2022 Communication on Progress

TGS ASA

Published date

May 27, 2022

No. of questions

63

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    Please see our 2021 Sustainability Report: https://www.tgs.com/sustainability

    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
    These documents are also publicly available: https://www.tgs.com/sustainability

    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
    Both TGS' Code of Conduct and Supplier Code of Conduct are publicly available: https://www.tgs.com/sustainability

    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
    Governance of these issues is discussed in detail in our 2021 Sustainability Report, available here: https://www.tgs.com/sustainability

    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
    Governance of these issues is discussed in detail in our 2021 Sustainability Report, available here: https://www.tgs.com/sustainability

    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
    Discussion of TGS' risk assessment process for each of these issues is discussed in more detail in our 2021 Sustainability Report: Governance of these issues is discussed in detail in our 2021 Sustainability Report, available here: https://www.tgs.com/sustainability

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Discussion of TGS' risk assessment process for each of these issues is discussed in more detail in our 2021 Sustainability Report: Governance of these issues is discussed in detail in our 2021 Sustainability Report, available here: https://www.tgs.com/sustainability

    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
    Discussion of TGS' risk assessment process for each of these issues is discussed in more detail in our 2021 Sustainability Report: Governance of these issues is discussed in detail in our 2021 Sustainability Report, available here: https://www.tgs.com/sustainability

    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
    Our hotline is publicly available through our website to both internal and external stakeholders, http://tgs.ethicspoint.com/ It allows for anonymous reporting either via web intake form or by phone. Our detailed reporting process is outlined in our 2021 Code of Conduct and further information may also be found in our 2021 Sustainability Report.

    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)

    Optional comment
    While the process is not communicated to all employees in local languages, all employees speak and understand English. Further, if you call to report a concern using the local numbers, the operator will be able to take the complaint in the local language if that is preferred.

    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

    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

    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
    Both TGS' short term incentive plan and long term incentive plan include health and safety targets related to our office and operational environment as well as emissions targets.

    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 (#)

    7

    Male (%)

    57

    Female (%)

    43

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    0

    Above 50 years old (%)

    100

    From minority or vulnerable groups (%)

    0

    Executive (%)

    0

    Independent (%)

    100

    13. Do you produce sustainability reporting according to:

    Optional comment
    TGS uses key sustainability frameworks to guide our nonfinancial disclosures, including the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board Standards (SASB), Task Force on Climate-Related Financial Disclosures (TCFD) Recommendations, UN Sustainable Development Goals, UN Guiding Principles on Business and Human Rights Reporting Framework, IPIECA and the World Economic Forum core set of ESG metrics. We view this report to be our Communication on Progress to the United Nations (UN) and this report identifies actions taken by TGS to specifically address the UN Sustainable Development Goals material to our operations. We also engage with several thirdparty firms that collect and report on ESG performance including Bloomberg, CDP, S&P Global’s CSA, Sustainalytics, ISS ESG and MSCI ESG.

    Data Assurance

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

    See KPMG's letter on page 20 of our 2021 Sustainability Report
    Optional comment
    The information provided in this questionnaire is based upon what is reported in TGS' 2021 Sustainability Report for which KPMG conducted an limited assurance assessment.

  • 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?

    Optional comment
    The above identifies the human rights issues most material to our organization, our operations and our value chain.

    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.

    TGS' actions related to human rights largely mirror our action taken towards labour as the human rights issue material to TGS relate to providing a safe and healthy working environment free of discrimination, harassment, forced or child labor that is also in accordance with all applicable labor laws and the laws related to freedom of association and collective bargaining. TGS' actions on these issues is outlined in more detail in the Labour section below.

  • 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

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    2021
    Optional comment
    See also TGS 2021 Modern Slavery Statement: https://www.tgs.com/sustainability/modern-slavery-statement

    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

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    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

    Working conditions (wages, working hours)

    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
    In addition to training, TGS contractually requires suppliers to abide by its Supplier Code of Conduct which includes having programs in place to ensure compliance with each of these topics.

    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

    Forced labour

    Child labour

    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 (%)

    3.4

    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 (%)

    0

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    38

    Non-executive board

    43
    Optional comment
    43% of our Board of Directors identify as female, 38% of our Executive Team identify as female, and 36% of our Senior Leaders identify as female.

    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 (%)

    Optional comment
    TGS initiated a gender compensation analysis through an independent provider at the start of 2021, utilizing the metrics set by the World Economic Forum and the UK Gender Pay Gap. The results of this analysis show that TGS had an overall gender compensation gap of 22%, but equal representation of women across all four pay quartiles.

    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
    Optional comment
    There were no work-related injuries to employees recorded in 2021

    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
    There were no work-related injuries, accidents or occupational illnesses to employees recorded in 2021 which resulted in lost days

    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

    TGS had no cause to provide or enable a remedy related to adverse impacts associated with this issue in 2021.

    Forced labour

    TGS had no cause to provide or enable a remedy related to adverse impacts associated with this issue in 2021. As noted in TGS' Sustainability Report, no instances of forced labour were reported in 2021.

    Child labour

    TGS had no cause to provide or enable a remedy related to adverse impacts associated with this issue in 2021. As noted in TGS' Sustainability Report, no instances of child labour were reported in 2021.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Detailed information on TGS' labor practices and the efforts made to ensure compliance with local labor laws and to provide a safe and health work environment free of discrimination and harassment may be found in our 2021 Sustainability Report.

    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.

    TGS strives to promote and maintain a work environment in which our people are treated with dignity, decency and respect, and published its Commitment to Diversity and Inclusion in 2021 in which TGS outlines its expectation that the workplace be business-like and free of unlawful bias, prejudice and harassment, and that employment decisions should be made on merit and not on the basis of race, color, national origin, religion, sex, disability or any other status protected by law. TGS also commits to being transparent in its progress and ensuring Board and Leadership oversight of its diversity and inclusion efforts. TGS’ policies against discrimination and harassment in the workplace are also reiterated in TGS’ Code of Conduct and local employee handbooks. Employees may report violations in accordance with the reporting procedures outlined below. Finally, all TGS employees receive annual training on TGS’ policies prohibiting discrimination, harassment, bullying and retaliation in the workplace and how to promote a diverse and more inclusive working environment. TGS respects national and local laws on freedom of association in the communities in which we do business, and the right of all people to join or not join a trade union to bargain collectively. 3.4% of our workforce was covered by a collective bargaining agreement in 2021. The company is committed to improving diversity, and in particular gender diversity, within the organization as well as working with other organizations to ensure women are given equal opportunity for development and advancement. Some key steps the Company took in 2021 include implementing a new Parental Leave policy in the US to provide increased time off to new parents. This new policy provides 16 weeks of paid time off for birth mothers and 12 weeks of paid time off for non-birth parents, all at 100% of salary. TGS initiated a gender compensation analysis through an independent provider at the start of 2021, utilizing the metrics set by the World Economic Forum and the UK Gender Pay Gap. TGS analyzes human rights and modern slavery risks within the organization and our supply chain as part of our annual corporate risk enterprise program. TGS’ employees are highly skilled and educated and predominantly based in offices and as such, TGS considers the risk of child labor or modern slavery in its workforce to be low. As with any company that predominantly relies upon contractors for its operations, the potential risk for human rights violations is greater within TGS’ supply chain. As part of its due diligence process, TGS requires suppliers to disclose their policies with respect to human rights and modern slavery and management of human rights issues in its supply chain and any human rights or modern slavery investigations, lawsuits or violations involving the supplier. TGS contractually requires suppliers and vendors to comply with human rights, modern slavery and labor laws, as well as TGS’ Supplier Code of Conduct and Human Rights policy, to ensure their supply chains do the same, in their work for TGS, and to notify TGS of any potential or actual violation of these laws. TGS has the contractual right to audit a supplier or vendor to ensure compliance with human rights laws as well as the right to terminate for violation of these laws or TGS’ policy. Finally, high risk third parties, suppliers and vendors also complete a certification of compliance on an annual basis that addresses their compliance with human rights, labor and modern slavery laws, TGS’ Human Rights policy and Supplier Code of Conduct. TGS had no cause to audit or terminate a supplier for failure to comply with the law or TGS’ human rights policies in 2021. TGS is committed to compensating its employees fairly and in accordance with all applicable labor laws. TGS’ compensation philosophy is based upon market conditions that are reviewed on an annual basis by the Compensation Committee of the Board of Directors. Employee compensation includes base salary, insurance and retirement benefits programs, and a profit-sharing bonus plan based on the Company’s performance and, in certain cases, stock-based, long-term incentive awards. TGS’ lowest salary is significantly above the national minimum wages. TGS’ HSE Director is responsible for managing and implementing TGS’ HSE-MS and reports directly to senior management as well as providing quarterly updates to both TGS Leadership and the Board of Directors. TGS defines safe operating procedures and guidelines in its HSE Management System (HSE-MS) designed to meet or exceed all appropriate legal requirements and, in the absence of any defined standards, to meet or exceed industry-wide best operating practices. TGS engages with its subcontractors in reviewing a range of HSE-related documents, including HSE project plans, hazard assessments, crew HSE plans and emergency preparedness documents. TGS monitors and assesses contractor performance by tracking and reviewing a range of leading and lagging HSE indicators to ensure adequate and correct incident information was collected and the situation remedied. TGS encourages contractors to report all near-miss and high-potential events to identify and share lessons learned, ensure adequate mitigation measures were implemented, and to safeguard personnel and equipment. Where necessary, TGS assists and participates in incident investigations. HSE performance is tracked and catalogued through TGS’ HSE-MS software application, allowing TGS to continuously monitor its contractors’ performance over time. Upon completion of a survey, TGS reviews all aspects of HSE performance to identify and discuss areas for improvement, lessons learned and additional hazards identified during the acquisition phase. HSE statistics and performance are reviewed with the senior management team on a quarterly basis. TGS achieved full compliance with vessel and land crew HSE audit requirements, and TGS Project and HSE Managers ensured that all outstanding action items were properly rectified before the start of acquisition. TGS provides multiple avenues for TGS’ internal and external stakeholders to report potential non-compliance with the law or TGS’ Code of Conduct, which also includes labour related issues, discrimination, harassment, modern slavery or human rights abuses. These mechanisms include the TGS hotline, which allows for anonymous reporting, and TGS prohibits retaliation.

  • 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

    2021

    Water

    2021

    Oceans

    2021

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

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

    2021

    Energy & Resource Use

    2021

    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

    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

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    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

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    TGS has set a long-term target to be net zero in Scope 1 and Scope 2 emissions by 2030. TGS has set short-term targets to reduce its Scope 1 and Scope 2 emissions by at least 10% from 2021 levels in 2022; by at least 20% from 2021 levels in 2023; and by at least 30% from 2021 levels in 2024. This is based up absolute numbers and is currently on track.

    Energy & Resource Use

    TGS' datacenter is the primary source of TGS' Scope 2 emissions due to the high power compute needed for TGS' operations. TGS tracks and reports the kWh required to run 1 teraflop of data to assess the energy efficiency of our on-premise computing. Since 2019, TGS has been installing more energy efficient equipment in our datacenter to address the energy and resource use.

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    TGS sets the annual goal of zero reportable spills or unplanned releases to the marine or land environment in our onshore and offshore operations. TGS has consistently met this goal each year.

    Oceans

    TGS requires all marine contracts to participate in Energeo's Ghost Net Initiative and to track and report all marine debris and abandoned fishing gear removed from the oceans by our vessels during seismic operations. In 2021, TGS' marine contractors removed 3.4 metric tons of debris from the marine environment.

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    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)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Oceans

    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

    Emissions (tCO2e)

    Scope 2 Emissions

    Emissions (tCO2e)

    Scope 3 Emissions

    Emissions (tCO2e)

    Optional comment
    The total Scope 1 emissions for 2021 was .67 mt CO2e, and the total Scope 2 emissions for 2021 was 11,215.16 mt CO2e. We track Scope 3 upstream emissions related to our operations (purchased goods and services) and that total in 2021 was 133,488.86 mt CO2e. This is detailed in our 2021 Sustainability Report available at https://www.tgs.com/sustainability

    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 (%)

    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.

    % of total energy consumption

    1.5

    Technology

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

    Percent of total revenue (%)

    0
    In 2021, TGS conducted an analysis of its operations and revenues to assess whether any of its activities are considered eligible activities under the EU Taxonomy Climate Delegated Act (EU) 2021/2139 (EU Taxonomy). TGS specifically focused on whether any of its operations or revenue aligned with the screening criteria for climate change mitigation and climate change adaptation as defined by the EU Taxonomy. At this time, TGS does not have any activities that meet the screening criteria, and thus has no revenue, operational expenditures or capital expenditures to report under the Taxonomy.

    Sector-specific Questions

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

    Optional comment
    TGS also operates in the renewable energy sector

    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

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

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

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

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

    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/$):

    Sector-specific: Forest, biodiversity, and land use

    14. 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).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    TGS is an office-based company that does not own, leave or manage any sites in areas adjacent to protected areas or key biodiversity areas. TGS also did not conduct any onshore surveys in 2021.

    Hectares

    TGS is an office-based company that does not own, leave or manage any sites in areas adjacent to protected areas or key biodiversity areas. TGS also did not conduct any onshore surveys in 2021.

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    TGS is an office-based company that does not own, leave or manage any sites in areas adjacent to protected areas or key biodiversity areas. TGS also did not conduct any onshore surveys in 2021.

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    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

    2071.59

    SOx

    161.37

    Volatile Organic Compounds (VOC)

    These emissions are not materially produced by our operations.

    Hazardous air pollutants (HAP)

    These emissions are not materially produced by our operations.

    Particulate matter (PM10)

    These emissions are not materially produced by our operations.

    Persistent organic pollutants (POP)

    These emissions are not materially produced by our operations.

    Other (please specify in text box)

    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.

    When planning and designing surveys, TGS commissions environmental impact assessments (EIAs) to identify marine mammal migration paths, spawning grounds, sanctuary areas or other ecologically sensitive locations that may be present in and around the survey area. TGS engages with stakeholders, such as fisheries and local communities, to understand their concerns and ensure ongoing communication throughout the duration of the seismic surveys. During the acquisition phase of a survey, TGS employs protected species observers (PSOs) and utilizes passive acoustic monitoring (PAM) to ensure that our field operations do not have a negative effect on cetaceans, turtles, marine mammals, etc. When operating in environmentally sensitive areas, such as Brazil and Argentina, TGS employs thirdparty HSE advisors who are tasked with managing all aspects of health, safety and the environment onboard their respective vessels, ensuring that full compliance with all environmental regulations and permit stipulations is achieved. To ensure compliance with the International Convention for the Prevention of Pollution from Ships (MARPOL), the Company requires all vessel contractors to report all spills, regardless of quantity and substance, and whether the spill entered the marine environment or was contained onboard a vessel. TGS has consistently met its goal of zero recordable spills and unplanned releases to the marine environment in our offshore operations since 2014, with 2021 being no exception. TGS requires all vessel contractors to comply with all applicable environmental laws and regulations and undergo audits from the International Marine Contractors Association or Offshore Vessel Inspection Database (IMCA or OVID). These audits are conducted by trained and accredited third-party auditors and inspectors; evaluate compliance with all applicable health, safety and environmental regulations and industry requirements; and ensure that all required health, safety and environmental permits and certificates are valid. TGS also conducts additional HSE inspections and audits throughout the acquisition phase of a seismic survey. In 2021, TGS chartered 37 vessels, including seismic, support, node layout and source vessels, and each of these vessels underwent the required audits and/or HSE inspections. TGS supports EnerGeo’s Ghost Net & Marine Debris Removal Initiative (GNI) and removed a total of 3.4 metric tons (7,496 lbs.) of debris from the marine environment through its 2021 operations. This initiative is an industry-wide effort to remove and collect ocean debris and fishing gear while conducting marine seismic surveys with the goal of creating and promoting a healthier marine environment and ecosystem. This debris is removed from the marine environment to reduce the harm it presents to ocean life such as turtles, birds, mammals or fish. Since 2020, TGS requires all vessels on TGS projects to report their marine debris removal efforts to EnerGeo and TGS on a project-by-project basis. In planning its onshore seismic operations, TGS continues to take additional measures and precautions beyond those set by law or regulation, including: (i) utilizing high-resolution imagery and LiDAR data during survey planning stages to help identify environmentally sensitive areas, chart routes of least or minimal impact and avoid tree cutting and vegetation disturbance; (ii) washing equipment to mitigate the potential spread of noxious plants or invasive species; (iii) planning operations away from riparian areas to minimize potential impacts on aquatic areas; (iv) working with biologists around designated wildlife-sensitive areas and abiding by any potential timing restriction related to wildlife migration periods; (v) completing archeological reviews of proposed survey areas prior to starting operations and ensuring that archaeologists clear off-road access to protect cultural resources; (vi) minimize fuel consumption and emissions by utilizing accommodations near the project area and reducing crew exposure hours; (v) blocking certain access points to recreational traffic within the survey area to allow vegetation to regenerate naturally and working exclusively on foot in designated areas to maintain a zero-impact footprint on the environment; (vi) utilizing existing train access and roads to minimize surface disruption and compaction and suspending vehicle operations during wet ground conditions to prevent surface deformation; (vii) maintaining regulatory compliance throughout continuous State and Federal Inspections; (viii) reducing waste, promoting recycling practices, burning or burying all biodegradable solid domestic waste without contaminating water bodies during operations; and (ix) carrying out reclamation programs to rehabilitate areas disturbed by vehicles operations.

  • Anti-corruption

    Commitment

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

    2021
    Optional comment
    For more information: https://www.tgs.com/sustainability

    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
    TGS has a Code of Conduct that expressly covers Conflicts of Interest, Gifts and Entertainment, and Interactions with Government Officials. TGS also maintains an Anticorruption Policy, Gifts & Enertainment Policy, Charitable Contributions and Social Welfare Policy, and Government Travel and Training Policy

    Prevention

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

    Optional comment
    TGS requires all suppliers, vendors and consultants deemed a high compliance risk to undertake anti-corruption training on an annual basis.

    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
    TGS requires all suppliers, vendors and consultants deemed a high compliance risk to undertake anti-corruption training on an annual basis.

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

    TGS also conducts quarterly reviews

    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
    None

    Confirmed during the current year, and related to this year

    0
    None
    Optional comment
    As noted in our 2021 Sustainability Report, TGS had no confirmed instances of corruption in 2021 or 2020.

    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?

    TGS works with its partners and its suppliers to ensure agreement and practices aligned with the OECD Convention on Combating Bribery of Foreign Public Officials. This is achieved through training of suppliers and high risk third parties on risk areas, implementation of a Supplier Code of Conduct, and working with industry groups to ensure ethical practices are implemented in our industry's operations.

    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.

    TGS conducts a risk-based analysis that assesses the potential anticorruption risks of projects. This analysis includes a review of the scope of the project; the countries in which it will take place; the use of any partners, consultants, suppliers or vendors; and the necessary mitigation measures to combat the corruption risk. Only a small portion of TGS’ revenues (<1%) derive from projects located in the 20 countries ranked lowest by Transparency International in its Corruption Percentage Index. In 2021, TGS conducted due diligence on partner and third-party relationships (based upon various risk factors including geographic location and nature of services) at the outset of the relationship and updated the information on a regular basis throughout the relationship and incorporated compliance provisions in the agreements that prohibit bribery and corruption. The Company continued to require these third parties to certify their compliance with TGS’ Anticorruption policy and complete online anticorruption training. TGS also reviewed payments made by these third parties. All of TGS’ international agents were assigned anticorruption training and a compliance certification.