2022 Communication on Progress

Safetec Nordic AS

Published date

May 18, 2022

No. of questions

60

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Safetec is committed to UN Global Compact and have updated the strategy accordingly.

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Safetec's Code of Ethics covers sustainability topics.

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    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

    Optional comment
    Dedicated position for QSSM from 2022, reports directly to CEO.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    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

    Optional comment
    Sustainability project, internal reporting (e.g. AMU), and knowledge HUB

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Safetec conducts a risk assessment on Group level, which is regularly updated. Risk and opportunities are also assessed in management meeting and projects.

    7. 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?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Annual Management Review and annual Sustainability Reporting covers review impacts of sustainability topics.

    Concerns and grievance mechanisms

    8. 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?

    Optional comment
    Notification through Code of Ethics.

    8.1. 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.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    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 information)

    Notifications are made available for 2 different roles (QSSM and HRM)
    Optional comment
    Confidential Notification/ Whistleblowing available through improvement log

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Safetec has not identified any processes with severe negative impacts to remediate for.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major 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

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    For a business like Safetec there are few incidents related to sustainability topics. Hence, there are in general no regular lessons captured. With respect to overtime use / working time this is monitored and followed up when breaches happen.

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Executive pay is set by the Board of Directors and is not directly linked to any sustainability aspects. Executive pay is based on principles that there are relatively small differences between management and expert consultants.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    5

    Male (%)

    80

    Female (%)

    20

    Non-binary (%)

    Safetec does not monitor status of non-binary employees or board members.

    Under 30 years old (%)

    0

    30-50 years old (%)

    20

    Above 50 years old (%)

    80

    From minority or vulnerable groups (%)

    Safetec does not monitor status of employees from minority groups.

    Executive (%)

    0

    Independent (%)

    100
    Optional comment
    All Board Members are considered to be Non-Executive, however 60% are hired regular employees and 40% are external.

    13. Do you produce sustainability reporting according to:

    Optional comment
    Safetec does currently not follow any particular standard for Sustainability reporting.

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Optional comment
    Safetec is ISO9001 and ISO14001 certified and audited by NEMKO on these. Financial statements are audited by EY.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In December 2021, Safetec contributed to the work of Plan International to ensure girls education. By supporting Plan’s work on this, we contribute to Sustainable Development Goal 4 to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all. In March 2022, Safetec decided to contribute to the Norwegian Refugee Council (NRC) for efforts for humanitarian aid to the most vulnerable in the conflict in Ukraine. NRC provide financial support, shelter, and water to people affected by the conflict. By supporting NRC, we contribute to Sustainable Development Goal 16 to promote peace, justice and strong institutions.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Code of Ethics (2020)

    Forced labour

    Code of Ethics (2020)

    Child labour

    Code of Ethics (2020)

    Non-discrimination in respect of employment and occupation

    Code of Ethics (2020)

    Occupational safety and health

    HSSSQ Policy (2022)

    Working conditions (wages, working hours)

    HR Manuals (2022)

    1.1. For each labour rights policy, is it:

    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 supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    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

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. 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 issues?

    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)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Not applicable for a professional services firm.

    Child labour

    Not applicable for a professional services firm.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Collaboration in the prevention/mitigation of the risks/impacts related to occupational safety and health is a core service provided to clients. Safetec has a workforce union and safety delegate service where labour issues are addressed.

    3. 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 issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    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

    Occupational safety and health

    Collaboration in the prevention/mitigation of the risks/impacts related to occupational safety and health is a core service provided.

    Working conditions (wages, working hours)

    Optional comment
    Safetec has a workforce union and safety delegate service where labour issues are addressed.

    4. Who receives training for the following labour rights issues?

    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

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    All employees are provided training during the onboarding process. In addition HSE and Union representatives are provided with more detailed training.

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Not applicable as freedom of association etc. is required by Norwegian law.

    Forced labour

    Not applicable for a professional services firm.

    Child labour

    Not applicable for a professional services firm.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    70
    Optional comment
    All regions have the right to establish a collective bargaining agreement. Only Norway have exercised this right.

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    70
    Optional comment
    All employees have the right to organise and for workers' organisation. Only Norway have exercised this right.

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    50

    Non-executive board

    20

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100
    Optional comment
    Covers only Norway and categories sufficient number of emploees (>2)

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0
    Optional comment
    Zero accidents and injuries. Work related illness is not measured.

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    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

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Safetec has had an active Working Environment Committee during 2021 that have worked in accordance with the Norwegian regulations and Safetec's HSS Manual. Focus areas for 2021 has been follow-up of employees with extra focus on well-being and workload, and prevention of job-related health problems.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Code of Ethics (2020)

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    1.1. For each environmental policy, is it:

    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 supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    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)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Together with our partners and customers, we strive to develop safe, reliable, and optimised sustainable solutions.

    3. 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?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    sustainable consulting

    Water

    Oceans

    sustainable consulting

    Forests / Biodiversity / Land Use

    Air Pollution

    sustainable consulting

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    sustainable consulting

    Energy & Resource Use

    sustainable consulting
    Optional comment
    Together with our partners and customers, we strive to develop safe, reliable, and optimised sustainable solutions.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Internal monitoring on paper consumption, waste, energy, and travel.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    We have no physical production or own any vehicles, hence we do not have any Scope 1 emissions

    Emissions (tCO2e)

    Scope 2 Emissions

    Emissions (tCO2e)

    Scope 3 Emissions

    Emissions (tCO2e)

    Optional comment
    Scope 1 Emissions : not relevant, Scope 2 Emissions: 4.46 tCO2e, Scope 3 Emissions: 32.5 tCO2e (all numbers Norwegian company only)

    6.1. Which Scope 3 categories are included in the organization’s scope 3 emissions calculation?

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    1
    Optional comment
    Cost of internal hours in R&D low-carbon projects (roundup percentage)

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    Safetec participates in R&D projects concerned with climate adaptation and resilience.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    Optional comment
    There is differentitation in numbers provided by landlords.

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Safetec only provide consultancy services.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Optional comment
    Consulting services in various market sectors.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Water is not a material topic.

    Groundwater:

    Water is not a material topic.

    Surface water:

    Water is not a material topic.

    Rainwater:

    Water is not a material topic.

    Wastewater:

    Water is not a material topic.

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water is not a material topic.

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Water is not a material topic.

    Groundwater:

    Water is not a material topic.

    Surface water:

    Water is not a material topic.

    Rainwater:

    Water is not a material topic.

    Wastewater:

    Water is not a material topic.

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Water is not a material topic.
    Optional comment
    Water is not a material topic.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Water is not a material topic.
    Optional comment
    Water is not a material topic.

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    Amount of pollution generated is negligible.

    SOx

    Amount of pollution generated is negligible.

    Volatile Organic Compounds (VOC)

    Amount of pollution generated is negligible.

    Hazardous air pollutants (HAP)

    Amount of pollution generated is negligible.

    Particulate matter (PM10)

    Amount of pollution generated is negligible.

    Persistent organic pollutants (POP)

    Amount of pollution generated is negligible.

    Other (please specify in text box)

    Amount of pollution generated is negligible.
    Optional comment
    Amount of pollution generated is negligible.

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    Amount of plastic waste generated is negligible.
    Optional comment
    Amount of plastic waste generated is negligible.

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    Amount of plastic waste generated is negligible.
    Optional comment
    Amount of plastic waste generated is negligible.

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Amount of plastic waste generated is negligible.
    Optional comment
    Amount of plastic waste generated is negligible.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Environment and sustainability has been included in the long term strategic plan in which Safetec shall develop services and solutions together with clients.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    Optional comment
    Safetec do not have an anti-corruption program, but our Code of Ethics clearly prohibits any form of corruption, money laundering or fraud. We do also have in place a system for anonymous notifications and whistle-blowing, and we have an Emergency Preparedness Plan that covers corruption.

    2. 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?

    Optional comment
    Policies and recommendations on conflict of interest is covered in our (1) Code of Ethics and (2) Project Manual.

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    Anti-corruption is covered by out Code of Ethics which is relevant for all employees and sub-contractors that are working for Safetec. Integrity is further stated as one of our company values.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    During the on-boarding process all employees go through our Code of Ethics.

    4. Does the company monitor its anti-corruption compliance programme?

    Safetec do not have an anti-corruption program, but our Code of Ethics clearly prohibits any form of corruption, money laundering or fraud. We do also have in place a system for anonymous notifications and whistle-blowing, and we have an Emergency Preparedness Plan that covers corruption. Notifications and incidents are monitored and reviewed on annual basis as part of the Management Review.

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    Zero incidents

    Confirmed during the current year, and related to this year

    0
    Zero incidents
    Optional comment
    Safetec has not had any incidents of corruption during the reporting year.

    6. 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?

    7. Does your company engage in Collective Action against corruption?

    Optional comment
    Safetec operate in regions with strong local laws and anti-corruption practices.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Safetec's Code of Ethics clearly prohibits any form of corruption, money laundering or fraud. We do also prohibit offering or accepting gifts, gifts of cash or services that are excessive in value to obtain an improper personal or business advantage. We have in place a system for anonymous notifications and whistle-blowing, and we have an Emergency Preparedness Plan that covers corruption.