Scope 1 Emissions
2022 Communication on Progress
ARK Group DMCC
Published date
May 25, 2022
No. of questions
67
Supplemental files
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?
3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentThe sustainability topics are assigned to Heads of Corporate Services Departments.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentThese topics are addressed by the Senior Management Team.Prevention
6. Does the company have a process or processes to assess risk?
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?
Optional commentPolicies and procedures are in place for all sustainability topics. Policies on certain topics, key to our industry, are passed on to partners and sub-contractors.7.1. During the due diligence process, which business relationships are reviewed?
Optional commentAll suppliers and business relationships are screened through the Refinitiv World Check platform. In addition, partners (grantees) go through an extensive risk assessment process where organisational policies pertaining to several topics are evaluated.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 commentARK maintains an independent, third-party whistleblowing service provider that is available to any ARK employee, partners and service providers. Details of the whistleblowing channels are communicated to all ARK employees and partners regularly and are also included in all contractual templates. The provider offers numerous channels including email, telephone or text, and offers many languages.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.
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?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentThese are captures through annual policy reviews carried out by the Corporate Services Department.Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentSustainability topics are monitored via annual reporting and policy reviews, which is appropriate for the current size of the organisation.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentARK does not have board or a governance body. The CEO has the ultimate authority in the organisation.13. Do you produce sustainability reporting according to:
Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
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?
Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
2.1. For each human rights policy, is it:
Prevention
3. 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 issues?
4. 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 issue?
5. Who receives training for the following human rights issues?
6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
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.
ARK has the following policies in place to ensure that ARK, its employees, partners and consultants are not complicit in human rights abuses and to guarantee that its operations support and respect the protection of human rights: 1. Human Rights policy, notably sections on Human Trafficking and Modern Slavery 2. Child Safeguarding and Protection Policy, which is signed by all staff and partners upon onboarding 3. Policy on Protection from Sexual Exploitation and Abuse, which is signed by all staff and partners upon onboarding 4. Whistleblowing policy, which details how ARK uses a third-party provider, allowing whistleblowing to be done anonymously and through an independent third-party monitoring provider. All ARK Employees and partners are signatories to the human rights policies. This encompasses non-ARK entities and their employees who have entered into partnership agreements with ARK. All ARK employees must demonstrate commitment to our policy to endeavour to safeguard human rights, and a written commitment is a mandatory part of the individual or organisation onboarding and must be made prior to any work commencing. Regular internal audits, in addition to an external audit, ensure these policies had been agreed to in writing and filed appropriately. All policies were reviewed and updated in February 2022 and communicated to staff during the reporting period. In this period, ARK worked with Nigeria’s National Agency for the Prohibition of Trafficking in Persons (NAPTIP) to build their capacity to deter and disrupt human trafficking routes and other human right violations. ARK staff supported NAPTIP staff to develop their communications campaign development and monitoring and evaluation capabilities . ARK maintains an independent, third-party whistleblowing service provider that is available to any ARK employee, partners and service providers. Details of the whistleblowing channels are communicated to all ARK employees and partners regularly and are also included in all contractual templates. If an individual knows or has any reason to suspect that human trafficking and modern slavery has taken, is taking or may take place, they can report concerns either directly to management or through the external whistleblowing service provider. The provider offers numerous channels including email, telephone or text, and offers many languages. The option to report anonymously is also possible. To date, no Human Rights complaints have been received by ARK. ARK continued to specialise in projects with a strong human rights protection element. The project supporting gender mainstreaming within the Jordan police force was expanded to include elements from the Jordanian Armed Forces, and new projects include supporting anti-human trafficking efforts in Nigeria. ARK’s external whistleblowing provider was assessed as providing a good level of service and the contract was renewed. No cases of human rights abuse were reported via ARK’s external whistleblowing channel. ARK managers also confirmed no reports of human rights abuse had been reported via other means. ARK project teams will continue to ensure human rights considerations are integrated into standard project management tools and outcomes. All projects included a Gender and Inclusion Analysis, which inform the projects’ Gender and Inclusion Plan. These capture any human rights considerations and how they affect or are affected by different identity groups. ARK’s business development team submitted seven applications for funding to support the reduction of human rights abuse. ARK expanded its efforts to support security and law enforcement efforts to work towards gender equity and improved human rights by working with our key stakeholders to expand opportunities for capacity building and training bringing a new Jordanian beneficiary into our project.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
1.1. For each labour rights policy, is it:
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?
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?
4. Who receives training for the following labour rights issues?
5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
Optional commentThere is no board.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?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentNo injuries during the reporting period.11. In the course of the reporting period, what was the company’s incident rate?
Optional commentNo incidents during the reporting period.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?
Optional commentThere have been no incidents in the reporting period.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.
ARK recognises that our people are truly the core of our business. Our commitment to the fair treatment, diversity, equality, well-being and development of our people is the foundation of our culture and all we do. Employees have the right to collective bargaining, although there have been no instances to date with staff instead choosing to raise any queries at an individual level. Forced and compulsory labour, as well as child labour, has no place within ARK or our partners, and this is clearly stated in our Human Rights and related policies. To ensure recruitment activity that supports commitment to the United Global Compact, and in accordance with its Code of Conduct, ARK’s Human Resources policies include recruitment standard operating procedures which are in line with all ILO standards, as well as the UK’s Conflict Stabilisation and Security Fund and Department for International Development code of conduct, and US State Department guidelines. The policies are implemented at all stages of the employees’ process within the company, from recruitment to end of contract, and ARK’s HR department liaises regularly with external counsel to ensure compliance with all local regulations where we operate. These procedures ensure risk of discrimination is minimised at the entry point into the company. Once engaged, staff are protected by anti-discrimination policies and by a culture of diversity. ARK complies with not only minimum wage standards where relevant for all its employees, but as part of its usual process, ensures that the wage offered allows for decent living in the corresponding country or city. These are benchmarked against industry and local standards and in all cases are greater than the applicable minimum wage. The Head of Communications has continued to work with the CEO to create opportunities such as Town Halls to further embed the company culture, and to create frequent communications relating to ARK’s positive community impact. Staff well-being continues to be a high priority as working life is disrupted due to the COVID-19 pandemic. ARK provides support to staff via access to external professional services including online, telephone or in-person counselling, financial services support, and private health insurance. Flexible working is now incorporated into working life at ARK. During the pandemic, we produced guidance for working from home, as well as practical support for staff who have challenging childcare arrangements as and when schools invariably lockdown. This approach has meant that the global data demonstrating the effect of the pandemic in the form of women leaving the workplace has not been seen at ARK, where we strive to ensure all staff are supported so they can continue to function positively in their role. Women on maternity leave during the reporting period have continued to receive maternity pay and leave benefits over and above those required by local labour law, a benefit ARK maintains due to the importance of this action in the overall goal of equal opportunities. Annual leave allowances continue to exceed those required by local legislation and a culture of utilising leave encourages staff to optimise their work-life balance. During the reporting period, ARK also participated in World Mental Health Day and brought greater focus to the emotional and mental wellbeing of staff. This involved a weeklong email campaign focusing on mental health and work to challenge the stereotype of what mental illness can look like, and to increase acceptance of asking for help and support. In addition, company policies underpinning the human rights and labour principles were updated in February 2022. These policies include Prevention of Sexual Exploitation and Abuse; Human Rights; Whistleblowing; Recruitment; Compensation; Health, Safety and Wellbeing; Child Safeguarding and Protection, Due Diligence; Anti-Bullying and Harassment. These policies reinforce our commitment to the UN Global Compact’s principles on Labour. ARK’s high standards in all areas relating to the protection and positive treatment of people are also expected from our project partners, and our suppliers. Company policies are shared on initial engagement as part of the contractual documents. The reporting period saw ARK successfully implement various capacity building initiatives to help our partners implement these policies. With the introduction of new labour legislation into the UAE in February 2022, all UAE based ARK employees received updated employment agreements. The new UAE labour covers multiple important topics including discrimination, bullying and harassment and improved staff benefits and allowances. Although ARK policies and procedures already went above and beyond the updated labour law, ARK was pleased these positive changes are now solidified as legislation. ARK continued to develop female police officers through the ‘train the trainer’ capacity building activities allowing us to train more female officers and provide additional officers with opportunities to work in operational roles alongside their male counterparts. In the next reporting period, a gender and gender pay report will be conducted to ensure our achievements to date in this area are maintained.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentARK has a company wide environmental policy that has been reviewed in February 2022.1.1. For each environmental policy, is it:
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?
Optional commentARK is a SME consultancy firm, therefore some of the environmental issues are not material to ARK's operations. ARK does however publish a bi-annual environmental report where environmental considerations are addressed as a whole. This report details the ways in which ARK has reduced its environmental impact, as well as initiatives it is involved in through project activities3. 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?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
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)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change 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.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Optional commentNone of the above. Consulting and project Management.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):
Water consumption (volume of water in megaliters):
13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Sector-specific: Air pollution
17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.
Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
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.
ARK continues to work on environmental issues through its Green Team and periodic environmental reporting. Throughout the reporting period, ARK has continued its recycling initiatives. For instance, the Dubai office has continued its commitment to the GreenBox recycling initiative enabled by InfoFort. Due to reduced paper consumption and remote working, paper use has been drastically minimised with only one paper collection carried out between November 2020 and November 2021. 11 kg of paper was collected in November 2021. The Jordan office have continued their efforts to minimise the use of paper and other single-use items. In the reporting period, the office has been successful in minimising consumption to such levels that no collections by the designated recycling provider has been required. The Lebanon office underwent a project to sort and shred old archives. Approximately 50 boxes of old documents were shredded and disposed through a partner recycling facility. In addition, the Lebanon office also recycled a large batch of office IT equipment. Air travel continues to be minimal. A carbon offset payment was made in April 2022 via Carbon Footprint Ltd to support a global portfolio of verified carbon reduction projects. ARK is also continuing to advocate for environmental initiatives within its project delivery. Under the Palestinian Community Resilience Building (PCRB) project funded by the UK Government, ARK and its partner Ahlam Lajea Association (ALA) are working across six Palestinian refugee camps in Lebanon. To mitigate environmental risks and enhance people’s perception of environmental issues and protective practices, ARK implements an environmentally-focused grant located in Shatila Camp. As a result of expanding waste collection activities to Burj al Barajneh, Tarik al-Jdideh and the surrounding areas, the team continues to grow with a total number of 195 direct beneficiaries at the end of 2021. The beneficiaries are involved in all aspects of operations including waste collection, waste division, waste sorting and packaging. The project showcased the financial value of the collection of waste therefore has encouraged camp residents to work on their own as private waste collectors covering the camp and the surrounding areas and through that the project has provided hundreds of beneficiaries with a direct income opportunity. According to UNRWA, the project has contributed to a 35% reduction of waste from the camp’s neighbourhoods, as a decrease in the spread of rodents and insects in the camp as the direct collection from households and the distribution of waste bags led to a reduction in dumping waste in the streets. Furthermore, the ongoing collection of waste has contributed to protecting the camp from floods. As Sabra was flooding in the week of the 15th of November, Shatila was not as badly impacted as the drainage and sewerage infrastructure was not blocked by solid waste. Although restrictions to mobility and health and safety precautions continue due to COVID-19, ARK recognises the importance of continuing its environmental efforts. ARK will continue its recycling efforts in the various country offices to downsize its office footprint even further. ARK will continue to keep international travel to the minimum required to manage ongoing projects. Travel approvals will continue to be scrutinised carefully before sign-off from senior managers, both for risk and to maintain the trend of reducing our corporate emissions further. ARK’s recycling initiatives will continue in the next reporting period.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentARK has continued to improve its anti-corruption policies and procedures during the reporting period. ARK's Anti-Fraud, Bribery and Corruption Policy was updated in February 2022.2. 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 commentARK has a standalone Gifts and Hospitality Policy, which provides guidance on the procedures to be followed when staff are offered gifts and hospitality. In addition, conflicts of interest are covered in various other ARK Policies, including the HR manual and the Procurement manual.Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentTraining is provided to staff during onboarding, as well as throughout their employment by the Head of Compliance. Training sessions may be in connection to various initiatives and themes, such as roll-out of a new policy or a form, signing of a new project or a client. Key staff also participate regularly training provided by third parties such as clients, regulatory authorities (such as DMCC) and webinars provided by business partners such as law firms. Invitations to such trainings are widely circulated amongst staff. ARK also trains all new partners (grant funding recipients) on anti-corruption processes with records documented in the appropriate procurement files.3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of 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?
Optional commentARK maintains an independent, third-party whistleblowing service provider that is available to any ARK employee, partners and service providers. Details of the whistleblowing channels are communicated to all ARK employees and partners regularly and are also included in all contractual templates.7. Does your company engage in Collective Action against corruption?
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.
ARK has continued to improve its anti-corruption policies and procedures. In February 2022, ARK’s policies pertaining to anti-corruption were updated, including the Anti-Fraud, Bribery and Corruption Policy, Code of Conduct, Whistleblowing Policy, as well as the HR Manual. There has also been a heavy emphasis on training, both internally and with external partners. As part of ARK’s standard operating procedures, all partners who receive grant funding from ARK went through extensive compliance training as part of ARK’s strong emphasis on anti-corruption efforts. Capacity building of local partners in fiscal responsibility and compliant use of donor funding continues to be a top priority for ARK. Training efforts in the reporting period were focused on Lebanon based grantees. Key ARK staff also participated in an anti-corruption training provided by one of its clients, the UK Government. During the reporting period, ARK successfully completed a Single Audit, which is an organisation-wide audit not only of ARK’s financial statements, but also of internal policies and procedures and compliance with donor regulations. This annual audit requirement set by the US Government gives ARK an opportunity to continuously improve its policies and procedures. The audit is independent of ARK’s annual financial audit. ARK’s Senior Managers continue to monitor the Gift and Hospitality register with no concerns identified due to strict adherence to the appropriate policies, awareness raising activities and staff training. The Gifts and Hospitality policy was reviewed during the reporting period and required no updates. All ARK staff have updated their Conflict of Interest declarations as required annually, with reminders and policy refreshers sent throughout the year. Efforts continue in training of new partners and providing support to existing partners. ARK is also looking to carry out an annual review its risk assessment procedures for selection of grant recipients.