2022 Communication on Progress

Aksa Akrilik Kimya Sanayi A.S.

Published date

June 15, 2022

No. of questions

60

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
    2021 Integrated Annual Report https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf

    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

    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

    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
    The Sustainability Committee is chaired by our General Manager, with the participation of the senior management of the Company, relevant department members and the Sustainability Manager, and operates under the Corporate Governance Committee. The committee is responsible for determining policies, targets and actions according to risks and opportunities, managing sustainability issues, and ensuring the integration of sustainability into business processes. Committee members coordinate the sustainability activities in their area of responsibility in line with the decisions taken at the meeting. Committee decisions are reported to the Board of Directors quarterly.

    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
    The Sustainability Committee is chaired by our General Manager, with the participation of the senior management of the Company, relevant department members and the Sustainability Manager, and operates under the Corporate Governance Committee. The committee is responsible for determining policies, targets and actions according to risks and opportunities, managing sustainability issues, and ensuring the integration of sustainability into business processes. Committee members coordinate the sustainability activities in their area of responsibility in line with the decisions taken at the meeting. Committee decisions are reported to the Board of Directors quarterly.

    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

    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

    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?

    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)

    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
    No complaint from employees or stakeholders on above topics in the reporting year

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

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

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    9

    Male (%)

    56

    Female (%)

    44

    Non-binary (%)

    Under 30 years old (%)

    30-50 years old (%)

    11

    Above 50 years old (%)

    89

    From minority or vulnerable groups (%)

    Executive (%)

    67

    Independent (%)

    33

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

    ISO 14064 & ISO 14046 Verifications are available on

  • Human Rights

    Materiality / Saliency

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

    Commitment

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

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

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    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.

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/D64B602800C5423691882588FF1DC740.pdf#page=46

  • Labour

    Commitment

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

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

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

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    2021

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

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

    Employees, or their representatives as Representative Board were notified of decisions impacting them. All employees are members of Representative Board and there is no any syndicate

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    In the reporting year , we did not face with any negative feedback or notification from the stakeholders on these topics https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=52 https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=50

    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

    Employees, or their representatives as Representative Board were notified of decisions impacting them. All employees are members of Representative Board and there is no any syndicate

    Forced labour

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=52

    Child labour

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=52

    Non-discrimination in respect of employment and occupation

    We participated in two workshops held in line with the UNGC Target Gender Equality Program in 2021 and exchanged ideas about actions to be taken with the participating companies. We have evaluated the actions that we can implement. Our Human Resources and Corporate Development Director took part as a speaker at the "Rais-ing Motivation for a Better World" event, which was held globally within the scope of the UNGC Target Gender Equality.

    Occupational safety and health

    Working conditions (wages, working hours)

    We provide our employees with the opportunity to work remotely 2 days a week
    Optional comment
    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=43

    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 (%)

    0

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

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

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

    0

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    20

    Non-executive board

    50

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

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    100

    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

    0.00000201537

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0.00228408816

    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

    Not faced with that kind of problem in the reporting year

    Forced labour

    Not faced with that kind of problem in the reporting year

    Child labour

    Not faced with that kind of problem in the reporting year

    Non-discrimination in respect of employment and occupation

    Not received negative feedback or notification on this topic in the reporting year

    Occupational safety and health

    Not received negative feedback or notification on this topic in the reporting year

    Working conditions (wages, working hours)

    Not received negative feedback or notification on this topic in the reporting year

    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.

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=46

  • 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

    2020

    Water

    2020

    Oceans

    2020

    Forests / Biodiversity / Land Use

    2020

    Air Pollution

    2020

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

    2020

    Energy & Resource Use

    2020

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    Water

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    Oceans

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    Forests / Biodiversity / Land Use

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    Air Pollution

    We did not get any negative feedback from none of the stakeholders in the reporting period.

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

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    Energy & Resource Use

    We did not get any negative feedback from none of the stakeholders in the reporting period.

    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

    We specify the absolute target to reduce the emissions .

    Water

    We specify the absolute target to reduce the emissions

    Oceans

    Forests / Biodiversity / Land Use

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=44

    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

    Our Company has held the Green Port Certificate since 2016. In this context, our sea water analysis results, which we have quarterly samples from four different points, meet the limit values of the Water Pollution Control Regulation, Table 4.

    Forests / Biodiversity / Land Use

    After the study in 2020 by a 3rd party , it is decided 3 year monitoring process under the headings specied.

    Air Pollution

    Annual reportings required by regulations

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

    Energy & Resource Use

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

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    1225899

    Scope 2 Emissions

    Emissions (tCO2e)

    5033

    Scope 3 Emissions

    Emissions (tCO2e)

    1121352

    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 (%)

    3

    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

    0

    Technology

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

    Percent of total revenue (%)

    3
    The ratio of revenues from newly developed products to turnover is 3%

    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

    132428.3

    Groundwater:

    0

    Surface water:

    132066.8

    Rainwater:

    361.498

    Wastewater:

    130963.4

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

    2.5

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    1464.9

    Groundwater:

    0

    Surface water:

    132066.8

    Rainwater:

    361.498

    Wastewater:

    130963.4

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

    11
    Optional comment
    Surface water is the total amount of dam water (3238.8 megaliter) and sea water (128,828,000 megaliter) withdrawal. Total consumption is calculated by subracting discharges from withdrawals. It includes rainwater vaporization , fresh water evaporation and RO-process water evaporation categories.

    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/$):

    4.99
    Optional comment
    4.99 m3 / ton for the reporting year

    Sector-specific: Air pollution

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

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    728.6

    SOx

    541.8

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    4.6728e-9

    Persistent organic pollutants (POP)

    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)

    17472
    Optional comment
    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/D64B602800C5423691882588FF1DC740.pdf#page=177

    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 (%)

    16.8
    Optional comment
    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/D64B602800C5423691882588FF1DC740.pdf#page=177

    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)

    4.1
    Optional comment
    Due to the pandemic , we used single-use plastics for food services

    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.

    In this reporting period , we set the targets for emissions , wastes , water consumption . https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEA7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf

  • Anti-corruption

    Commitment

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

    2021

    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
    https://www.aksa.com/en/human-resources/ethic-management/ethic-management/i-401

    Prevention

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

    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?

    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
    0

    Confirmed during the current year, and related to this year

    0
    0

    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
    There were no notifications received on ethical issues in 2021

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

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

    https://www.aksa.com/ca/docs/CE3E6CEF4AFB473D9E100AEAD7CD27/60C03801C6A344DAA6CB875C69D2D4A4.pdf#page=99