Report - COP Prototype

2022 Communication on Progress

Mantu

Published date

May 30, 2022

No. of questions

Supplemental files

Mantu Information Security Policy_EN_2022.pdf D&I Policy.pdf Health and Safety Policy 2022..pdf 2022_Sustainable Development Policy.pdf 2022_Sustainable Development Policy.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

Mantu's CEO writes a letter every year to reaffirm the company's participation in the UNGC. In this letter, he addresses all the topics marked above. He signs off on the sustainability targets during the monthly management committee. He is also in charge of reviewing the yearly sustainability report and validating the Sustainable Development policy. He reviews the main risks related to the business model.

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

All our commitments are outlined in our latest sustainability report (December 2021). This report is downloadable here: https://www.mantu.com/positive-impact/

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

Mantu's Code of Conduct covers all these topics internally. Our sustainable procurement charter ensures that these principles are also respected in our supply chain. More information is provided in our sustainability report (p. 48-51).

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

All these topics are discussed at the board level, especially by the Executive VP Human Resources and the Executive VP Sustainable Development. Operationally, the Positive Impact department is in charge of managing sustainability topics.

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

All these topics are reviewed daily by the Risk and Audit department as well as the Positive Impact department. These departments work alongside other relevant governances (business, HR, legal, etc.) and stakeholders depending on the topic. They report to the Executive VP Human Resources board member and the Executive VP Sustainable Development.

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

Risks are assessed yearly on these levels through 5 axes of compliance: Quality (ISO9001), Information Security (ISO27001), Environment (ISO14001 & ISO50001), Health & Safety (ISO45001) and Ethics (which include human rights, environmental impact, fraud and corruption). This process is managed through yearly cycles supported by an integrated risk assessment methodology and an integrated risk management tool, allowing us to map the company’s risk profile, track evolution, and ensure an iterative and continuous risk monitoring process. We also have a business continuity and recovery planning and crisis management system. This system allows high-level risk identification, and continuous monitoring and improvement across each scope.

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

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

A due diligence process is inherent to our risk analysis methodology: risks accross our activities and value chain are detected, their importance is assessed according to their likelihood and impact/potential impact and concrete measures are then taken to handle these risks (by mitigating/accepting them for instance).

7.1. During the due diligence process, 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

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?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

Optional comment

A formal procedure exists within Mantu to raise concerns. In regards to a company employee, this can be done by contacting a specific email address (directed to a specific team). The incident can also be reported to the employee's manager, their superior within the company, a director, or human resources representative. All employees are encouraged to promptly report such incidents to any of the individuals listed above to ensure that the company can respond immediately. Mantu takes all complaints very seriously, and all reports are investigated promptly, thoroughly, and as confidentially as possible. All information received throughout the investigation will be kept in confidence, except to the extent necessary to conduct a thorough investigation. If the investigation confirms that a breach of the present code of ethics & conduct or any discrimination or harassment has taken place, disciplinary action will be taken against the offender. Depending on the severity of the misconduct, disciplinary action against the employee may range from a warning to termination of employment. Disciplinary action may also be taken against managerial employees who are aware of a complaint or inappropriate behavior occurring, and who fail to take immediate and appropriate action in response to such conduct. If the harassment is from a vendor, client, or customer, the company will take appropriate action to stop the reported behavior.

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

A formal procedure exists within Mantu to raise concerns. In regards to an employee of the company, this can be done by condacting a specific email address (directed to a specific team). The incident can also be reported to the employee's manager, their superior within the company, a director, or human resources representative. All employees are encouraged to promptly report such incidents to any of the individuals listed above to ensure that the company can respond immediately. Mantu takes all complaints very seriously, and all reports are investigated promptly, thoroughly, and as confidentially as possible. All information received during the investigation will be kept in confidence, except to the extent necessary to conduct a thorough investigation. If the investigation confirms that a breach of the present code of ethics & conduct or any discrimination or harassment has taken place, disciplinary action will be taken against the offender. Depending on the severity of the misconduct, disciplinary action against an employee may range from a warning to termination of employment. Disciplinary action may also be taken against managerial employees who are aware of a complaint or inappropriate behavior occurring, and who fail to take immediate and appropriate action in response to such conduct. If the harassment is from a vendor, client, or customer, the company will take appropriate action to stop the reported behavior.

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

Optional comment

Root cause analyses are conducted for each case of minor/major compliance that is raised by our internal audit team on Mantu's reference standards. This process enables a constant improvement of our policies/processes/practices.

Executive Pay

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

Optional comment

Executive pay linked to sustainability performance is not yet in place but we plan to set it up within the next two years.

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 (#)	9
Male (%)	78
Female (%)	22
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	89
Above 50 years old (%)	11
From minority or vulnerable groups (%)	0
Executive (%)	100
Independent (%)	100

Optional comment

All our governance structures are outlined in our latest sustainability report p. 14-15 (December 2021). This report is downloadable here: https://www.mantu.com/positive-impact/

Data Assurance

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

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

All the internal sources of the data that we disclose that falls under the scope of the Ecovadis assesment have been checked during our yearly evaluation. We obtained a gold medal in 2021 in this sustainability assessment. The environmental metrics we disclose have been verified by an external auditor during our ISO 14001 & ISO 50001 certification, without any major non-compliance found.

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2022
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Employees undertake to comply with all security instructions and internal regulations, particularly quality regulations, as may be in force from time to time within the company. To ensure information security, Mantu has committed to comply with the ISO 27001 certification. In European countries, Mantu is also compliant with the General Data Protection Regulation (GDPR) concerning data privacy. Mantu will also observe local data privacy legislation and implement the relevant provisions in accordance with local legislation. When employees are required to work at the premises of client companies, they shall abide by the provisions of the client’s internal regulations, particularly with regards to health protection, safety, and confidentiality.

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

The policy which has been developed respects the international best practices on the matter. Like all Mantu's policies, it has been revised at the most senior level of the company, it is publicly available and covers our own operations and our value chain.

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?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

At the end of 2021, we conducted a double materiality analysis to better understand how our stakeholders have been affected by our activities and the significance of Mantu's impact on these topics. In this context, stakeholders have been interviewed regarding digital privacy.

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?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

On the topic of digital security/privacy, Mantu has put in place: - Awareness training to prevent information security breaches -Information security due diligence program of third parties, especially with suppliers, with specific questions on the RFP questionnaire - Information security risk assessments - Audits of control procedures to prevent information security breaches - Whistleblower procedure for stakeholders to report information security concerns

5. Who receives training for the following human 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.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

All employees are trained in digital security during their onboarding processs. Our direct suppliers are trained in this topic during the RFP process.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human 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)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

For each high or critical risk, a decision is made with according action plans to mitigate it (in cases where mitigation has been identified as the most relevant option).

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)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Mantu has not been involved in any issues which could have required remediation solutions in 2021. There have been no serious negative impacts to report.

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.

Following a continuous improvement approach, Mantu keeps refining its methodology regarding human rights principles. We are working to better integrate the recommendations of the OECD on due dilligence for responsible business conducts.

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)

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)

Optional comment

All our policies are based on international laws, standards, or best practices. They are all made publicly available, are approved at the most senior level of the company and are applied in our own operations. Our suppliers are also involved as they ratified our Sustainable Procurement Charter, that encompasses all these policies.

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)

Optional comment

Mantu's internal policies, as the code of ethics and conduct, includes chapters about employees rights such as the collective bargaining agreement, freedom of association, human rights, and health and safety. The policies mention the position of the company towards these topics as well as guidelines or instructions on how to prevent risks. These policies are available to all employees and are pro-actively shared during onboarding. Furthermore, Mantu engages with employee representatives in the prevention and mitigation of the risks and impact on the different topics.

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)

Optional comment

Mantu engages with employee representatives on all the topics mentioned above. Our suppliers are also committed to abiding by human rights regulations and to building capacity on these different topics. For instance, some of our suppliers have committed to hiring a certain percentage of workers with disabilities. Mantu also collaborates with governmental and regulatory bodies. For instance, in 2021 we ratified the United Nations' Women Empowerment Principles. Audits are also conducted, either internally or by external auditors, and corrective action plans are drafted for any non-conforming or improvement point. All our employees are trained in the topics mentioned above during their onboarding proccess.

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

Our suppliers are committed to human rights issues in the context of the ratification of our Sustainable Procurement Charter. All employees are trained in various human rights labour topics during their onboarding, either through e-learning sessions or policy ratification. Our contracts, made with either our suppliers or our clients, include some clauses regarding human rights labour.

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)

Optional comment

Mantu participates in different reporting initiatives such as the GRI, or the Ecovadis assessment. These standards provide a list of indicators that we use year after year to assess our progress. We also set ambitious targets in these topics and review them regularly. External parties, such as auditors, also check our practices and enable us to keep improving our performance. As child labour and forced labour are less likely to happen in our value chain, we only review potential issues on an ad-hoc basis.

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	83

Optional comment

The commitment to manage freedom of association and collective bargaining is based mainly on regulatory compliance, but we have also undertaken voluntary initiatives. We focus on countries where we have a legal obligation to organize the elections of employee representatives, where we have requests from trade unions (e.g., UK, Sweden) to join our company, or where most employees are unionized and issue a membership invitation to management. We then measure the effectiveness of our approach through internal audits and surveys (at local and group level).

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 (%)

Optional comment

This topic is difficult to monitor, as some employees are unionized without the trade union being affiliated with the company.

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

	Percent of women (%)	Unknown
Senior leadership level position	30.2
Non-executive board

Optional comment

Mantu does not have a Non-Executive board. There are 30,2% of women within the organization’s governance bodies.

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 (%)

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

Optional comment

This data is not currently tracked at the group level but is available at the local level. We are working to consolidate this measurement in the health and safety action plan. It will be available at the end of 2022.

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

	Incident rate	Unknown	Choose to not disclose
Incident rate

Optional comment

The data is not currently tracked at the group level but is available at the local level. We are working to consolidate this measurement in the health and safety action plan. It will be available at the end of 2022.

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
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.
Forced labour
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.
Child labour
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.
Non-discrimination in respect of employment and occupation
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.
Occupational safety and health
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.
Working conditions (wages, working hours)
No adverse impacts have been identified during the reporting period regarding these topics, therefore, applying remedies is not applicable.

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.

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
Oceans
Forests / Biodiversity / Land Use
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

Optional comment

This policy is aligned with the UNGC sustainable development charts, as well as the ISO 14001 and 50001 standards. This policy is publicly available in our 2021 sustainability reporting p. 66-77 and has been developed thanks to internal expertise.

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

For all of Mantu's material environmental topics, we are engaging with stakeholders on two improvement axes: data accessibility and impact reduction. We are working with them to find the best solutions to our environmental challenges.

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

Optional comment

Following the PLAN - DO - CHECK - ACT cycle required by the ISO 14001 and ISO 50001 standards, Mantu has established different activities that allow us to measure our greenhouse gas emissions (including energy consumption), prioritizing the environmental and energy aspects we need to improve and designing an appropriate action plan. Activities are conducted according to an annual cycle model so that we can measure our progress and adapt our action plan to reduce our carbon emissions and energy consumption as much as possible. Here are the main steps of the process: - Measurement of environmental impact through annual carbon footprint assessment - Identification of the priority issues to be addressed (non-exhaustive): environmental impact analysis (all environmental aspects whose impacts are quoted as high or critical are prioritized), environmental risk analysis (all risks with high or critical priority levels are prioritized), stakeholder analysis (all stakeholder requirements with significant importance to Mantu are prioritized), legal watch (all current and future applicable legal requirements are prioritized), etc. - The design of an action plan to address each of these priority issues. In addition to this process, Mantu collaborates with partners to make significant progress within the company: for instance, Mantu collaborates with waste management companies to ensure best practices are in place. Regarding climate action, in 2021 Mantu participated in the United Nations' Climate Ambition Accelerator program which enabled its commitment to setting up a net-zero target which will be validated by the SBTi.

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

In the environmental action plan, each activity is associated with an environmental target to achieve. This target can be a percentage of CO2e reduction or another quantitative KPI depending on the issue. The Positive Impact team then manages an environmental dashboard (which covers energy issues) that includes targets such as the percentage of compliance with legal requirements, the rate of environmental aspects with decreased impact levels, the rate of activities rolled out in the action plan, etc. Continuous improvement of the management system is ensured through periodic audits conducted by our internal team, leading to an improvement action plan.

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	SBTi near term and net-zero targets validated by the end of 2022.
Energy & Resource Use	All offices we own in France relied on renewable energy by the end of 2021.
Water
Forests / Biodiversity / Land Use
Air Pollution	Rolling out a carpool solution in France by the end of 2022. Decrease of our carfleet in Switzerland in 2022.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

For all significant environmental impacts identified, an action plan has been set up for improvement and to decrease our impact on the 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

Optional comment

Generally, we set the environmental target at year +1, after the action deployment deadline, but it is adjusted depending on each action. Since some actions are rolled out at group level, their associated targets are defined in the same scope. A management review is organized every year, attended by the members of our top management (the highest governance body). Environmental issues with relevant KPIs are introduced and the outputs of this review lead to the design of improvement actions. Progress is also reported in our yearly sustainability report p. 66-77.

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

Optional comment

For each environmental impact which has been identified as significant, some improvement actions are designed to decrease our impact on the environment.

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Our reported Carbon Footprint in 2021 covers our 2020 activities. Scope 1: 353.44 tCO2e Scope 2: 102.97 tCO2e Scope 3: 11,990.85 tCO2e

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 (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Several Positive Business Impact services have been developed during the reporting period (a digital sobriety offer, the new brand RESP3CT, etc.). However, the revenue invested in the development of these projects has not been consolidated yet.

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

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

Optional comment

We have rolled out emergency procedures to enable efficient reactions to potentially urgent climate situations along with some Business Continuity Plans to ease the recovery from climate events.

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

Unknown

Optional comment

5% of the total electricity purchased comes from renewables.

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

No monitoring regarding the revenue generated from eco-friendly services has been made 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.

Here are some examples of concrete actions that have been taken during the reporting year: - We have set up some criteria for the purchase of key product categories: for instance, we buy computers that are TCO labeled (including Energy Star label) - We rolled out the Smart Working project, enabling employees to keep working from home which helps decrease our environmental impact from commuting. - We limited our business travel to that which was strictly necessary - We created the Environmental Office Management guide which helps Office Managers worldwide adopt best practices in our offices - We included hybrid and electric cars in our carfleet catalogues. In 2021, we also took part in the UN Climate Ambition Accelerator program which enabled Mantu to know more about the SBTi near term and net-zero targets standard for which we committed at the beginning of 2022. The biggest challenge we face is being able to start our transition towards the decarbonization of our activities and supply chain.

Anti-corruption

Commitment

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

2021

Optional comment

Staying focused on anti-corruption is important to Mantu. This is achieved by a combination of risk assessment and internal audits. Mantu continuously assesses corruption risks as part of Group Risk Assessment, in line with our strategy and target-setting processes.

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?

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

Optional comment

All our policies and recommendations on these topics are explained in our latest sustainability report (December 2021), in the chapter "MECHANISM FOR ADVICE AND CONCERNS ABOUT ETHICS" p. 36 - 41.

Prevention

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

Optional comment

Only a few of Mantu's people have been trained on anti-corruption policies or procedures as we do not have a general training provision on this topic. However, this training is planned for roll out in 2022 and to be fully effective in 2023.

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

This anti-corruption training has been provided to employees in relation with the banks and the management of treasury, as well as for procurement officers and category managers in order to control the risk of corruption with our suppliers. An awareness session is also provided to business managers on corruption and business ethics.

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

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Mantu continuously assesses corruption risks as part of Group Risk Assessment, in line with our strategy and target-setting processes. This topic is also monitored through internal audits.

Optional comment

The anti-corruption topic is monitored alongside other KPIs in Mantu's ethics dashboard.

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

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?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

0 incidents of corruption occurred in the reporting period.

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

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.

Anti-corruption is an important subject for Mantu. As our current procedures to manage anti-corruption principles are effective, we will continue doing so in the coming months. It means managing anti-corruption as a risk in Mantu's global risk assesment, as well as leading internal audits thoroughfully. An ethics commitee has been created in order to treat cases as well as to propose guidelines and best practices for all employees. A training module will be soon released for top management and for other critical functions in order to reinforce awareness and to build capacity to deal with corruption suspicions. The whistleblowing procedure released in 2021 will be also communicated more often to our employees.