2022 Communication on Progress

CEMEX

Published date

June 2, 2022

No. of questions

65

Supplemental files

CEO Statement

Signed
  • Governance

    Policies and Responsibilities

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

    Optional comment
    Within our annual report on form 20-F and Integrated Report, CEMEX, S.A.B. de C.V. (“CEMEX”) discloses information pertaining to the relevance of sustainable development to the company, the impact of our business and operations on both people and the environment, our commitment to zero tolerance for corruption, our sustainability targets, ESG reporting, and risks related to our business model. Our annual report on form 20-F is signed by our Chief Executive Officer, and our Integrated Report is endorsed by our Chief Executive Officer and Chairman of the Board of Directors by means of a letter to stakeholders contained in such report. Also, CEMEX has a Global Anti-Corruption Policy which contains a message from our Chief Executive Officer explicitly emphasizing a zero-tolerance stance toward corruption. Since 2014, CEMEX’s Board of Directors has a Sustainability Committee that addresses the aforementioned matters within its functions, which are following: (i) overseeing our sustainability and social responsibility policies, strategies, and programs; (ii) evaluating the effectiveness of sustainability programs and initiatives; ensuring sustainable development is embedded in our strategy; (iii) supporting our Board of Directors in fulfilling its responsibility to shareholders regarding our company’s sustainable growth; (iv) evaluating the ambition of our sustainability targets and the progress towards them; (v) providing assistance to our Chief Executive Officer and senior management team regarding our strategic direction on sustainability and social responsibilities model; (vi) identifying the main risks and opportunities concerning sustainability-related matters and overseeing global initiatives; and (vii) endorsing our model of sustainability, priorities, and key performance indicators. The Sustainability Committee particularly provides board-level oversight on our Climate Action and CO2 Management Strategy and other relevant matters like water management, biodiversity conservation, and strengthening of our communities. Our Chief Executive Officer is a member of this committee, and the committee is presided by an independent director. The committee issues a report presented at and subject to the approval of CEMEX’s Annual Shareholders Meeting. The Sustainability Committee’s report includes (i) the evaluation of CEMEX’s annual performance on its key sustainability indicators; (ii) the review of CEMEX’s sustainability risk agenda, as well as the reputational or financial impact and the probability of occurrence of such risks and an action plan aimed at mitigating such risks; (iii) its awareness of CEMEX’s Integrated Report and CEMEX’s Net-Zero Carbon Emissions by 2050; (iv) and other matters related to sustainability and ESG reporting. Also, CEMEX has published several position papers on diversity and inclusion, climate change, aggregates recycling, green building schemes, alternative fuels, environmental management and biodiversity, and on sustainable construction, which highlight our committal stance on the aforementioned matters. Please see our 2021 annual report on 20-F, our 2021 Integrated Report, both filed with the U.S. Securities and Exchange Commission (“SEC”), and our Global Anti-Corruption Policy at CEMEX’s corporate website for more information. 2021 annual report on form 20-F: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm Please also refer to our Global Anti-Corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 For more information on our position papers, please visit the following link: https://www.cemex.com/sustainability/esg-reporting-center/policies-positions

    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
    Each year, CEMEX publishes its annual report on form 20-F and Integrated Report, in which we restate our commitment with human rights, labor rights, environment and anti-corruption within our company, with our business partners, and the communities we impact. Please see our 2021 annual report on form 20-F and 2021 Integrated Report, both filed with the U.S. Securities and Exchange Commission, for additional information. Annual report on form 20-F: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm With regard to the environment, CEMEX has made is “Future in Action” program publicly known. This program includes CEMEX’s commitments in relation to environmental action in general and CO2 emissions reductions in particular. Por more information regarding Future in Action, please see: https://www.cemex.com/sustainability/future-in-action https://www.sec.gov/Archives/edgar/data/1076378/000119312521198708/d139595d6k.htmAlso, CEMEX has published several position papers on diversity and inclusion, climate change, aggregates recycling, green building schemes, alternative fuels, environmental management and biodiversity, and on sustainable construction, which highlight our committal stance on the aforementioned matters. For more information on our position papers, please visit the following link: https://www.cemex.com/sustainability/esg-reporting-center/policies-positions Furthermore, CEMEX has a Code of Ethics and Business Conduct and a Global Anti-Corruption Policy, applicable for all CEMEX subsidiaries and affiliates, current and newly hired employees, officers, directors, and third parties doing business with us. Our Code forbids personnel from promising or providing anything of value to government officials or our third parties to secure any undue advantage or unduly influence any decision. Please visit the following link for more information on our Code of Ethics and Business Conduct: https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf/78d61821-09fd-9622-e13d-465b6268f7bd?t=1557247414359 Our Global Anti-Corruption Policy includes a message from our Chief Executive Officer, underlining a zero-tolerance stance towards the payment of bribes or kickbacks of any kind, whether dealing with Government Officials or with the private sector. Please visit the following link for more information on our Global Anti-Corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 In addition, CEMEX has implemented a Human Rights Policy, expressing our active and continuous determination to meet our responsibility to respect and support internationally recognized human rights standards. Please visit the following link to view our Human Rights Policy: https://www.cemex.com/documents/20143/160187/cemex-policy-statement.pdf/805b051b-3a9e-ffe6-ac78-a7cda17c01e7?t=1524499706805

    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
    CEMEX has a comprehensive Code of Ethics and Business conduct that provides guidance on human rights, a safe and respectful workplace, environmental responsibility, and zero-tolerance on corruption. Our Code of Ethics and Business Conduct applies to all CEMEX businesses and geographies where CEMEX is present, and its guidelines apply to board members, personnel, third parties (including but not limited to customers, suppliers, and contractors), and other stakeholders. We also have a Code of Conduct When Doing Business with Us, with establishes a comprehensive guideline to be considered and followed by our business partners. Our Code provides guidance on supplier sustainability, our environmental policy, our health and safety policy, supplier relations and fair dealing, occupational health and safety and security, working conditions, freedom of association and non-retaliation, prohibition on forced labor and child labor, non-discrimination, environmental regulatory compliance, management of environmental impacts, zero tolerance policy towards any form of bribery or corruption, transparency and integrity, equality and fairness in supplier relations, among other matters. In addition, CEMEX has implemented a Human Rights Policy, expressing our active and continuous determination to meet our responsibility to respect and support internationally recognized human rights standards. For more information, please see our Code of Ethics and Business Conduct: https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf/78d61821-09fd-9622-e13d-465b6268f7bd?t=1557247414359 Also, please refer to our Code of Conduct when Doing Business with Us: https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/b67b560b-47e0-aebb-c325-041accaa5f09?t=1575567242798 Please visit the following link to view our Human Rights Policy: https://www.cemex.com/documents/20143/160187/cemex-policy-statement.pdf/805b051b-3a9e-ffe6-ac78-a7cda17c01e7?t=1524499706805

    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
    CEMEX has a comprehensive Code of Ethics and Business conduct that provides guidance on human rights, a safe and respectful workplace, environmental responsibility, and zero-tolerance on corruption. Our Code of Ethics and Business Conduct applies to all CEMEX businesses and geographies where CEMEX is present, and its guidelines apply to board members, personnel, third parties (including but not limited to customers, suppliers, and contractors), and other stakeholders. We also have a Code of Conduct When Doing Business with Us, with establishes a comprehensive guideline to be considered and followed by our business partners. Our Code provides guidance on supplier sustainability, our environmental policy, our health and safety policy, supplier relations and fair dealing, occupational health and safety and security, working conditions, freedom of association and non-retaliation, prohibition on forced labor and child labor, non-discrimination, environmental regulatory compliance, management of environmental impacts, zero tolerance policy towards any form of bribery or corruption, transparency and integrity, equality and fairness in supplier relations, among other matters. In addition, CEMEX has implemented a Human Rights Policy, expressing our active and continuous determination to meet our responsibility to respect and support internationally recognized human rights standards. For more information, please see our Code of Ethics and Business Conduct: https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf/78d61821-09fd-9622-e13d-465b6268f7bd?t=1557247414359 Also, please refer to our Code of Conduct when Doing Business with Us: https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/b67b560b-47e0-aebb-c325-041accaa5f09?t=1575567242798 Please visit the following link to view our Human Rights Policy: https://www.cemex.com/documents/20143/160187/cemex-policy-statement.pdf/805b051b-3a9e-ffe6-ac78-a7cda17c01e7?t=1524499706805

    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
    Since 2014, CEMEX’s Board of Directors has a Sustainability Committee, which has the following functions: (i) overseeing our sustainability and social responsibility policies, strategies, and programs; (ii) evaluating the effectiveness of sustainability programs and initiatives; ensuring sustainable development is embedded in our strategy; (iii) supporting our Board of Directors in fulfilling its responsibility to shareholders regarding our company’s sustainable growth; (iv) evaluating the ambition of our sustainability targets and the progress towards them; (v) providing assistance to our Chief Executive Officer and senior management team regarding our strategic direction on sustainability and social responsibilities model; (vi) identifying the main risks and opportunities concerning sustainability-related matters and overseeing global initiatives; and (vii) endorsing our model of sustainability, priorities, and key performance indicators. The Sustainability Committee particularly provides board-level oversight on our Climate Action and CO2 Management Strategy and other relevant matters like water management, biodiversity conservation, and strengthening of our communities. Our Chief Executive Officer is a member of this committee, and the committee is presided by an independent director. The committee issues a report presented at and subject to the approval of CEMEX’s Annual Shareholders Meeting. The Sustainability Committee’s report includes (i) the evaluation of CEMEX’s annual performance on its key sustainability indicators; (ii) the review of CEMEX’s sustainability risk agenda, as well as the reputational or financial impact and the probability of occurrence of such risks and an action plan aimed at mitigating such risks; (iii) its awareness of CEMEX’s Integrated Report and CEMEX’s Net-Zero Carbon Emissions by 2050; (iv) and other matters related to sustainability and ESG reporting. The Sustainability Committee also oversees and discusses our Sustainability Risk & Opportunity Agenda, which addresses our social impact strategy, compliance with our Code of Ethics and Business Conduct, our Climate Action Strategy, our workforce experience and diversity and inclusion efforts, among other matters. Our Audit Committee is responsible for overseeing CEMEX’s performance on business ethics and compliance as well as human rights; evaluating our internal controls and procedures and identifying deficiencies; following up with corrective and preventive measures in response to any non-compliance with our operation and accounting guidelines and policies; evaluating the performance of our external auditors and analyzing the reports, opinions, and other information issued by them; describing and valuing non-audit services performed by our external auditors; reviewing our financial statements and determining if their approval should be recommended to the Board of Directors; informing the Board of Directors of the state of the company’s internal controls, internal audit and accounting systems, including any breaches detected; supporting the Board of Directors in producing different reports submitted to shareholders; assessing the effects of any modifications to the accounting policies approved during any fiscal year; overseeing measures adopted as a result of any observations made by our shareholders, directors, executive officers, employees or any third parties with respect to accounting, internal controls, and internal and external audits, as well as any complaints regarding management irregularities; supervising complaints raised by employees, third parties and other stakeholders to report ethical, corruption, and/or compliance matters utilizing confidential methods and other whistleblowing mechanisms; ensuring compliance by the Chief Executive Officer with the resolutions adopted by the shareholders and Board of Directors; and analyzing any risks identified by our company’s independent auditors, accounting, internal control, and process assessment areas. While our Audit Committee evaluates internal controls and procedures and oversees remediation, our Global Ethics & Compliance Committee defines our global ethics compliance strategy. Our ETHOS Group oversees and manages the Global Compliance program, and our Local ETHOS Committees implement local ethics strategies and investigate complaints. Together, such committees and group continually update the company’s internal policies by reviewing and monitoring changes and updates to laws, regulations, and best practices to apply any relevant practices at CEMEX. Some of our main efforts include defining compliance policies and identifying robust mechanisms in relation to due diligence and third-party management, detection of conflicts of interest and reporting of related person transactions, prevention of corruption, money laundering, insider trading and violations of sanctions programs, and reporting any conflict mineral transactions. Also, our Corporate Practices and Finance Committee oversees policies related to anti-corruption, reviewing related party transactions and any conflicts of interest, reviewing policies regarding the use of corporate assets, reviewing unusual or material transactions, among other responsibilities contained in CEMEX’s bylaws and those described in CEMEX’s 2021 20-F and Integrated Report. Pursuant to Mexican Securities Law and CEMEX’s bylaws all members of our Corporate Practices and Finance Committee, including its President, are independent directors. Also, The Corporate Legal Director of Compliance oversees matters related to human rights, labor rights, and anti-corruption. Furthermore, CEMEX’s Governance System allows our Board of Directors and their Committees to receive input, cooperation and feedback by means of comment, suggestions, reports, grievances and complaints from employees, business partners and society in general. Such comments are considered, and our Board of Directors and its Committees oversee compliance with company mandates, guidelines, policies, and procedures to fulfill corporate strategy and address laws and regulations, best practices and guidelines, stakeholder demands, society’s values and ideals and global and local trends, risks and circumstances. Please see our latest annual report on form 20-F, our latest Integrated Report, both filed with the U.S. Securities and Exchange Commission (“SEC”), and our Global Anti-Corruption Policy at CEMEX’s corporate website for more information. 2021 20-F: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm CEMEX Bylaws: https://www.cemex.com/documents/20143/160115/2022-cemex-by-laws.pdf/15dc6726-41fe-e710-59bf-522019418201?t=1648593708679 CEMEX Global Anti-corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708

    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
    CEMEX’s risk management model is a combination of ‘bottom-up’ and ‘top-down’ systems, which connects top management insights with the rest of the organization to comprehensively manage risks and opportunities. The risk management process is implemented in a standardized way by our Enterprise Risk Management representatives which are present at the global, regional, and country levels. The risk and opportunity agendas are developed twice a year and updated on an ongoing basis. Risk agendas are designed to include all types of risks, trends, emerging concerns, and opportunities that could impact CEMEX’s strategic and operational objectives in the short (zero to one year), medium (one to two years), and long term (more than two years). Our Executive Committee, to whom the risk agendas are delivered, discusses the enterprise risk and opportunity agenda at least once a year. These sessions emphasize discussion on risks and definition of treatment strategies. Additionally, the relevant information on our risk management system is presented to the Board of Directors. Through the Corporate Practices and Finance Committee, the Board of Directors, responsible for risk oversight, discusses the enterprise risk and opportunity agenda at least once a year. Additionally, the Board of Directors is responsible for reviewing the effectiveness of our risk management system enforced by our Executive Committee. Through its Sustainability Committee, the Board of Directors oversees and discusses the Sustainability Risk & Opportunity Agenda. Other risk management areas and processes within our company complement our risk and opportunity management model, among them: Process Assessment, Internal Control, Legal, Financial Risk Management, ETHOS Compliance, and Sustainability. For more information, please see our latest (2021) Integrated Report, which was filed with the U.S. Securities and Exchange Commission: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm

    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
    CEMEX reviews most (less than 100%) relevant business relationships including those outside the supply chain. Our Enterprise Risk Management Team is responsible for analyzing local and global compliance risks and, performing risk oversight, including risk identification, monitoring assessment, reporting and mitigation. Additionally, our Enterprise Risk Management Team performs the identification and evaluation of risks according to our internal Risk Agenda Guidelines. For more information, please see our latest (2021) Integrated Report, which was filed with the U.S. Securities and Exchange Commission: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm

    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
    Every third party we issue a payment to undergoes a due diligence process, which includes the review of certain corporate documentation such third party provides, as well as a statement or certification of compliance where the third party certifies they will abide by the applicable CEMEX policies (or their own policies) and applicable laws, particularly concerning corruption, AML, sanctions programs, and similar matters. Any risks identified in the process are reviewed and mitigated, if possible, before entering a commercial relationship with such third parties. As per our Global Anti-Corruption Policy: "XII. Third Parties ... Prior to entering into a business relationship, Third Parties must provide a signed copy of CEMEX’s Third Party Compliance Declaration, mandatory legal documentation and complete a due diligence process according to the guidelines set out in the Global Policy for Third Parties available in CEMEX’s official website and CEMEX’s Policy Center at Shift. ... Due diligence must be performed and preserved during the process of selecting the third party to prove that the third party, its shareholders, directors and officers and/or representatives being used for interactions with CEMEX: is a bona fide and legitimate entity; is qualified to perform the services for which it will be retained; does not have any impermissible relationship with a political party or Government Official; and maintains business and ethical standards consistent with those of CEMEX. As per our Global Anti Corruption Policy, "XII. Third Parties. [...] Due diligence should be tailored by the Compliance Area to the risks associated with the situation. Due diligence may include external research and confirmation of the third party’s qualifications and an in-person meeting or interview with the principals of the third party. [...] ... Even when dealing with Third Parties with whom CEMEX already has an approved relationship, CEMEX personnel must be alert for suspicious circumstances, i.e. “red flags”. Due diligence must be enhanced if there are red flags of potential corruption, which include but are not limited to the following: The country where the transaction is taking place has a significant perception of corruption; [...]" As per CEMEX's Global Policy for Third Parties, "CEMEX operates under a zero-tolerance policy towards bribery and corruption. All Third Parties and CEMEX Personnel are expected to comply with anti-bribery and anti-corruption laws in effect in countries where CEMEX conducts business." Our 2021 Integrated Report: “Our aim of always managing our supplier relationships with integrity, honesty, respect, and with adherence to applicable laws and regulations, promotes a culture of open communication that strengthens our relationship. Acknowledging our Code of Ethics and Business Conduct, Code of Conduct when Doing Business with Us, Global Anti-Corruption Policy, and Global Anti-Money Laundering Policy is part of the Third-Party Compliance Declaration required for the new supplier registration process. ... It is important that third parties with whom we do business are aligned with our core set of principles. As such, CEMEX places a high priority on verifying that third parties are reputable and able to meet the guidelines we have developed to seek alignment to our core values. We have instituted various policies to guide the selection and transactions with our third parties. We have guidelines to review third parties with whom we do business and also have a due diligence and third-party management framework in place. As part of our third-party management standards, we also have internal policies which define specific procedures for the review and authorization of donations, sponsorships, and contributions. … A due diligence process is embedded in CEMEX’s existing approach to risk management with a special focus on potential human rights risks. It is integrated into our company’s regularly running formal processes, including: […] Global Compliance Program: This function conducts legal compliance projects, including screenings of suppliers to identify any human rights concerns relating to a supplier, [...] Suppliers Assessment: We partner with specialized independent firms to assess most of our suppliers across the globe. As part of their scope, these assessments include respect and promotion of human rights in their workforce and supply chain. Contractors Assessment: This program is designed to certify that those strategic contractors with which we engage are equally committed to respect human rights aligned with the health and safety of their employees, clients, and the communities in which they operate. To support CEMEX in this important program, we rely on leading global technology and applications development firms. CEMEX reviews internally results of relevant assessment topics to ensure consistency with our business risks and strategy. CEMEX’s strategic business functions carried out a deep-dive exercise to map the “impact on CEMEX”. These functions include Sustainability, Health and Safety, Human Resources, Social Impact, Corporate Communications and Public Affairs, Corporate Finance, Energy, Enterprise Risk Management, Planning, Procurement, Supply Chain, Logistics, Legal, Investor Relations, Customer Experience, Commercial, and Urbanization Solutions. Our Contractor Health and Safety Verification Program helps us verify that certain contractors comply with health and safety processes and keep safe while working with us. Implemented by our Global Procurement team through a specialized third-party organization that utilizes a data-driven system, the assessment checks for regulation compliance, liability policies, risk premiums, manuals and procedures, and applicable training and accreditations, among other requirements. Additionally, CEMEX’s ETHOS Group oversees and manages our Global Compliance Program. ... Our supplier Code of Conduct When Doing Business With Us, takes into account issues like environmental and biodiversity engagement, ensuring basic labor conditions and promoting Health and Safety as a high priority, Strengthening Human Rights, and Enhancing Diversity and Equality.” As per our supplier Code of Conduct When Doing Business With Us: “Suppliers identified as having a high environmental impact shall take action and demonstrate proof of continuous improvement towards implementing and applying a recognized environmental management system. … a) Occupational health and safety: […] Suppliers identified as being moderate to high risk for occupational health and safety violations shall take action and bring proof of continuous improvement towards implementing and applying a recognized occupational health and safety management system.” For more information, please see our latest Integrated Annual Report, filed with the U.S. Securities and Exchange Commission, our Global Anti-Corruption Policy, our Global Policy for Third Parties and our Code of Conduct When Doing Business With Us: 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm Code of Conduct When Doing Business with Us: https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/ Global Anti-Corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 Global Policy for Third Parties https://www.cemex.com/documents/20143/160082/2020-global-third-parties-policy.pdf/4a7ae000-99b2-c431-be82-9f527f9fd507?t=1591024783552

    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

    Optional comment
    Every third party we issue a payment to undergoes a due diligence process, which includes the review of certain corporate documentation such third party provides, as well as a statement or certification of compliance where the third party certifies they will abide by the applicable CEMEX policies (or their own policies) and applicable laws, particularly concerning corruption, AML, sanctions programs, and similar matters. Any risks identified in the process are reviewed and mitigated, if possible, before entering a commercial relationship with such third parties. Additionally, the Corporate Legal Compliance department has the faculty to request additional information as part of our due diligence process, on a discretionary basis. As per our Global Anti-Corruption Policy: "XII. Third Parties ... Prior to entering into a business relationship, Third Parties must provide a signed copy of CEMEX’s Third Party Compliance Declaration, mandatory legal documentation and complete a due diligence process according to the guidelines set out in the Global Policy for Third Parties available in CEMEX’s official website and CEMEX’s Policy Center at Shift. ... Due diligence must be performed and preserved during the process of selecting the third party to prove that the third party, its shareholders, directors and officers and/or representatives being used for interactions with CEMEX: is a bona fide and legitimate entity; is qualified to perform the services for which it will be retained; does not have any impermissible relationship with a political party or Government Official; and maintains business and ethical standards consistent with those of CEMEX. As per our Global Anti Corruption Policy, "XII. Third Parties. [...] Due diligence should be tailored by the Compliance Area to the risks associated with the situation. Due diligence may include external research and confirmation of the third party’s qualifications and an in-person meeting or interview with the principals of the third party. [...] ... Even when dealing with Third Parties with whom CEMEX already has an approved relationship, CEMEX personnel must be alert for suspicious circumstances, i.e. “red flags”. Due diligence must be enhanced if there are red flags of potential corruption, which include but are not limited to the following: The country where the transaction is taking place has a significant perception of corruption; [...]" As per CEMEX's Global Policy for Third Parties, "CEMEX operates under a zero-tolerance policy towards bribery and corruption. All Third Parties and CEMEX Personnel are expected to comply with anti-bribery and anti-corruption laws in effect in countries where CEMEX conducts business." Our 2021 Integrated Report: “Our aim of always managing our supplier relationships with integrity, honesty, respect, and with adherence to applicable laws and regulations, promotes a culture of open communication that strengthens our relationship. Acknowledging our Code of Ethics and Business Conduct, Code of Conduct when Doing Business with Us, Global Anti-Corruption Policy, and Global Anti-Money Laundering Policy is part of the Third-Party Compliance Declaration required for the new supplier registration process. ... It is important that third parties with whom we do business are aligned with our core set of principles. As such, CEMEX places a high priority on verifying that third parties are reputable and able to meet the guidelines we have developed to seek alignment to our core values. We have instituted various policies to guide the selection and transactions with our third parties. We have guidelines to review third parties with whom we do business and also have a due diligence and third-party management framework in place. As part of our third-party management standards, we also have internal policies which define specific procedures for the review and authorization of donations, sponsorships, and contributions. … A due diligence process is embedded in CEMEX’s existing approach to risk management with a special focus on potential human rights risks. It is integrated into our company’s regularly running formal processes, including: […] Global Compliance Program: This function conducts legal compliance projects, including screenings of suppliers to identify any human rights concerns relating to a supplier, [...] Suppliers Assessment: We partner with specialized independent firms to assess most of our suppliers across the globe. As part of their scope, these assessments include respect and promotion of human rights in their workforce and supply chain. Contractors Assessment: This program is designed to certify that those strategic contractors with which we engage are equally committed to respect human rights aligned with the health and safety of their employees, clients, and the communities in which they operate. To support CEMEX in this important program, we rely on leading global technology and applications development firms. CEMEX reviews internally results of relevant assessment topics to ensure consistency with our business risks and strategy. CEMEX’s strategic business functions carried out a deep-dive exercise to map the “impact on CEMEX”. These functions include Sustainability, Health and Safety, Human Resources, Social Impact, Corporate Communications and Public Affairs, Corporate Finance, Energy, Enterprise Risk Management, Planning, Procurement, Supply Chain, Logistics, Legal, Investor Relations, Customer Experience, Commercial, and Urbanization Solutions. Our Contractor Health and Safety Verification Program helps us verify that certain contractors comply with health and safety processes and keep safe while working with us. Implemented by our Global Procurement team through a specialized third-party organization that utilizes a data-driven system, the assessment checks for regulation compliance, liability policies, risk premiums, manuals and procedures, and applicable training and accreditations, among other requirements. Additionally, CEMEX’s ETHOS Group oversees and manages our Global Compliance Program. ... Our supplier Code of Conduct When Doing Business With Us, takes into account issues like environmental and biodiversity engagement, ensuring basic labor conditions and promoting Health and Safety as a high priority, Strengthening Human Rights, and Enhancing Diversity and Equality.” As per our supplier Code of Conduct When Doing Business With Us: “Suppliers identified as having a high environmental impact shall take action and demonstrate proof of continuous improvement towards implementing and applying a recognized environmental management system. … a) Occupational health and safety: […] Suppliers identified as being moderate to high risk for occupational health and safety violations shall take action and bring proof of continuous improvement towards implementing and applying a recognized occupational health and safety management system.” For more information, please see our latest Integrated Annual Report, filed with the U.S. Securities and Exchange Commission, our Global Anti-Corruption Policy, our Global Policy for Third Parties and our Code of Conduct When Doing Business With Us: 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm Code of Conduct When Doing Business with Us: https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/ Global Anti-Corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 Global Policy for Third Parties https://www.cemex.com/documents/20143/160082/2020-global-third-parties-policy.pdf/4a7ae000-99b2-c431-be82-9f527f9fd507?t=1591024783552

    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
    ETHOSline is our institutional reporting mechanism, accessible through our company website, mobile devices or through our intranet, that is open and free for anyone to use. This secure, confidential, and independent platform is available 24 hours a day, seven days a week, to both employees and the general public to report any allegations of misconduct anonymously or confidentially. To secure confidentiality, ETHOSline runs on a platform provided by NAVEX Global, a third-party expert on ethics and compliance reporting. Certain reports go directly to the company’s internal audit area, which directly reports to CEMEX’s Board of Directors’ Audit Committee (all of the committee’s members are independent board members). Additionally, CEMEX has both global and local ethics committees: “Global and Local Ethics Committees: Composed of representatives from different functions in each of the countries in which we operate, these dedicated taskforces encourage awareness and enforcement of our Code of Ethics and Business Conduct. All of them receive, investigate, and collaborate to resolve reported ethics breaches, including those related to human rights.” On the other hand, our external independent auditor has the faculty of reporting to the authorities adverse findings found in our processes. CEMEX, S.A.B. de C.V. is a public listed company in the U.S. and Mexico, and we control four publicly listed companies: CEMEX Latam Holdings S.A. (listed in the Colombian Stock Exchange), CEMEX Holdings Philippines, Inc. (listed in the Philippine Stock Exchange, Trinidad Cement Limited (listed in the Trinidad and Tobago Stock Exchange) and Caribbean Cement Company Limited (listed in the Jamaica Stock Exchange). Our external auditor oversees all public entities within the CEMEX Group. Please see our 2021 20-F report, our 2021 Integrated Annual Report, both filed with the U.S. Securities and Exchange Commission (“SEC”), and our Global Anti-Corruption Policy at CEMEX’s corporate website for more information. 2021 20-F: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm

    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
    As shown on our 2021 Integrated Report (pg. 108), “at CEMEX, we believe it is essential to have a trusted, secure channel in which our employees, our stakeholders, or any third party can raise a concern or suspicion about ethics or compliance violations via the online portal, email, or the phone line. CEMEX encourages anyone to come forward and, accordingly maintains a strict no retaliation policy against anyone who reports in good faith. Each report, complaint, or inquiry received through our ETHOSline is duly processed and disseminated to the corresponding areas for its review and follow up. If considered necessary, an investigation will be carried out, in a reasonable timeframe, to obtain objective information to be able to take an appropriate decision. If a report is found to be substantiated, the corresponding disciplinary measures will be taken. To achieve impartial, credible, fair and consistent results, our ETHOS governing bodies must abide by our ETHOS manuals which provide directives and guidelines on how to properly manage reports, complaints and inquiries received through ETHOSline, with the purpose of guaranteeing an effective end-to-end process.” Certain reports go directly to the company’s internal audit area, which directly reports to CEMEX’s Board of Directors’ Audit Committee (all of the committee’s members are independent board members). Additionally, our Code of Ethics is available for employees in all our institutional languages (English, Spanish, French, German, Croatian, Polish, Arabic, Hebrew and Czech) on our intranet called “Spark”.

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Our Human Rights Policy expresses our determination to meet our responsibility to respect and support internationally recognized human rights standards. Its implementation is focused on establishing the right controls throughout our existing governance processes and tools. Additionally, human rights continue to be included in both our Code of Ethics and Business Conduct and our Code of Conduct When Doing Business with Us. We expect our employees, suppliers, contractors, and other business partners to consistently apply all of our policies and procedures applicable to them wherever we operate and we seek to engage with third parties who are able to meet our principles in this regard. CEMEX’s Human Rights Compliance Assessment enabled us to discuss and define action plans by country in order to proactively anticipate any potential human rights impacts. Nonetheless, we continue to work very closely with our operations to build their capabilities and maintain a robust mitigation and remediation model that enables us to prioritize and address human rights issues, while working to maximize our positive impacts. As per our Human Rights Policy: “We have instituted a process of on-going due diligence, which comprises the assessment of CEMEX’s actual and potential human rights impacts in our operations, and other processes such as risk assessments, legal certifications, environmental and social impact assessments.” With this process CEMEX seeks to identify, mitigate and prevent among other risks any adverse human rights impacts. In addition, CEMEX has implemented processes to enable the remediation of any adverse impacts that CEMEX has identified, caused or contributed to. Additionally, “[a]s part of our shared responsibility to climate change mitigation and adaptation, and our continued determination to respect and support internationally recognized human rights standards, we are fully committed to carrying out our business activities in an environmentally responsible and sustainable manner and to minimizing the environmental implications of our activities. This commitment is embodied in our Environmental, Water, and Biodiversity policies.” Our global environmental policies seek to avoid, prevent, mitigate, and remediate impacts related to our activities. A monthly Environmental and Social Incidents Report details all relevant events in the period. It results in a direct message from our CEO requesting our operations to address and remediate identified situations. Some of the measures taken to mitigate adverse impacts consist on: • Complying with ESG laws and regulations • Engaging with communities and key stakeholders for increased communication and risk mitigation • Actively engaging with the United Nations through agencies such as UNGC and UNDRR • Securing ETHOS line to report alleged ethics, compliance, or governance violations • Implementing Sustainability Committees at corporate and regional levels • CEMEX ESG initiatives: Future in Action, Social Impact Strategy, Environmental Strategy, Climate Action Strategy, position papers, policies, information disclosure, communication campaigns On the other hand, CEMEX’s Health and Safety Management System defines the parameters to operate in accordance regulations regarding health and safety, and is our main tool to establish performance requirements and goals for our operations by helping us assess potential risks and plan the measures needed to mitigate them in a coordinate manner. The Health and Safety Management System empowers our leaders to implement a successful health and safety strategy across our operations and guides us on how to adequately allocate resources to training programs for our employees. Furthermore, our line managers utilize our HSMS on an ongoing basis to make an annual deep review of further improvement opportunities and to formulate their annual Health and Safety Improvement Plans. CEMEX also has a Global Anti-Corruption Policy which contains a message from our Chief Executive Officer explicitly emphasizing a zero-tolerance stance toward corruption. Our position on corruption is also included on our Code of Ethics and Code of Conduct When Doing Business with Us, in frequent training sessions and in communication campaigns. Our ETHOSline (which is our institutional hotline) is also available for any external party 24/7 and CEMEX reviews and investigates any reports or inquiries received through ETHOSline in accordance with internal guidelines and protocols, and if applicable, applies the corresponding remediation measures. As per page 117 of our 2021 Integrated Report, “As part of the campaigns that enhance our Code of Ethics and Business Conduct, we encourage people to speak up - without fear of retribution - about any concerns on ethics and human rights. We aim to strengthen the credibility of our reporting channels and continually assess and review how best to improve our approach to protecting human rights. Our Human Rights Policy reflects our support and respect for the protection of internationally proclaimed human rights principles, as expressed in the International Bill of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. In addition, it recognizes employees, communities, contractors, and suppliers as main areas of impact and reaffirms our commitment to the promotion of and respect for human rights throughout our worldwide operations, local communities, and supply chain.” For more information, please refer to our 2021 Integrated Report, filed with the U.S. Securities and Exchange Commission, our Global Anti-Corruption Policy, and our Code of Conduct When Doing Business With Us: 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm Code of Conduct When Doing Business with Us: https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/ Global Anti-Corruption Policy: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 Human Rights Policy: https://www.cemex.com/documents/20143/160187/cemex-policy-statement.pdf/805b051b-3a9e-ffe6-ac78-a7cda17c01e7?t=1524499706805 Code of Ethics and Business Conduct: https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf/78d61821-09fd-9622-e13d-465b6268f7bd?t=1557247414359

    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
    Our company analyses both internal and external developments and implements mitigation measures and amends and updates policies as necessary. As per page 109 of our 2021 Integrated Report, “CEMEX has set up an Enterprise Risk Management (ERM) framework to maximize the creation of sustainable value for our stakeholders. This proactive and structured approach, established across all our operations, allows CEMEX to prevent and/ or minimize the impact of potential risks and capitalize on opportunities. […] The risk management process is implemented in a standardized way by the ERM representatives which are present at the global, regional, and country levels. The risk and opportunity agendas are developed twice a year and updated on an ongoing basis. […] Our Executive Committee, to whom the risk agendas are delivered, discusses the enterprise risk and opportunity agenda at least once a year. These sessions emphasize discussion on risks and definition of treatment strategies. Additionally, the relevant information on our risk management system is presented to the Board of Directors. Through the Corporate Practices and Finance Committee, the Board of Directors, responsible for risk oversight, discusses the enterprise risk and opportunity agenda at least once a year. Additionally, the Board of Directors is responsible for reviewing the effectiveness of our risk management system enforced by our Executive Committee. Through its Sustainability Committee, the Board of Directors oversees and discusses the Sustainability Risk & Opportunity Agenda. Other risk management areas and processes within our company complement our risk and opportunity management model, among them: Process Assessment, Internal Control, Legal, Financial Risk Management, ETHOS Compliance, and Sustainability. […] Our risk management process adheres to international best practices from the Risk Management Society (RIMS) and Business Continuity Institute (BCI). It is compliant with ISO 31000:2018-Risk management standards and ISO 22300:2018-Business continuity management systems.” Particularly regarding risk mitigation, as per page 110 of our 2021 Integrated Report, “[m]itigation strategies with a specific action plan for each risk are implemented. ERM representatives follow up on the risk treatment strategy and, in some cases, act as coordinators of ad-hoc task forces focused to mitigate specific risks.” Regarding environmental mitigation actions, as per page 112 of our 2021 Integrated Report, we “comply with ESG laws and regulations, engage with communities and key stakeholders for increased communication and risk mitigation, actively engage with the United Nations through agencies such as UNGC and UNDRR, maintain our secure ETHOSline to report alleged ethics, compliance, or governance violations, implement Sustainability Committees at corporate and regional levels, and have the following CEMEX ESG initiatives: Future in Action, Social Impact Strategy, Environmental Strategy, Climate Action Strategy, position papers, policies, information disclosure, communication campaigns.” Additionally, please refer to page 113 for a detailed description of our mitigation actions relating to climate risks. In relation to anti-corruption mitigation actions, as per page 114 of our 2021 Integrated Report, we “comply with local, state, and federal laws and regulations, continuously enhance CEMEX’s Compliance program: new and updated policies and continued training, enhance our Code of Ethics and Business Conduct, which addresses anti-bribery, health responsibility, confidentiality, conflicts of interest, financial controls, and preservation of assets, ensure that our employees acknowledge and understand our Code of Ethics and Business Conduct, improve internal controls through continuous internal audits and internal controls in place Incorporate compliance-related initiatives in the management of third parties, and identify and assess potential new laws and regulations.” Regarding human rights, particularly health and safety mitigation actions, as per page 115 of our 2021 Integrated Report we “ensure nothing comes before the health and safety of our employees, contractors, and the community where we operate, implement Health and Safety Protocols in all our operations (Behaviors that Save Lives, Pandemic Endurance & Rapid Response Teams), adhere to high health and safety standards, and monitor, prepare, and comply with health and safety recommendations.” Additionally, as per page 117, “As a signatory and active participant of the UN Global Compact, we reaffirm our support of its 10 principles on Human Rights, Labor, Environment, and Anti-Corruption. With a strong commitment to these principles, we annually submit an Advanced Communication of Progress. As part of the mitigation actions proposed as follow-up to our Human Rights Compliance Assessment, we updated our Code of Ethics and Business Conduct in 2018 and released our Code of Conduct when doing Business with Us in 2019; and, through them, we continue to promote and protect human rights. We aim to ensure humane treatment in our facilities and together with CEMEX’s Global Workplace Diversity and Inclusion Policy, we strive to prevent discrimination of women, people with disabilities, ethnic minorities, and other vulnerable groups. CEMEX reinforces awareness and commitment to human rights with internal campaigns and through social impact initiatives dedicated to improving quality of life, creating social cohesion, and promoting diversity and equality through company-sponsored programs.”

    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
    For the year ended December 31, 2021, the aggregate amount of compensation we paid, or our subsidiaries paid, to all members of CEMEX, S.A.B. de C.V.’s management was $50 million, which amount includes the salaries paid to the members of our board of directors, including its Chairman, and the salaries of our senior management, including of our Chief Executive Officer. Of the $50 million that we paid to members of CEMEX, S.A.B. de C.V.’s management, $26 million was paid as base compensation and cash-based performance bonuses, including pension and post-employment benefits, and $24 million corresponds to stock-based long-term compensation. Variable Compensation Plan (“VCP”) The terms of the VCP available to our senior management are based on cash value added (“CVA”) and consider performance metrics that include a combination of the employee’s business unit, regional and consolidated global results as compared to our specific annual target goals, including certain health and safety, which relate to human rights and labor law, and sustainability-related factors. In addition, the evaluation process considers each member of senior management’s Individual Performance Assessment, along with his or her supervisor’s input. The competitiveness of our executive compensation structure, as well as the mix between base and variable, as well as short- and long-term compensation, is reviewed every two years. This analysis measures competitiveness versus similar size firms in both the US and European markets. The most recent review was performed in October 2021 by WTW (formerly Willis, Towers, Watson), a firm specialized in multinational risk management, insurance brokerage and company advisory. CEMEX, S.A.B. de C.V.’s board of directors is compensated in a fixed manner based on participation in board meetings. The compensation of the board of directors is approved each year at CEMEX, S.A.B. de C.V.’s general ordinary shareholders’ meeting. In 2021, the amount approved by our shareholders was $22,400 per each board meeting attended and $5,400 per each committee meeting attended, and the actual amount paid for attendance to these meetings was approximately $1.8 million. The Chairman of CEMEX, S.A.B. de C.V.’s board of directors, however, is compensated in a similar manner as CEMEX, S.A.B. de C.V.’s senior management, including through the long-term performance plan based on CEMEX’s total shareholder return versus peer groups. The base salary of the Chairman of CEMEX, S.A.B. de C.V.’s board of directors is 27% fixed and the remaining 73% is variable compensation. The total compensation (including fixed and variable compensation) of the Chairman of CEMEX, S.A.B. de C.V.’s board of directors and the Chief Executive Officer is approved every year by the Corporate Practices and Finance Committee of the board of directors, which is integrated by three (3) independent directors. The Corporate Practices and Finance Committee of the board of directors also reviews and approves the annual variable compensation of all members of senior management, key value position participants, and corporate and regional executives who are entitled to this benefit. On May 10, 2022, CEMEX announced that its Executive Variable Compensation program, which includes progress on its ambitious carbon reduction goals as a variable, will be expanded to cover more than 4,500 executives. This initiative is part of the company's Future in Action program, which focuses on reducing the carbon footprint of CEMEX's operations and products to become a net-zero CO2 company by 2050. Beginning 2022, the CO2 emissions component will have an impact that will range from -10% to +10% in the total cash payout of the Annual Executive Variable Compensation. Regarding the prevention of corruption, our compensation plans for executives include a provision for involuntary termination related to executive misconduct. If an executive commits any felony or illegality, such employee would be subject to termination for misconduct: “All unvested CEMEX CPOs covered by this Award, the LTIP or in general any stock compensation plan offered by CEMEX and/or any affiliate of the CEMEX Group or in which you participate as part of your employment with CEMEX and/or any affiliate of the CEMEX Group, will be forfeited and revoked, with full effects and without the need of a judicial resolution, in case of your misconduct. You understand, acknowledge, accept and agree that the Committee, after consultation with CEMEX, has, for purposes of this Award, full and final authority to determine misconduct cases based on CEMEX and/or CEMEX Group policies, guidelines, mandates and also considering applicable laws.” Please see our 2021 20-F, which was filed with the U.S. Securities and Exchange Commission for more information: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm Please refer to our press release on our expansion the executive compensation link to climate action for more information: https://www.cemex.com/-/cemex-expands-executive-compensation-link-to-climate-action

    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 (#)

    12

    Male (%)

    91.6

    Female (%)

    9

    Non-binary (%)

    Under 30 years old (%)

    0

    30-50 years old (%)

    0

    Above 50 years old (%)

    100

    From minority or vulnerable groups (%)

    Executive (%)

    25

    Independent (%)

    75
    Optional comment
    In accordance with the definition of “vulnerable group” of the GRI 405 Standard (Diversity and Equal Opportunity), CEMEX’s Board of Directors does include vulnerable groups: elderly persons (100%) and women (9%). The calculation of our independent directors is made under principles of Mexican law and as set forth in article 26 of the Mexican Securities Market Law. Generally, under the Mexican Securities Market Law, a director is not independent if such director is an employee or officer of the company or its subsidiaries; an individual that has significant influence over the company or its subsidiaries; a shareholder that is part of a group that controls the company; or, if there exist certain relationships between a company and a director, entities with which the director is associated or family members of the director. The citizenships of the 12 members of CEMEX’s Board of Directors comprise of Mexicans (9), British (1), Brazilian (1), and Spanish (1). CEMEX is a Mexican company incorporated under Mexican law. Please see our 2021 20-F, which was filed with the U.S. Securities and Exchange Commission for more information: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm

    13. Do you produce sustainability reporting according to:

    Global Cement and Concrete
    Optional comment
    Please see our 2021 annual report filed on form 20-F as well as our 2021 Integrated Report, both filed with the U.S. Securities and Exchange Commission (“SEC”) for more information. 2021 20-F: https://www.sec.gov/Archives/edgar/data/0001076378/000119312522133730/d305933d20f.htm 2021 Integrated Report: https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm Also, please see our 2021 Annual Report filed with the Mexican Stock Exchange: https://www.bmv.com.mx/docs-pub/infoanua/infoanua_1185597_2021_1.pdf

    Data Assurance

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

    Please see page
    Optional comment
    cemex.com/IntegratedReport2021
  • 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?

    Environmental footprint, community impacts

    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.

    CEMEX has a Corporate Human Rights Policy that uses as a foundation UN's guiding principles (Protect, Respect and Remedy). We proactively work to ensure our own practices, as well as those of our suppliers, partners, and others within the value chain, respect the rights of individuals and the communities in which we operate. Our Code of Ethics establishes our commitment to human rights. CEMEX encourages its suppliers to adhere to the standards of its Conduct when Doing Business with Us. Our Sustainability Model has key objectives to address social global challenges, including: Poverty, Income Inequality, Aging Population, and Unemployment. We have management systems to integrate de human rights principles. At CEMEX, each of our business units has an Enterprise Risk Management (ERM) process in place. ERM aims to support top management across the organization in the decision-making process, reducing the impact of adverse events and capitalizing on opportunities. Among other topics, ERM monitors and assesses any type of potential risk including human rights violations. We provide training on business ethics and human rights and launch communication campaigns to raise awareness. Employees and the public in general are encouraged to report any potential ethics violation to the Human Resources Department, the Local Ethics Committee or through our ETHOSline. The ETHOSline is offered as a safe and confidential tool for employees and the public in general to ask questions and report potential violations, including human rights.
  • 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

    2018

    Forced labour

    2018

    Child labour

    2018

    Non-discrimination in respect of employment and occupation

    2018

    Occupational safety and health

    2020

    Working conditions (wages, working hours)

    2019
    Optional comment
    Please see our Human Rights Policy here https://www.cemex.com/documents/20143/160187/cemex-policy-statement.pdf t Also please see our Code of Conduct that is ratified by our CEO and Director of the Board https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf As well as our Code of Counduct when doig business with us https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf/ these are applicable for the first 4 (freedom of association, child labour, forced labour and non-discrimination). See our H&S Policy here https://www.cemex.com/documents/20143/160187/CemexHealthAndSafetyPolicy.pdf Our Flexible Work Schedule Policy is not public but you can learn out it in our Integrated Report www.cemex.com/IntegratedReport2021

    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
    I have tried may times to use the check boxes and they keep disappearing! Please consider for freedom of association, forced labour, child labour and working conditions all options up to and including "Applied to the company’s supply chain and/or other business relationships?" For Non-discrimination, Occupational safety and health all options up-to and including "Developed involving labour rights expertise from inside and outside the company"

    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)

    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 (%)

    40

    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 (%)

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    9

    Non-executive board

    8.4

    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 (%)

    97

    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

    0.5
    Optional comment
    Our Employee Lost Time Injury Frequency Rate (LTI FR) (per million hours worked) for 2021 was 0.5 and 0.2 for contractors. See page 219 of our 2021 Integrated Report www.cemex.com/IntegratedReport2021

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    77.6
    Optional comment
    Employee Lost Time Injury Severity Rate (LTI SR) (lost days per million hours worked) was 77.6 See page 219 of our 2021 Integrated Report www.cemex.com/IntegratedReport2021

    Response and Reporting

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

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

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

    Forced labour

    To our knowledge there were no adverse impact associated

    Child labour

    To our knowledge there were no adverse impact associated

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    At CEMEX, no one is forced to perform hazardous tasks against their will or tasks that are detrimental to their health or well-being. We strive for our operations in every country comply with the local laws and we take measures to prevent workers from falling into debt bondage through company loans. All our employees are free to leave the company anytime and we do not offer any benefit used as a leverage to force labor. At CEMEX we are strongly committed to protecting and respecting the rules regarding child labor in every country we operate. Our company policy is to only hire people who are 18 or older. Our selection and hiring process requires the presentation of government-issued identification, as well as a rigorous investigation of the person’s information. This process also extends to our contracted labor suppliers. The Ethics Committee received 41 reports related to discrimination. 4 of the discrimination-related reports received remains in process.13 of the reports we were able to confirm that discrimination occurred, and 24 other accusations were false. In all reports received, measures are implemented and monitored by local ethics committees comprising high level executives from the local business unit. Management of risk is a continuous process and the cornerstone of the CEMEX H&S Management System. We constantly identify hazard and assess the risks associated with our activities. We take action to manage the risk and prevent or reduce the impact of potential incidents. Processes are established and promoted to identify hazards associated with CEMEX activities and to assess risks, control the hazard and manage the risks to acceptable levels. Risk assessments and risk management/control measures are documented and resulting actions implemented through local procedures. See more on pages 243-244 www.cemex.com/IntegratedReport2021
  • 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

    2016

    Water

    2020

    Oceans

    CEMEX's operations do not have a direct impact over oceans, please refer to Water policy

    Forests / Biodiversity / Land Use

    2016

    Air Pollution

    2016

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

    2016

    Energy & Resource Use

    2016
    Optional comment
    Water Policy - https://www.cemex.com/documents/20143/160082/2020-cemex-water-policy.pdf Environmental Policy (includes Climate Action, Air Pollution, Waste, Energy & Resource Use) https://www.cemex.com/documents/20143/11674932/CemexEnvironmentalPolicy.pdf Biodiversity Policy https://www.cemex.com/documents/20143/11674932/CemexBiodiversityPolicy.pdf

    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
    I have tried many times and the checkmarks keep disappearing on me! Please consider for Climate Action, Water, Biodiversity and Energy & Resource Use all options up to and including "Developed involving environmental expertise from inside and outside the company?"; for Waste and Aire Pollution please consider all options up-to and including "Applied to the company's supply chain and/or other business relationships?"These are included in the Code of conduct when doing business with us https://www.cemex.com/documents/20143/49059650/supplier-code-of-conduct_EN_2019.pdf

    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

    CEMEX's operations do not have a direct impact over oceans, please refer to Water

    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

    CEMEX's operations do not have a direct impact over oceans, please refer to Water

    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

    CEMEX's operations do not have a direct impact over oceans, please refer to Water actions

    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

    -Reduction of net CO2 emissions per ton of cementitious product vs. 1990 > 40% by 2030. Target aligned with SBTi Well Below 2ºC Scenario -Clinker Factor (cementitious) 71% by 2030 -Alternative fuels rate 50% by 2030 -Clean electricity consumption in cement 55% by 2030

    Energy & Resource Use

    -Clean electricity consumption in cement 55% by 2030

    Water

    -Implementation of Water Action Plans in sites located in water-scarce areas 100% by 2030 -Reduction in specific freshwater withdrawal in Cementitious -20% by 2030 -Reduction in specific freshwater withdrawal in Aggregates -15% by 2030 -Reduction in specific freshwater withdrawal in Concrete -10% by 2030

    Forests / Biodiversity / Land Use

    -Quarry rehabilitation plans, Biodiversity Action Plans, and third-party certification 100% by 2030 -Third-party certification on critical sites 100% by 2030

    Air Pollution

    -Reduction of dust emissions per ton of clinker vs. 2005 95% by 2030 -Reduction of NOX emissions per ton of clinker vs. 2005 47% by 2030 -Reduction of SOX emissions per ton of clinker vs. 2005 67% by 2030

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

    Total waste-derived sources managed 25 million tons annually by 2030

    Oceans

    Optional comment
    See page 15 ww.cemex.com/IntegratedReport2021

    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

    Optional comment
    Please note that we have iniciativas en efforts in all of the topics above but to our knowledge there were no stakeholders impacted.

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    38400000

    Scope 2 Emissions

    Emissions (tCO2e)

    3700000

    Scope 3 Emissions

    Emissions (tCO2e)

    10700000
    Optional comment
    Please note that we were not able to provide data for emissions (tCO2e) and select an option (full, none, partial). For S1, S2 the answer is full and for Scope 3 it is partial. Also please note that this is note tCO2e but tCO2, other GHG are non-material

    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 (%)

    0.24
    Optional comment
    R&D activities comprise part of the daily routine of the aforementioned departments and divisions. Therefore, the costs associated with such activities are expensed as incurred. In 2019, 2020 and 2021, total combined expenses of these departments recognized within administrative expenses were $38 million, $31 million and $35 million, respectively. See page

    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

    12.7
    Optional comment
    https://www.cemex.com/documents/20143/11025391/2021-investor-cdp.pdf/ See our 2021 CDP response C8.2a please note that this figure corresponds to 2020. 2021 figure is not yet available as the 2022 CDP Climate Change questionnaire has note been published

    Technology

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

    Percent of total revenue (%)

    56
    Annual sales of cement and concrete products with outstanding sustainable attributes (%) please see page 15 www.cemex.com/IntegratedReport2021

    Sector-specific Questions

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

    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

    57200

    Groundwater:

    29200

    Surface water:

    14100

    Rainwater:

    600

    Wastewater:

    600

    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

    41600

    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/$):

    Please consider instead 255 l/ton of cement, 238 l/m3 of ready-mix, 132 l/ton of aggregates
    Optional comment
    See page 222 www.cemex.com/IntegratedReport2021

    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

    40

    Hectares

    2766

    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)

    1260

    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

    250

    Other ecosystem restoration

    3500

    Reforestation

    Natural regeneration

    350

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Sector-specific: Waste

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

    Waste Generated (t)

    405000

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

    Hazardous Waste Ratio (%)

    0.6
    Optional comment
    2.4 thousand tons of hazardous waste was sent for disposal

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

    Single-use plastics (tonnes)

    This is not applicable for our industry. Our products are distributed either buy bulk or in paper sacks.

    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.

    We have established 2030 goals for consumption of waste-derived sources from other industries; reduction in CO₂; power consumption from clean energy in cement; dust, NOx and SOx emissions; quarry rehabilitation, Biodiversity Action Plans and third-party certification; and implementation of Water Management Plans in sites located on water-scarce areas. We reaffirmed our commitment with our long-term 2050 ambition to deliver net-zero CO2 concrete globally. 556% of our annual sales from cement and ready-mix concrete are derived from products with outstanding sustainable attribute. CEMEX has developed a user-friendly online learning tool to help top and middle management gain a solid understanding of sustainability. The Leadership in Sustainability Training Program covers key issues impacting executives’ lives and the sector in which CEMEX operates, as well as the implications for how we manage and run our operations and provide value to customers. Furthermore, this year we developed a Sustainability Learning Pathway, that includes a collection of videos, articles, and resources for employees at all levels to grasp the key concepts of the environmental aspect of sustainability as one of our strategic priorities at CEMEX. A sustainability module has been included in the on-boarding process of new employees. The CEMEX Sustainability Committee assists the board in overseeing strategies designed to manage environmental, social, economic, and governance related risks. It also reviews the effectiveness of policies and procedures relating to health and safety, employment practices, stakeholder relationships, environment, human rights, resources preservation, authorities’ involvement, and sustainable development.
  • Anti-corruption

    Commitment

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

    2021
    Optional comment
    Regarding our anti-corruption efforts, our Global Anti-Corruption Policy (https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708) was drafted by the Legal Compliance Department with support from external counsel, includes various controls which were developed by Internal Control, and these internal controls are regularly audited by our Process Assessment Department. The CEMEX Corporate Legal Compliance Department carries out yearly reviews of the Global Compliance Program to assess and identify priorities and high-risk topics; this comprises a review of compliance-related initiatives related to anti-corruption. As per our 2021 Integrated Report, “As part of the ETHOS organization’s responsibilities, enhanced monitoring is given to the most sensitive countries concerning corruption risks pertinent to the countries in which we operate. During 2021, our main standalone operations in terms of revenues were: the USA (medium risk), Mexico (high risk), France (low risk), UK (low risk), Israel (medium risk), Germany (low risk), Spain (medium risk), Poland (medium risk), the Philippines (high risk), Colombia (high risk), the Dominican Republic (high risk), and Panama (high risk). We also operate in other countries of which some are low risk, medium risk (such as Jamaica, Trinidad and Tobago, among others), and high risk (such as Haiti, Guatemala, Nicaragua, among others). This risk classification is based on Transparency International’s 2021 Corruption Perception Index.” On another note, our Global Anti-Corruption Policy was last updated on November 2020 and the CEMEX Corporate Legal Compliance Department is planning to update it in 2023.

    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
    Please refer to page 106 of our 2021 Integrated Report (https://www.sec.gov/Archives/edgar/data/1076378/000119312522084273/d100277dex1.htm ), as reported in question AC.1 above, which provides that “Our Global Anti-Corruption Policy emphasizes CEMEX´s zero tolerance stance on bribery and corruption. It covers a myriad of topics including conflicts of interest, donations, gifts and hospitalities, government interaction, and red flags when dealing with third parties. Regarding government interaction, our policy prescribes best practices, specific rules and tools for the management of relationships with both government entities and officials. Some examples include: a specific category in our accounting system to identify payments to, and revenues from, government entities, permitting their identification as separate line items; our Government Interaction Tool, which tracks, documents, and provides a user-friendly system for authorizing interactions between government officials and CEMEX employees, before they take place, whenever there will be an expense made on CEMEX´s behalf; and internal controls that are particularly focused on overseeing compliance with our government interaction guidelines and rules. Additionally, we have a Corporate Hospitalities to Government Officials Policy which, specifically regulates entertaining, gifts, travel expenses and other hospitalities provided to government officials.” You may consult our Global Anti-Corruption Policy here: https://www.cemex.com/documents/20143/160082/global-anti-corruption-policy.pdf/3993d595-ff91-5eab-643f-c63cb1cf5ef1?t=1607120278708 Additionally, “[d]uring 2021, CEMEX published a new policy on Conflicts of Interest, which reaffirms our position that all members of the CEMEX Group (including our CEO, Executive Committee and Board of Directors) shall always act in accordance with CEMEX’s best interests, and directly prohibits the CEMEX Group from entering into transactions and/or negotiations where a conflict of interest may exist. We also launched a new global reporting process and digital platform where all employees are required to report any situation that could represent an actual, potential or apparent conflict of interest. All reports are evaluated and authorized, if applicable, by a multidisciplinary team as well as the employee’s supervisor. In line with the new conflict of interest process, we also carry out a related party transaction review which seeks to comply with applicable regulations and market practices to report and review any transactions with related persons and is applicable to all CEMEX operations worldwide.” Additionally, please refer to page 107 of our 2021 Integrated Report which demonstrates that during 2021 a total of 2,773 employees participated in the training session called “ETHOS Do the Right Thing” which covered practical scenarios and “do´s and don´ts” in relation to conflicts of interest, employee relations, harassment and fraud. Our Code of Ethics and Business Conduct also includes a section on “Responsible Decision-Making” in relation to conflicts of interest, gifts and hospitalities, use of company assets, and political activity as well as a specific section on “Anti-corruption”. Please refer to pages 20-21 and 24-31 of our Code of Ethics and Business Conduct available here: https://www.cemex.com/documents/20143/160061/Code-of-ethics.pdf/78d61821-09fd-9622-e13d-465b6268f7bd?t=1557247414359 We also have internal policies which define specific procedures for the review and authorization of donations, sponsorships, and contributions in which various areas of the Compliance Organization have certain roles and responsibilities.

    Prevention

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

    Optional comment
    Please refer to our 2021 Integrated Report: “Our employees are continuously reminded of CEMEX´s business ethics and compliance principles in multiple ways including training. We schedule regular compliance training sessions to promote our corporate values, policies, and procedures; inform and remind our employees about unacceptable behavior; and reinforce our institutional reporting mechanisms”. As per our Global Anti-Corruption Policy, “CEMEX personnel are expected to comply with this Policy, participate in anti-corruption training, and communicate the principles established by this Policy to their colleagues and business partners. In addition, CEMEX’s relevant employees shall be required to provide anti-corruption compliance certification every two years.” From a total of around 40,000 employees, each year different groups of employees are selected to participate in anti-corruption training sessions. As such, the areas and employees are rotated every year with the intention of covering the most employees as possible. Therefore, every year different employees are selected to participate and eventually all employees will have participated in anti-corruption training sessions. On the other hand, with regards to training for contractors and direct suppliers, we are not checking those boxes seeing as due to the pandemic, we faced significant obstacles and risks. However, we intend to begin providing particular training sessions to certain contractors and direct suppliers at some point during 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

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

    Please refer to page 108 of our 2021 Integrated Report: “Internal Legal Audits. Our internal legal audits serve as another means to evaluate and verify the knowledge and compliance of CEMEX´s relevant policies by certain key employees. The ultimate purpose of this exercise if to identify areas of opportunity to continuously improve and enhance our compliance policies and procedures. Even taking into account the restrictions imposed by the COVID-19 pandemic, a total of 104 internal legal audits were conducted during 2021, both in person and remotely, in 22 countries with a particular focus on anti-corruption, anti-money laundering, antitrust, conflicts of interest, and international trade compliance matters”.
    Optional comment
    Review issues on an ad-hoc basis: In addition to our ETHOSline, we have diverse official reporting channels such as our Legal, Human Resources, Process Assessment and Internal Control Departments, our Local ETHOS Committees, and our Audit Committees. In case a report is received directly by one of these, the issue will be received on an ad-hoc basis. Furthermore, our Process Assessment Department presents reports after they conduct internal audits of controls and compliance with policies and any deficiencies are reviewed and remediated, if necessary. Internal Controls: Our Global Anti-Corruption Policy has specific internal controls to monitor compliance, such as: (1) handling of complaints received through any of the official channels set out in CEMEX’s Code of Ethics, (2) Government Interaction Authorization tool, (3) Follow-up and update of the Global Anti-Corruption Policy, (4) Payments to Government Entities Report, (5) Gifts and Hospitalities to other Third Parties (non-Government Officials) recipient or beneficiary control. Please refer to our Global Anti-Corruption Policy for more details. While not all of these are automated, some are such as our hotline which is called ETHOSLine and certain alerts that Global Enterprise Services has set up to detect irregularities (in contrast to the ordinary course of business) which are displayed in dashboards. External Independent Monitoring: Seeing as we are a publicly-listed company, our external statutory auditor, KPMG, audits our Global Compliance Program, including certain components and aspects relation to anti-corruption

    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
    NA

    Confirmed during the current year, and related to this year

    0
    NA
    Optional comment
    Please refer to page 222 of our 2021 Integrated Report, which demonstrates that 0 incidents related to fraud, kickbacks and other corruption incidents with government officials were reported. Additionally, as per page 236 our 2021 Integrated Report, “[t]here were no incidents that met the Foreign Corrupt Practices Act and UK Bribery Act standard for corruption, nor were any legal cases regarding corrupt practices by either our organization or our employees concluded during the reporting year. We continuously monitor our employee´s behavior and compel our employees to report any corruption acts through ETHOSline” or any other reporting channel.

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    Optional comment
    While no corruption incidents were reported or suspected within the reporting period, please find below an overview of the measures we take when we receive a report (in relation to any topic) through ETHOSline. Please refer to page 108 of our 2021 Integrated Report: “Each report, complaint, or inquiry received through our ETHOSline is duly processed and disseminated to the corresponding areas for its review and follow up. If considered necessary, an investigation will be carried out, in a reasonable timeframe, to obtain objective information to be able to take an appropriate decision. If a report is found to be substantiated, the corresponding disciplinary measures will be taken. To achieve impartial, credible, fair and consistent results, our ETHOS governing bodies must abide by our ETHOS manuals which provide directives and guidelines on how to properly manage reports, complaints and inquiries received through ETHOSline, with the purpose of guaranteeing an effective end-to-end process. During 2021, a total of 626 cases were reported through our official channels, of which 64% were received through ETHOSline, and approximately 35% through local committees and 1% through our Global Ethics and Compliance Committee. Out of those 626 cases, 565 were closed, of which 284 were substantiated. As a result, 105 employees were dismissed, 59 employees received remedial training, and 124 were subject to disciplinary action. Additionally, 94 internal processes and/or policies were reviewed and updated as a result of certain investigations. We also received 126 inquiries through our official channels.”

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

    Optional comment
    Seeing as we are a signatory member of the United Nations Global Compact since 2004, we have been analyzing, as of the beginning of 2022, the possibility of applying and engaging in Collective Action against corruption, to determine how this would fit, complement and play out with our current initiatives.

    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.

    At CEMEX, we are committed to conducting business in full compliance with all applicable laws, rules, and regulations in accordance with high ethical standards. We strive to do business with transparency and integrity and ensure that all transactions comply with applicable anti-corruption and anti-bribery laws. This includes a zero-tolerance stance towards the payment of bribes or kickbacks of any kind, whether when dealing with Government Officials or with the private sector. Particularly regarding permissible interactions with government officials, we have conducted training sessions regarding how to use our Government Interaction Tool and send constant reminders, via Compliance News (further described below) and other communication channels, to our employees. Our anti-corruption compliance program is characterized by consistent communication campaigns, engaging training hours, constant benchmarking, thorough due diligence, appropriate grievance mechanisms, and continuous enhancement. Since last year, we’ve been working on updating our Global Anti-Corruption Policy to incorporate best practices through benchmarking and considering our needs and those of our employees, facilitating their understanding and compliance with the policy. To procure our policy incorporates best practices and the highest standards, we have created a Global Daily News Tracker in which we check for updates from both authorities and experts on a daily basis, regularly participating in webinars and related events. We plan on launching our updated policy during 4Q22, accompanied by a robust communication campaign to procure proper dissemination and understanding of the updated policy and its related controls and procedures. Our employees are continuously reminded of CEMEX´s business ethics and compliance principles in multiple ways, including training. We schedule regular compliance training sessions to promote our corporate values, policies, and procedures; inform and remind our employees about unacceptable behavior; and reinforce our institutional reporting mechanisms. COVID-19 represented a challenge for us in the sense that it prevented traditional in-person training; however, we were able to redesign our training methods to leverage digital tools. In 2021, we created our Global Anti-Corruption Pathway to assist all employees in maintaining high ethical standards and acting with transparency in our day-to-day dealings by including practical day-to-day examples. The Pathway was uploaded to CEMEX University, an institutional platform dedicated to the continuous development of our employees. As part of our compliance awareness efforts, including on anti-corruption-related matters, we publish our “Compliance News” every month. “Compliance News” is a newsletter that includes summaries on relevant compliance updates such as recent developments from regulatory agencies, enforcement actions against other companies and the corresponding lessons learned, updates to applicable laws and regulations, as well as relevant internal updates relating to our policies and processes, and employee obligations. Specifically, over 90 antitrust and anti-corruption campaigns were launched to all our employees last year as per our 2021 Integrated Report. Last year, due to challenges and obstacles presented by the Covid-19 pandemic, the legal audits that are carried out by the Compliance and Legal Departments on an annual basis were mainly virtual as the majority of our employees were still working from home. In order to ensure we were properly prepared for carrying out legal audits virtually, we received a training session by an external law firm, which specializes in audits and internal investigations, which provided us with best practices and practical recommendations on how to deal with possible scenarios during the legal audits. As we are gradually returning to the office, at least on a hybrid model, we plan to make our plan for legal audits more robust by taking advantage of conducting the audits in person.