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)
01/2022 - 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:
We intend to look at publishing a public commitment to at least the environment on siro.ie within the next 2 years.

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:
HR - human rights, labour rights, environment / HSEQ - labour rights, environment / Legal - anti-corruption
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:
ESG Committee looks at environment (but not the other topics), limited representation from key departments. The committee is still fairly new and as such although access to necessary information is provided, understanding of risks within the committee remains low.
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:
Environment risks - ISO14001, HSEQ risk assessment process policy & internal audits Corruption risks - outlined in anti-bribery and corruption policy, Labour rights/human rights - HSEQ focused (near miss reporting, risk assessment process policy, ISO 45001 & OHSAS 18001), gender pay gap reporting conducted annually to identify risks, IT monitor digital security
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
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
Environment - ISO14001 includes work conducted by contractors, internal audit held in 2022 focused on material suppliers Corruption - anti-corruption and bribery policy applies to all suppliers Labour rights/human rights - HSEQ risk assessments e.g. MESC's, RASC's etc apply to contractors, assessed heavily during on-boarding of new contractors. Internal audit held in 2022 focused on gender equality of material suppliers
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:
Environment - ISO14001 includes work conducted by contractors, internal audit held in 2022 focused on material suppliers, audits held regularly by HSEQ team Corruption - anti-corruption and bribery policy applies to all suppliers and includes a section on due diligence Labour rights/human rights - development of RASC's and MESC's, daily risk assessments etc. Internal reporting on gender pay gap to mitigate negative impacts on gender equality conducted annually.
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
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
Environment - material suppliers recently audited, ISO14001 Corruption - due diligence process outlined in anti-bribery and corruption policy which applies to all new and existing suppliers, Labour rights/human rights - all MESC's, RASC's and risk assessments apply to work conducted by contractors
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:
Whistleblowing policy - covers corruption, environment, HSEQ etc.
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:
Whistleblowing policy - applies to all topics. Personal concerns can be processed through Grievance Policy or Dignity at Work Policy.
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:
Labour rights/human rights & environment - HSEQ risk assessment process (register) Corruption - anti-corruption and bribery policy requires a register to be maintained, bi-annual review of policy conducted
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:
We voluntarily publicly report on sustainability, however we do not fall within national/local regulation. We report in line with the UN SDG's.
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:
Assurance for GHG emissions is being prioritised for the next reporting period
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:
Topics identified as being material to SIRO in the 2023 materiality assessment
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:
Digital security sits within the IT User Security Policy Gender equality sits within the DEI Policy

Please input the year the relevant human rights policy was last reviewed
Year (YYYY)
Digital security/privacy
Gender equality and women’s rights
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
Gender equality and women’s rights
Please provide additional explanation:
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:
Gender equality - Women and Allies @ SIRO was set up to collaborate with colleagues on how to mitigate issues regarding gender equality in the workplace.
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:
Digital security - IT provide mandatory security training quarterly Gender equality - Women and Allies @ SIRO have provided multiple training sessions to the workforce (mentoring), HR have provided unconscious bias training, SIRO have collaborated with an external group Women in Technology and Science, SIRO HR have completed annual gender pay gap reporting and undertook remedies during pay review cycle.
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:
Digital security - IT security training mandatory for all employees. Gender equality - Unconscious bias training held for some employees in reporting period, ERG committee events open to all employees but attendance in voluntary.
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)
In 2023 SIRO intends to update the gender pay gap reporting in line with incoming Irish regulatory standards ahead of mandatory date. SIRO also intends to set targets for executives for gender equality at a minimum.
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
Please provide additional explanation:
Non-discrimination included in Dignity at Work policy and code of conduct Safety is included in Safety Policy and code of conduct

Please input the year the relevant labour rights policy was last reviewed
Year (YYYY)
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Please provide additional explanation:
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)
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Please provide additional explanation:
Non-discrimination - code of conduct for non-discrimination applied to supply chain. Both code of conduct and dignity at work policy approved at most senior level and apply to entire workforce. Safety - aligned with ISO standards, approved at most senior level and applied to SIRO employees and contractors.
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:
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
Please provide additional explanation:
Safety - HSEQ team deliberately and consistently engages with internal employees and contractors to prevent/mitigate risks as part of normal business including audits, toolbox talks, workshops, quarterly meetings etc.
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
Please provide additional explanation:
Non-discrimination - compulsory dignity at work training held in reporting year, unconscious bias training and disability awareness training held by SIRO for all employees Safety - ongoing collaboration and training of employees and contractors across a range of topics, frequent audits by HSEQ team, training for internal employees and contractors held on an ongoing basis by HSEQ team (recorded in training register)
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
Please provide additional explanation:
Non-discrimination - Dignity at work training mandatory on Metacompliance. Non-mandatory training including unconscious bias and disability awareness training held annually for select employees (e.g. for those involved in recruitment). Safety - HSEQ training provided to all employees at beginning of employment, contractors and suppliers provided training where required on necessary topics - training register managed by HR/HSEQ, ad hoc training held at quarterly meetings, build meetings, company off sites etc.
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
Please provide additional explanation:
Non-discrimination - Dignity at work policy only published in 2022. Training completion rates are monitored. Safety - HSEQ set annual targets and report to SLT and board
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:
Maintained at 31% from previous year.
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:
Mean pay gap (bonus not included) is 4% in favour of women
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:
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
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)
No additional comments
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:
Given the nature of our works, water, oceans and air pollution are not material topics for the SIRO business as identified by our materiality assessment. Climate change, biodiversity and waste are included within the Code of Conduct (updated Dec 2022). Waste is further covered with the HSEQ risk assessment policy. Energy is included within the Sustainability Policy (updated Nov 2022).
Please input the year the relevant environment policy was last reviewed
Year (YYYY)
Climate change
Forests/biodiversity/land use
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
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
Forests/biodiversity/land use
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
The Code of Conduct is approved by the Director for People and Culture (sitting on the senior leadership team) and applies to all colleagues and persons working on behalf of SIRO (climate change, biodiversity use). The Sustainability Policy is approved by the CEO and only applies to SIRO colleagues (energy use). Waste Management EHSMS 3.7 Version 5.0 and Risk Assessment Process EHSMS 2.2 Version 7.0 approved by Head of HSEQ. Waste and biodiversity use falls under ISO 14001 certification.
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:
Climate change - Work with FTTH Council on setting emission baselines for the fibre industry & identification of emissions reduction opportunities. Water, oceans and air pollution - Materiality assessment held in 2023. This assessment identified all three topics as non-material to SIRO. Waste - Monthly reporting from all subcontractors on waste, assisted by Head of HSEQ to identify opportunities for improvement. Audit of material suppliers held in 2022 by Head of HSEQ including management of packaging waste. Collaborating with external groups to research recycling options for C&D waste. Working with local governments and industry to reduce our concrete and asphalt waste to landfill. Energy - Work with contractors to identify and pilot energy efficiency projects.
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:
Climate change - Work with FTTH Council on setting emission baselines for the fibre industry & identification of emissions reduction opportunities. Engaging with contractors and material suppliers on scope 3 emissions including data availability. Audited scope 1 and 2 emissions against GHG Inventory Management Plan. Biodiversity use - Work with Biodiversity in Schools providing local schools with education on pollinators. Work with AIPP to carry out science-based actions to protect pollinators including engaging with SIRO employees and contractors. Waste - Monthly reporting from all subcontractors on waste, assisted by Head of HSEQ to identify opportunities for improvement. Working with external parties to research recycling options for C&D waste. Working with industry and contractors to reduce our concrete and asphalt waste to landfill. Energy - Work with contractors to identify and pilot energy efficiency projects.
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:
Climate change - Science-based target through SBTi, 4.2% annual reduction target internally Water - ad hoc monitoring of water consumption in office when provided by building manager (annual basis), no targets associated with this due to very low consumption. Biodiversity use - Project specific targets are set (e.g. AIPP, Pollinator Project) Waste - HSEQ internal target Energy - SIRO has only begun to monitor and track energy use and as such has no existing target.
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)
Climate change - Reduce scope 1 and scope 2 emissions by 50% by 2030 from a 2019 baseline year. Absolute target, externally verified, not on track. This is supported by an absolute 4.2% annual reduction target internally. Waste - Internal HSEQ target to achieve zero net waste to landfill by 2030. Absolute target, not externally verified, on track (92% reduction by end of 2022).
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.)
Please provide additional explanation:
Both climate change and waste are reported on annually in the sustainability report. Waste figures are reported internally to the SLT and board. Climate change figures are reported internally to the SLT with the aim to report to the board in the following reporting year.
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:
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:
Scope 2 is reported according to location-based EF
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:
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:
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:
CTO owns risk that relates to network and systems resilience. This risk looks at business continuity, resilient infrastructure, disaster recovery etc. Actions include redundancy and backup, preventative maintenance, upgrade and reinforcement, network monitoring, response to outages, resilient power supply (e.g. back up batteries). SIRO has also undertaken energy efficiency investigations to explore peak shifting and reducing consumption in POP cabins.
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:
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:
254.465t Mixed waste/general, 34316.59t backfill waste and 5600.05t other
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)
During the reporting period, SIRO has increased focus on community engagement by participating in a national biodiversity project. SIRO has also been investigating C&D waste recycling opportunities for backfill, concrete and asphalt which could have a positive impact on small scale utilities overall. SIRO is exploring options to increase percentage of renewable energy in our overall consumption in the following reporting period. In 2023 SIRO will have emissions data from 2019 and 2022 verified by a third party. SIRO will report under the CDP in 2023.
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:
AC1.1. If yes, in what year was this programme last reviewed? (YYYY)
(YYYY)
Programme last reviewed
Please provide additional explanation:
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:
SIRO has a stand alone Anti-Bribery and Corruption Policy, last reviewed in 2022. SIRO also has a Whistleblowing Policy, last reviewed in 2022.

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:
Mandatory training programme developed in 2022 and uploaded to Metacompliance.
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
All employees
Please provide additional explanation:
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:
The anti-corruption and bribery compliance program, including the policy, was only developed in late 2022. Monitoring of participation rates is ongoing.
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:
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)
We have set a target to achieve 100% compliance for all internal employees to complete the anti-corruption training. To help us achieve these target we provided in person training as well as online training through Metacompliance. However we are facing challenges in reaching 100% with current participation rates at 67%. We are working to identify ways to increase participating in the mandatory online training.

Sustainability Reports*

60112916-SIRO_Sustainability-Report_2022-v341 (FINAL).pdf

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