Report - COP Prototype

2022 Communication on Progress

Inci Holding

Published date

June 20, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

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

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

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

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

- As İnci Holding, we have a sustainability strategy in line with our vision, "We grow our corporate value across generations by investing globally in future businesses", which is officially published on our official website. - Our policy documents that we share with all our employees cover the following topics; Environmental Policy, Economic Performance Policy, Product and Service Policy, Training and Development Policies, Decent Business Environment and Corporate Culture Policy, Corporate Social Responsibility and Ethics Policy, Sustainability Policy, Stakeholders' Policy. - Within the scope of zero tolerance for corruption; it is strictly forbidden to offer bribes or kickbacks and any misconduct constitutes a legal offense at İnci Holding. In case of being exposed to such offer or request, the situation is immediately reported to the relevant manager or the Ethics Committee. It is strictly prohibited to ask to borrow money from customers, suppliers, our competitors and other third parties. Bribery and any unethical business practice are prohibited. All business and business activities and transactions would be fully and accurately recorded in our company's accounting system and in accordance with local laws; and would always be open to inspection. - İnci Holding 2021 Sustainability Report is being prepared for publication in 2022. Sustainability topics are among our group based company goals. In our sustainability perspective; being fully aware of the interactions between economic, social and environmental dimensions, we are committed to sustainable development, taking into account all the effects of the decisions taken within the scope of economic, social and environmental. In our sustainability perspective; we have designed our economic and social sustainability roadmap to serve our vision; For new generations 'Investing in institutionalization', 'Investing in responsible production and consumption', 'Investing in people and society' 'Investing in innovation'. We aim to be the leader in researching and developing ways of doing business, technologies and products that will support sustainability. - İnci Holding Corporate Risk Management System ensures that important risks are defined, control processes are evaluated, the right risks are taken in the right amount, these risks are managed with appropriate processes, and action plans are developed to reduce the risks to acceptable levels. For this reason, all our group companies are responsible for identifying and monitoring the critical risks within their own structure, taking decisions regarding the management of these risks and reporting them to the Board of Directors periodically. In this direction, within the scope of Enterprise Risk Management practices, each process owner, together with a senior manager, takes the necessary measures to reduce these risks to an acceptable level and contributes to corporate sustainability.

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

İnci Holding's 1st Sustainability Report (2021) has been prepared with the aim of transparently sharing the group's activities in the field of sustainability, important opportunity and risk areas, and targets.

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

As we continue to shape the future with all our employees, suppliers and customers in ethical management, we adopt compliance with ethical principles and values as our priority. We care about placing ethical behaviors on an institutional basis and reflecting this understanding in an integrated way into our strategic plans.

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

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

İnci Holding Ethics Commitee: Within the scope of İnci Holding's Ethical Principles, Commitee is responsible for analyzing notifications, ensuring the adoption of the ethical system, overseeing its effective operation and making long-term plans. It consists of the Chairman, Board Members, Human Resources Director, Internal Audit Manager, Legal Counsel and Ethics Manager. The extended ethics committee consists of the Ethics Committee and company ethics representatives. The Ethics Committee prepares an annual report every 6 months to be submitted to the Board of Directors. Notification management is provided through an independent ethical telephone line of İnci Holding. İnci Holding Sustainability Committee: The purpose of the committee is to coordinate sustainability issues, to guide companies on strategic topics, to reveal synergy areas, to be a facilitator, information, dissemination and network provider for companies in studies on the subject, and to provide benefit-oriented value to internal and external stakeholders. Under the chairmanship of the Holding CEO, the Committee consists of Sustainability Sponsor Board Member, Human Resources and Corporate Communications Director, Strategic Planning and Business Development Director, Technology Director, Finance Director, Internal Audit Manager and General Secretary.

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

İnci Holding Risk and Audit Committee; It works to monitor and control the risks that İnci Group companies may be exposed to, to monitor internal audit and independent audit activities, and to increase the effectiveness of internal control and financial reporting processes.

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

At İnci Holding, the effective management of risks is the responsibility of all group companies and all employees, and accordingly, it is an important performance measure. All group companies are responsible for identifying and monitoring the critical risks within their own structure, taking decisions regarding the management of these risks and periodically reporting them to the relevant authorities. In this direction, within the scope of Corporate Risk Management practices, each process owner, together with a senior manager, defines their risks and the necessary measures to reduce these risks to an acceptable level.

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

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

Yes, we have a formal process

Optional comment

Our ethical code/principles are understandable and accessible to all stakeholders. Case studies are conducted with company managers and ethical representatives and improvement actions are implemented. Awareness-raising activities are carried out for employees through internal and external communications. Within the scope of ethical communication activities, supplier information is provided. In addition, experience sharing activities are carried out by acting with relevant non-governmental organizations in order to spread the ethical management approach.

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

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?

Optional comment

In order to ensure the efficiency of the functioning of the İnci Holding Board of Directors in line with the determined focus areas, it works on determining the appropriate member composition, determining the member candidates suitable for this composition, selecting the members, measuring and evaluating the strategic performance of the Board of Directors and its members. According to the results of the Board Performance Evaluation, which is applied as a 360-degree evaluation by an independent organization every year, the development areas for the BOD operation are determined and an action plan is prepared.

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 (#)	8
Male (%)	50
Female (%)	50
Non-binary (%)
Under 30 years old (%)
30-50 years old (%)	37.5
Above 50 years old (%)	67.5
From minority or vulnerable groups (%)
Executive (%)	12.5
Independent (%)	12.5

Data Assurance

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

No assurance for any metrics

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

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

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

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Inclusion, diversity and equality in society are among our core values. In this regard, we are launching applications that will set an example for both the sector and the society we live in. We also contribute to raising social awareness with trainings and projects in our group. We support the economic empowerment of women in the business world and society with the actions we take. The culture of equality between men and women, which is the basis of our approaches, is reflected in all our processes. We work with the principle of "giving importance to equality of opportunity and respecting differences and ethical values" in all Human Resources processes and practices, from recruitment to remuneration, from training to promotion. We support gender equality within the scope of our diversity and inclusion culture with our awareness activities. We take care to take part in efforts aimed at empowering and empowering women in all sectors and at all levels. One of the most important global initiatives of the private sector, Women's Empowerment Principles (WEPs) was signed by İnci Holding in 2016. We have a human resources approach that support Equal Pay for Equal Work.

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

With the Gender Equality Workshop we held in 2021, we worked on gender equality in communication and its transformation into corporate behavior, increasing women's employment and improving working environments, and aligning with how we can plan and spread our future steps to be taken together with our group companies. We started working together to set a common goal on a group basis.

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Selected employees who are work with HR Team and Diversity & Inclusion Project Members. C Level also attended.

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Targets are set first for HR, Business Development, Corporate Communications and related all parts.

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

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

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.

Together with our group companies, we carry out various social responsibility projects for women to take part in business life. In this context, we continue our awareness communications by supporting internship programs, where we offer employment opportunities only to female employees, and global solidarity movements that address gender inequality. Beside this, we would like to increase women employment in our young talent programme. Increasing the number of women at all levels, from the Board of Directors to our field teams, is among our important goals.

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
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
last review in 2021 (Every year)
Working conditions (wages, working hours)
last review in 2021 (Every year)

Optional comment

All employees' rights are guaranteed by employment contracts therefore we guaranteed working conditions for all employess.

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

The HR Comitee and the BOD evaluates annual benchmarkings.

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

Optional comment

Since there are no unionized employees in our Group, collective bargaining agreements are not valid for İnci Holding.

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	50
Non-executive board	67

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 (%)	83

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

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

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
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

İnci Holding has started to apply flexible working hours: The “Employee Voice” study, implemented with the aim of improving the employee experience, showed us that 80% of İnci Holding employees prefer hybrid work, 15% prefer to work from home every day, and 5% prefer to work from the office every day. We took action to take action in this regard. Based on the approach of "Don't do anything about me without me", we realized a "Design Sprint" study with the establishment of a Design Team of 8 people from different departments. The principles of the "New Working Model" determined in this way; It was gathered under the titles of Space Flexibility, Time Flexibility, Home Economics Support and Ergonomic Working Support at Home. The model was finalized by displaying multidimensional thinking, covering all operational, financial and human dimensions.

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.

İnci Holding has been awarded the “Great Workplace” certificate by the Great Place to Work® organization, the only employee experience platform that offers global measurement and is based on 30 years of research data, with a general perception score of 72% and a confidence index score of 77%. We continuously improve processes to prevent occupational accidents, and make the necessary investments to ensure that the results of accidents are traceable and accountable. We respect human rights in all regions where we operate, comply with national and international legal regulations regarding human rights, and expect our business partners to comply as well. Occupational health and safety is never compromised in our building, where İnci Holding and its group companies operate, and everyone within the working area, including subcontractors, is considered as İnci Holding employee and included in the scope of the occupational health and safety system. As İnci Holding, we continue our leadership in OHS issues, and we continue to implement innovations in the field of OHS within the framework of the plans we have determined. We ensure that our working conditions are evaluated with the OHS Awareness Awards given every year.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
2021
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

Optional comment

Within the scope of our environmental policy; wWe implement and maintain environmentally friendly practices such as waste management, energy efficiency and efficient water use in our companies and businesses. We evaluate the direct and indirect environmental impacts arising from our operations and are committed to reducing these impacts. Within the framework of the awareness of our responsibilities towards society in reducing the use of natural resources and protecting nature; We accept global warming and climate change as risks, and raise awareness of our stakeholders on this issue. In our sustainability policy&perspective; being fully aware of the interactions between economic, social and environmental dimensions, we are committed to sustainable development, taking into account all the effects of the decisions taken within the scope of economic, social and environmental. In our sustainability perspective; we have designed our economic and social sustainability roadmap to serve our vision; For new generations 'Investing in institutionalization', 'Investing in responsible production and consumption', 'Investing in people and society' 'Investing in innovation'. We aim to be the leader in researching and developing ways of doing business, technologies and products that will support sustainability.

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

We defined our reference and target years for the İnci Group and determined our annual greenhouse gas emission reduction targets. At this point, we will maintain our competitive advantage while determining our priority targets; We have chosen targets in line with the roadmap limiting global warming to 1.5 degrees. for the year 2030; Compared to 2018, our reference year, we set a 50% absolute reduction target. On our way to decarbonisation, in line with the targets we have set with our companies until 2030; We have determined our carbon reduction action plans separately for each of our companies. We prepared our sustainability strategy in 2021, and we are working on separate action plans in these areas in all our group companies in our leverage. We have prepared criteria sets to evaluate our suppliers in our value chain. We also plan to provide the necessary development areas to adapt them to our sustainability strategy.

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

These matters are included in our materiality. We shared a survey with our stakeholders (600 institutions & individuals). Stakeholders of İnci Holding: Synergy Group (Holding Board of Directors, Holding Management Team, Executive and Non-Executive Shareholders, Group Company Boards and Senior Management, Foundation Board and Senior Management, Vinci Senior Management), Sustainability Teams, Financial Institutions, Academicians, Educational Institutions, Non-governmental Organizations, Holding suppliers, Media representatives, Public institutions, International organizations, Founders of Invested Companies, Partners of “Joint Venture” Companies, Holding Employees

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

As İnci Holding, we implement and maintain environmentally friendly practices such as waste management, energy efficiency and efficient water use. We evaluate the direct and indirect environmental impacts arising from our operations and are committed to reducing these impacts. In line with the awareness of our responsibilities towards society in reducing the use of natural resources and protecting nature, we accept global warming and climate change as risks, and raise awareness of our stakeholders on this issue. Border carbon regulation, energy tax regulation, emissions trading system, social climate fund etc. We follow developments closely and review our strategies and actions in the light of changes. In our waste management activities, our primary priority is to prevent and reduce the amount of waste produced. We try to select products (including packaging) that require the least resources for production. Additionally, we prioritize work at the individual and corporate level to move away from single-use or single-use products wherever possible. If the consumption of a product cannot be prevented, we receive training on how to reuse reusable products. Carbon action plans have been prepared. Energy efficiency projects were prioritized in our group companies. Feasibility studies were carried out for the use of renewable energy. Opex studies continued in companies related to water use. In addition to all these, sustainability in the supply chain is a critical issue for us. In addition to our efforts to raise awareness of our companies on this issue in 2021, we started a study to evaluate suppliers with sustainability parameters. We continue our activities for the gradual use of supplier checklists. As İnci Holding, we have planted a total of 95 thousand saplings in the last 25 years!

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

As İnci Holding, we review the corporate risk inventory and evaluate the sustainability risks every year. Developments are evaluated on the basis of KPIs.

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

-We invest primarily in early-stage technology companies in the fields of supply chain, energy management/storage and industry 4.0. - We have investments in special charging systems, energy storage and microgrid solutions for electric commercial vehicle fleets. - LowerCarbon Focused Online Marketplace: a new generation, focused, shopping platform where consumers can find the products and services they need for clean energy and energy efficiency. -- As İnci Holding, we have planted a total of 95 thousand saplings in the last 25 years.

Climate Action

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

Scope 1 Emissions

Full

None

Only office building of İnci Holding

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

130

Scope 3 Emissions

Full

Partial

None

Only office building of İnci Holding

Emissions (tCO2e)

Optional comment

Our environmental data in the CoP Notice covers only the Holding operations. In general practise of İnci Group; our carbon footprint reporting standard is carried out on the basis of financial control since our global partnerships are also in our activity portfolio,. In order to monitor the total impact within the scope of our sustainability report, the total footprint of all our group companies has been calculated on a consolidated basis, based on the operational control approach.

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Only practising holding type (office business) operations, not including any production.

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

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

We have taken action to increase resilience in our supply chains

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

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

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

Other (Please provide additional information)

Unknown

Optional comment

In 2021, we primarily addressed the issue of decarbonisation. With the year 2021, regarding the developments brought about by the agreements such as the Paris Agreement and the European Green Deal, which also emerged in the sustainability priorities of our companies; We determined our decarbonization roadmaps and implemented our “Carbon Footprint Calculation and Target Setting Project”. In this project, we calculated the consolidated carbon footprints and carbon densities of our companies and the group with the project teams we formed in all group companies of İnci Holding. Afterwards, we defined our reference and target years for all our companies and the İnci group and determined our annual greenhouse gas emission reduction targets. At this point, we will maintain our competitive advantage while determining our priority targets; We have chosen targets in line with the roadmap limiting global warming to 1.5 degrees. for the year 2030; Compared to 2018, our reference year, we set a 50% absolute reduction target. On our way to decarbonisation, in line with the targets we have set with our companies until 2030; We have determined our carbon reduction action plans separately for each of our companies. - We have investments in special charging systems, energy storage and microgrid solutions for electric commercial vehicle fleets. - LowerCarbon Focused Online Marketplace: a new generation, focused, shopping platform where consumers can find the products and services they need for clean energy and energy efficiency. - We continue to make investments for the use of natural refrigerants by zeroing the use of gases with greenhouse effect in our production facility and products. - In our production processes in wheel factories, we monitor wheel-based energy data and provide improvements made on a component basis. By making regular checks and measurements with the energy tracking system, we take quick actions on equipment that exceeds the daily limit and aim to run the machinery in the most efficient way. - The evaluation process of projects that are suitable for the areas determined in the Business Development strategy and that will provide synergy with our current operations continues. Under the heading of energy storage/management, initiatives for battery technologies that can create synergy with our future portfolio, software for energy management and cell packaging technologies are examined. In the mobility/automotive part, which is another topic, products and business models that will not be affected by the transformation in the sector are researched.

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Optional comment

Although the use of renewable energy for holding operations is not yet valid, the energy efficiency studies of our group companies continue with all due diligence. We believe that the use of renewable energy resources will increase in the coming periods.

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

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	1.2
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water withdrawn in regions with high or extremely high water stress (%)

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	1.2
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)

Optional comment

running water for office operations

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/$):

Unknown

Not applicable (Please provide additional information)

Optional comment

0,0002 (running water for office operations)

Sector-specific: Waste

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

Waste Generated (t)

1.8

Unknown

Not applicable (Please provide additional information)

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 (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

Hazardous Waste Amount - Battery - ton 0.1 Amount of Non-Hazardous Waste - Domestic -ton, 1.7

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)

Unknown

Not applicable (Please provide additional information)

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.

As we continue to establish our sustainability strategies, we have primarily addressed the issue of decarbonization in 2021. We carry out product and process development studies to minimize our negative impact on the environment by following global developments and agreements such as the EU Green Deal. We also consider the many direct or indirect effects of the 'Fit for 55' and Border Carbon Adjustment Mechanism, which include the steps that Europe should take to reduce its emissions by 55% in 2030, and propose new regulations and mechanisms in this regard, on our manufacturing companies. We are working to expand our strategy by setting science-based targets in the upcoming periods. We create our strategic plans with our companies against developments, risks and sanctions in the international arena; We strive to be a part of every step taken in the name of combating the climate crisis, low-carbon production and sustainability. Efficient Use of Resources: Managing the energy power used by the company in production and/or consuming products and services provided by different suppliers, taking actions to reduce its impact on the environment by increasing energy efficiency (reducing total consumption, using renewable energy resources, etc.). Water supply, efficient use of water, etc. manage issues. Minimizing carbon emissions in overall actions of İnci Group. Developing Environmentally Friendly Products and Services: Developing products and services that minimize the damage to the environment while maintaining high standards within the sector's value chain. Our subsidiaries started to follow the revenues from sustainable products with the definition of "sustainable product". Waste Management and Circular Economy: Ensuring that wastes are collected, transported, treated and disposed of in line with the waste management process and waste-related laws, technologies, and economic mechanisms. In addition, aiming to extend the life cycle of products with a model that includes sharing, renting, reusing, repairing, renewing and recycling existing materials and products for as long as possible.

Anti-corruption

Commitment

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

Optional comment

There is no formal anti-corruption programme in place because the organization is a holding company with no customers, except related parties, and few suppliers; and further Inci Holding A.S. is not a publicly held/listed company in Turkey. However, there are internal controls, policies, and procedures in place, supported by a corporate risk management framework, and all these are monitored by the risk and audit committee through internal audit function of the Board of Directors of Inci Holding. Additionally, Inci Holding has its own ethical codes of conduct monitored by Ethical Committee of Board of Directors since 2014 .

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

The ethical code, which also serves as a staff hand book includes related above-mentioned measures. Annually reminders are sent to all suppliers, especially towards the year-end, and trainings are given on a periodical basis to all existing staff and newcomers. Affidavits are signed by all employees on an annual basis confirming their adherence to the ethical code of conduct.

Prevention

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

Optional comment

Inci Holding Ethical Code includes detailed information related to anti-corruption and integrity. However, annual training programmes are designed together with Ethical Committee and the Company’s own Academy that covers all employees.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

Optional comment

Trainings are given only to employees, separately on a periodical basis to all existing staff and, after each new recruitment, to the new joiners. However, at the year ends, procurement department informs all suppliers related to Inci Holding Ethical Values. Most of the customers of the Company are the Group Companies (related parties) and all have similar Ethical Values (code of conduct).

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

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

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

There is no anti-corruption compliance programme in place, but the ethic code of conduct is monitored, at the first level, by the Ethical Committee, reporting any incompliance issues directly to the board, and at second level, by the Risk and Audit Committee, reporting internal audit’s findings on any weaknesses and related recommendations, again directly to the board of directors.

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
Confirmed during the current year, and related to this year
Root causes and nature of the incidents are evaluated by Ethical Committee according to the procedure. Bribery, corruption and any unethical business practice are prohibited. All business and business activities and transactions would be fully and accurately recorded in our company's accounting system and in accordance with local laws; and would always be open to inspection. All tangible assets, datas, records etc. of business partners, individuals or corporate customers cannot be disposed of in the absence of a special permission.

Optional comment

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

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

The Company has no obligatory disclosure reporting related to incidents in accordance with its own reporting environment (non-publicly held holding company). If there are any incidents they are reviewed by, first the ethics committee, and then by the risk and audit committee. The outcome of the analysis is brought to the board for the ultimate decision.

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

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

There were no specific actions taken during the reporting period, as also explained above, via the ethics and risk & audit committees directly reporting to the board, proposed actions are brought to the attention of the board of directors.