosures 306-4, 306-5 (2020); ISAR B.2.3
(Matrix – Text Box with option for Unknown or N/A)
Hazardous waste ratio (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Hazardous waste
Please provide additional explanation:
E21. Please report the company’s estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
Linked to: WEF Common Metrics
(Matrix – Text Box with option for Unknown or N/A)
Single-use plastic (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Single-use plastics
Please provide additional explanation:
Overall Environment
E22. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016)
(Text Box)
1. To effectively measure and manage our emissions, we have implemented the CO2 calculator that allows us to monitor emissions from road transport on a monthly basis in Business Units operating on a standard Transport Management System (TMS). This tool is integrated into our TMS and telematics software and takes into account various factors. Our solution is consistent with HBEFA and EN 16258. 2. IKEA Industry, Volvo Trucks and Raben Group join forces in Poland to deploy zero-emission Volvo FM electric trucks in the transport system. Electrification of transport is one of the solutions to address the root cause of climate change. 3. To reduce the emissions related to energy consumption, we signed a 7-year PPA (physical PPA), which ensures our supply of energy from renewable sources to all of our own depots in Poland by 2029. In addition, from 2022, energy with certificates of origin is also available in Germany. 4. Zero-emission warehouses are our key to climate-neutral logistics. The application of photovoltaic panels and heat pumps will consequently reduce emissions for a standard 10,000 m2 facility by 96%. 5. We have expressed our awareness of, and commitment to, tackling climate change by adopting the Environment and Climate Policy, which was updated in 2022, incorporating new climate targets. Despite the setting of the new targets, we have reaffirmed our previous commitments related to reducing emissions intensity in our two largest areas of operation. Meeting climate targets is a fixed agenda point for the Sustainability Committee.
Anti-Corruption
Commitment
AC1. Does the company have an anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-c (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, it is not an immediate business priority
No, but we plan to within the next two years
Yes [Prompts AC1.1]
Please provide additional explanation:
Corruption is a global problem which affects all countries and industries. To mitigate the risk of corruption within Raben Group and its supply chain in 2022, we implemented Anti-corruption Policy. Adopted on the Group level Policy will be implemented in all countries. The Policy, which includes a principle of zero tolerance for corruption, is supplemented by the Anti-corruption Manual. The manual sets up an anti-corruption framework and follows country-specific regulations. To meet the highest standards, we require the use of a due diligence procedure for assessing all business partners.
AC1.1. If yes, in what year was this programme last reviewed? (YYYY)
(YYYY)
Programme last reviewed
Please provide additional explanation:
Anti-corruption Policy was introduced in 2022
AC2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g., with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
(Radial – Select One)
No, but we plan to within the next two years
No, and we have no plans to develop them
Yes, included within a broader policy or as a standalone policy
Please provide additional explanation:

Prevention
AC3. Who receives training on anti-corruption and integrity?
Linked to: WEF Common Metrics; GRI Disclosure 205-2 (2016)
(Select all that apply)
Select employees [Prompts AC3.1]
All employees [Prompts AC3.1]
Contractors [Prompts AC3.1]
Direct suppliers of the organization [Prompts AC3.1]
Indirect suppliers of the organization [Prompts AC3.1]
Other – such as partners, clients, etc. [Prompts AC3.1]
No training provided
Please provide additional explanation:
In 2022 we started training all managers from all Raben's business units (15 countries). Until the end of 2023, all managers will be trained. Also in the second half of 2023, we will use online training for all blue-white collar employees.
AC3.1. How often is such training provided?
(Matrix – Select one answer option per line)
One time only
Every two or more years
Every year
We do not collect this data
Select employees
Please provide additional explanation:
Raben Group implemented anti-corruption policy in 2022. By the end 2023 the policy will be implemented in all Business Units followed by a detailed risk assessment. Full disclosure is planned for 2024.
AC4. Does the company monitor its anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-e (2021) for the topic GRI 205 (2016); SDG Action Manager - SDG 16: Peace, Justice, and Strong Institutions
(Select all that apply)
Review topics on ad hoc basis
Yes, through internal employee self-evaluations
Yes, through automated controls monitoring
Yes, through external independent monitoring
Yes, through other mechanisms (Please provide additional information) [Makes text box mandatory]
No, we do not monitor the anti-corruption compliance programme (Please provide additional information) [Makes text box mandatory]
Please provide additional explanation:
Raben Group implemented anti-corruption policy in 2022. By the end 2023 the policy will be implemented in all Business Units followed by a detailed risk assessment. Full disclosure is planned for 2024.
Performance
AC5. Please report the company’s total number and nature of incidents of corruption during the reporting year. If applicable, please describe the nature of the incidents in the text box below
Linked to: GRI Disclosure 205-3 (2016); WEF Common Metrics; ISAR D.2.1
(Matrix – Text Boxes with option for Unknown or N/A)
Number of incident(s) (Please describe the nature of the incidents in the text box below)
Unknown
Choose to not disclose
Confirmed during the current year, but related to previous years
Confirmed during the current year, and related to this year
Please provide additional explanation:
Response and Reporting
AC6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016); Reporting Guidance on the10th Principle Against Anti-corruption – B3
(Select all that apply)
Initial case assessment
Internal investigation
Review by risk/ethics committee
Review by board of directors
External audit/review
Other (Please provide additional information) [Makes text box mandatory]
Not applicable/no incidents in the reporting period
Please provide additional explanation:
One anti-corruption concern was registered in 2022 but after investigation, it wasn't confirmed as a corruption case.
AC7. Does your company engage in collective action against corruption?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, but we plan to within two years
No, it is not an immediate business priority
Yes (Please explain) [Makes text box mandatory]
Please provide additional explanation:
AC8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to implement the anti-corruption principle, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for the topic GRI 205 (2016)
(Text Box)
Corruption is a global problem that affects all countries and industries. To mitigate the risk of corruption within Raben Group and its supply chain in 2022, we implemented Anti-corruption Policy. Adopted on the Group level Policy will be implemented in all countries. The Policy, which includes a principle of zero tolerance for corruption, is supplemented by the Anti-corruption Manual. The manual sets up an anti-corruption framework and follows country-specific regulations. To meet the highest standards, we require the use of a due diligence procedure for assessing all business partners. The procedure will be developed by the end of 2023, with implementation in 2024.

Sustainability Reports*

Raben_Group_Report_2022_EN_online.pdf

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