Report - COP Prototype

2022 Communication on Progress

Esselunga S.p.A

Published date

June 23, 2022

No. of questions

Supplemental files

Esselunga_Code of Conduct.pdf Esselunga_Sustainability Policy.pdf Esselunga_Extract General Part of Model 231.pdf Esselunga_Suppliers code of conduct.pdf ESSELUNGA SpA_Opinion 2021 ENG_DEF.pdf ESSELUNGA SpA_Opinion 2021 ENG_DEF.pdf politica-sostenibilta-en.pdf Suppliers code of conduct.pdf Esselunga_Suppliers code of conduct.pdf Esselunga_Sustainability Policy.pdf Esselunga_Suppliers code of conduct.pdf Esselunga_Code of Conduct.pdf Esselunga_Sustainability Policy.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

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

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

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

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

Estratto Parte Generale del Modello 231 -->

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

We don't have a specific anti-corruption code. Our “Code of Conduct” "[...] is observing the law and ruling regulations. This Code is an essential part of the preventive control system adopted by Esselunga Group companies in order to prevent crimes that could be committed in performing their activities, specifically the predicate crimes set out in Legislative decree no. 231/2001, related to the administrative responsibility of legal persons (the “Decree”)". The Legislative decree no. 231/2001 includes also Crimes against the public administration (art. 24 and 25 Legislative decree no. 231/2001) and Corporate crimes (Art. 25-ter Legislative decree no. 231/2001).

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

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

Until the definition of an anti-bribery system, Internal Audit department will audit corruption risk only related to specific business processes in order to evaluate the compliance to the crimes set out in Legislative decree no. 231/2001. The Legislative decree no. 231/2001 (related to the administrative responsibility of legal persons) includes also Crimes against the public administration (art. 24 and 25 Legislative decree no. 231/2001) and Corporate crimes (Art. 25-ter Legislative decree no. 231/2001).

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

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Optional comment

During 2021 the Company has carried out an analysis and an assessment with the company functions for the definition of an anti-bribery system. The implementation process will require integration with existing processes (e.g. suppliers qualification) and IT systems.

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

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

Anti-corruption is considered as a pre-requisite.

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 (%)	89
Female (%)	11
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	22
Above 50 years old (%)	78
From minority or vulnerable groups (%)	0
Executive (%)	55
Independent (%)	11

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

Please refe

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

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?
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)
Freedom of expression
Access to culture
Access to water and sanitation
Digital security / privacy
Rights of women and/or girls
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Other
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.
Please refers to Consolidated non-financial Report 2021: https://www.esselunga.it/content/dam/istituzionale20/azienda/investor-relations/new/Esselunga%20-%20Bilancio%20Consolidato%202021_ENG.pdf § 4. Respect for human rights § 5. The Esselunga Group’s people § 7. Social topics: supply chain

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
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)
We refer here to the agreements with the Trade Unions.

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 (%)	100

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 (%)	9

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

	Percent of women (%)	Unknown
Senior leadership level position	13
Non-executive board

Optional comment

Senior leadership level position = senior executives. In 2021, there were no non-executive board.

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

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	23.9

Optional comment

Rate have been calculated based on 1,000,000 hours worked.

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.4

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)

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.

Please refers to Consolidated non-financial Report 2021: https://www.esselunga.it/content/dam/istituzionale20/azienda/investor-relations/new/Esselunga%20-%20Bilancio%20Consolidato%202021_ENG.pdf § 4. Respect for human rights § 5. The Esselunga Group’s people § 7. Social topics: supply chain

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
2022
Oceans
Forests / Biodiversity / Land Use
2022
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

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

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

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

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

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

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

Optional comment

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	30% reduction in greenhouse gas emissions, intensity, externally verified
Energy & Resource Use	Produce energy from renewables plants to 6000 MWh within 2025
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	Improve the percentage of food surplus that is donated, recovered and recycled, reducing food waste, externally verified; 100% of the packaging of Esselunga branded products in recycled, recyclable or compostable material, externally verified
Oceans

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

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

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

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Scope 3 emissions will be calculated within July 2022.

Emissions (tCO2e)

Optional comment

Scope 1: 95799,39 Scope 2: 182648,27. Note: Scope 2 emissions are calculated using market-based emissions calculation method in which GHG emissions, arising from the purchase of electricity from renewable sources, are assigned an emissions factor of zero. Emissions from the remaining energy were calculated by applying an emission factor of 458.57 gCO2/kWh (residual mix for Italy for 2020).

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)

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

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

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)

Sensitive data. For this reason it has not been disclosed.

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	6832
Groundwater:	3945
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	6832
Groundwater:	3945
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water consumed in regions with high or extremely high water stress (%)	0

Optional comment

In addition, there are water resources withdrawn from third parties for a total of: 2886 megaliters.

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

The exact value is 0.0007. Currency conversion date of 04/13/2022.

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	34
Hectares	86.4

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)

Unknown

Not applicable (Please provide additional information)

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

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
1
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

Optional comment

The above project is a forest improvement (extraordinary maintenance and integration of plants in an existing forest).

Sector-specific: Waste

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

Waste Generated (t)

99.92

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

The exact value is 0,08%

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.

Please refers to Consolidated non-financial Report 2021: https://www.esselunga.it/content/dam/istituzionale20/azienda/investor-relations/new/Esselunga%20-%20Bilancio%20Consolidato%202021_ENG.pdf § 2.6 European Taxonomy Dissemination § 9. Environment

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

Refers to the anti-bribery system, during 2021 the Company has carried out an analysis and an assessment with the company functions for the definition of an anti-bribery system. The implementation process will require integration with existing processes (e.g. suppliers qualification) and IT systems.

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

In this case we refer to some of the procedures in place. Such as, for example: Whistleblowing procedure, Conflict of interest procedure, Personnel selection and hiring procedure, Gifts and sponsorship procedure, Management of relations with PAs, Management of in-store inspections by the supervisory authorities; as well as the following documents: Code of Ethics and Conduct, Sustainability Policy and Supplier Code of Conduct.

Prevention

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

Optional comment

As stated in our Organisational, management and control Model: "The Company provides training about the content of the Decree and the principles set out in the Model. The training courses differ depending on the employees' position, the level of risk in their areas and whether they represent for the company with third parties".

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

The course content on Organisational, management and control Model is updated to reflect changes in the legislation (e.g. introduction of new predicate crimes) and the Model's content (e.g. adoption of new special parts).

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

During the recruitment process the candidate are asked to sign a form to report the presence of conflicts of interest. Furthermore, on an annual basis, the Executives sign a form on the absence of conflicts of interest. The procedures are also periodically reviewed on the occasion of regulatory updates or changes to processes or internal reorganisations.

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

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

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.