Report - COP Prototype

2022 Communication on Progress

ACTE International

Published date

June 23, 2022

No. of questions

Supplemental files

SMAC 04-2022 - ACTE Intl - Anti-bribery code.pdf Lettre d'engagement dirigeantes.pdf Lettre d'engagement organe de gouvernance.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

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

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

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

Optional comment

The most Senior Executive of our company, ACTE International Groupe's General Manager, Mrs Anne LE ROLLAND, issues each year a personnalized statement in our COP to share the specific CSR challenges of the year linked to the updated context. Additionnally, in the framework of our ISO37001 certification, our Anti-Corruption Code is regularly reviewed and updated and we have many internal and external communication during the year regarding our Zero Tolerance against corruption policy, showing a strong leadership on this topic.

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

Regarding anti-corruption, our management commitment is expressed in our Anti-Corruption Code (latest update in 2022, page 4) which is widely shared with our employees in France and Morocco, and all our business partners (see attached document), as well as on our website. There are also 2 specific committment letters from ACTE top management and governance (mother company GM) integrated in our Certified Anti-Corruption management system (ACMS)- see attached documents which will also be shared on our website.

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

2022 CSR Charter

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

Mrs Sylvie THONNERIEUX, CSR Manager, Expert and trainer in CSR and Anti-Corruption policies

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

We have built since 2015 operational internal groups (Groupes Boos'Terre) with the participation of all our employees on the following topics : Environment, Green Mobility, Well-being at work, Social Commitment. In 2022, we have just elected an official Economic and Social Committee and are planning to have a cross-functional committee to work on strategy and planification of our sustainability targets. For Anti-Corruption, we have a team of internal experts, including one Anti-Corruption compliance office, managing our certified Anti-Corruption management system, directly reporting to our Group General Manager.

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

Re. Corruption risks, we perform an annual Risk assessment in the framework of our ISO37001 certification, since 2019. We are presently preparing our certification renewal audit, scheduled on July 11 & 12. Regarding Human rights, labour rights and environmental risks we are working in 2022 for a similar risk approach, based on our experience with anti-corruption risk-mapping.

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

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

Optional comment

We have a precise written procedure regarding Corruption risks assessment, including criteria based on turnover level, country risks, sectorial risks, market risks, etc. to assess 1rst gross risk and then stuying prevention and control systems in place, as well as their efficiency, to land on net risk level.

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

We shall be working this year on our materiality matrix and CSR risk assessment in order to strengthen prevention and control, in our value chain, against any potential negative impacts of our activity (already identified as mainly indirect considering our business model).

7.1. During the due diligence process, which business relationships are reviewed?

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

Optional comment

For the anti-corruption diligence process, we use from simple website and internet search, to screening and complete due diligence investigation by specialized service providers.

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

There is a formal process regarding our specific anti-corruption alert system, with the anti-corruption compliance officer and the anti-bribery alert system. For other CSR topics, employees turn to the CSR department manager who is the CSR compliance officer. Additionnally, we intend to duplicate the same alert system tool for CSR issues related to human rights, labour rights and environment before the end of 2022.

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

Complete procedure in place, regularly communicated internally and externally, with specific training and awareness raising for ACTE International employees and partners.

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

For employees only as per labour law

Lessons

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

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

If any issues related to labour rights, human rights, environment issues concerning our own employees, our HR department and GM would conduct root-cause analysis to avoir re-occurrence. Regarding anti-corruption matters, everything is managed by our anti-corruption management system, with a specific follow-up improvement table and updating and strengthening of our processes and procedures if needed.

Executive Pay

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

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 (#)	7
Male (%)	100
Female (%)
Non-binary (%)
Privacy info
Under 30 years old (%)	0
30-50 years old (%)
Above 50 years old (%)	100
From minority or vulnerable groups (%)
Executive (%)	100
Independent (%)

Optional comment

Above description is our mother company information M&M France. https://www.societe.com/dirigeants/m-m-militzer-munch-france-307048439.html ACTE International is now 100% daughter company of M&M France and has no more board. The general managers at ACTE International are 2 women, above 50 years old not from minority or vulnerable groups.

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)

ISO37001 Certification by accredited body https://www.acte-international.com/web/aw_29007/fr/prevention-de-la-corruption-acte-international-1ere-pme-francaise-certifiee-iso-37001

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
CSR Charter 2022
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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

Prevention

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

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

Optional comment

Webinars with RHSF

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

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

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

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.

Starting 2022, we plan to communicate and to raise awareness specifically with our major logistics partners about most salient human rights issues. We also intend to implement self-assessment questionnaires and schedule audits of the management systems implemented by our major partner to be in line with our Anti-Corruption and CSR policies.

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
2022
Forced labour
2022
Child labour
2022
Non-discrimination in respect of employment and occupation
2022
Occupational safety and health
2022
Working conditions (wages, working hours)
2022

Optional comment

All expressed in our new CSR Charter 2022

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
Only with our internal stakeholders, our direct employees, to provide information on elections of Economic and Social Committee.
Forced labour
N/A Not relevant to our direct activity
Child labour
Not relevant to our direct activity
Non-discrimination in respect of employment and occupation
Only with our internal stakeholders, our direct employees. No discrimination is practised at ACTE International, women are widely represented, top management are women.
Occupational safety and health
Only with our internal stakeholders, our direct employees. Low impact, office jobs strictly compliant with French regulation by Médecine du Travail
Working conditions (wages, working hours)
Only with our internal stakeholders, our direct employees. In strict compliance with French Labour law.

Optional comment

Multiannual individual talks with each employee, according to French law.

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

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

Optional comment

We are up to communicate widely on our new CSR Charter and to build capacity among our relevant business partners

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

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

Optional comment

No specific training provided yet to our employees, it is scheduled for current year. Later on in the year to our business partners.

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

We intend to work in 2022 with a CSR internal Committee on most salient topics for our company internally (occupational H&S, working conditions), and at the same time communicate and ask for commitment of our major business partners (logistic partners) to our CSR Charter.

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	100

Optional comment

Convention Collective Expertises : évaluations industrielles et commerciales

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

Optional comment

No unionised employee until now in our company (very usual in France in SMEs). Social and Economics Committee (CSE) elections undergoing at present (1rst round call for TU candidates mid of Jund, 2nd round end of June open to all employees).

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

	Percent of women (%)	Unknown
Senior leadership level position	100
Non-executive board

Optional comment

GM Group and GM company are both women. We don't have a 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 (%)

Optional comment

We are planning to check this kind of information in our 2022 CSR action plan

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

Optional comment

No injury, no occupational disease. Service providing jobs.

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

Optional comment

No incident either.

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.

During the reporting period, internally, we are strictly operating in conformity with French legal requirements (service of a specialized lawyer in French Labour law) regarding wages, working time, occupational H&S. Starting mid 2022, we plan to launch again an internal "Well being at work" survey, benchmark our improvement potential with our lawyer, set improvement objectives and KPIs to be able to report about our existing performance and progress. Regarding our value chain, we are starting to broadly communicate our new 2022 CSR Charter, with specific awareness raising with our major business partners.

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
Water
Oceans
commitment included in our 2022 CSR Charter
Forests / Biodiversity / Land Use
commitment included in our 2022 CSR Charter
Air Pollution
2022 CSR Charter
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
commitment included in our 2022 CSR Charter
Energy & Resource Use
commitment included in our 2022 CSR Charter

Optional comment

We have a general commitment on environment protection, biodiversity preservation, fight against climate change, waste and chemicals management, energy use in our 2022 CSR Charter. We have our internal active Environment, Green mobility working groups. But no detailed policy or procedures on environmental topics for the moment.

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
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre
Water
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre
Oceans
Forests / Biodiversity / Land Use
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre
Air Pollution
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre
Energy & Resource Use
With our internal stakeholders only, our employees, working on practical actions with our Environment and Mobility Groupes Boos'terre

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
Applying our water use reduction policy
Oceans
Forests / Biodiversity / Land Use
Contributing to biodiversity by financing bee
Air Pollution
Working on
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Applying our waste management policy (no plastic, paper dematerialisation, etc.)
Energy & Resource Use
Applying our energy consumption reduction policy

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

No monitoring on progress at present, this is what we intend to implement or improve starting 2022 by comparing consumptions, fixing improvement targets, etc.

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

No adverse environmental impact detected

Climate Action

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

Scope 1 Emissions

Full

None

We are a small service providing company. We will start this year analysing our direct and indirect GHG emissions and use science-based targets approach.

Emissions (tCO2e)

Scope 2 Emissions

Full

None

We are a small service providing company. We will start this year analysing our direct and indirect GHG emissions and use science-based targets approach.

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

We are a small service providing company. We will start this year analysing our direct and indirect GHG emissions and use science-based targets approach.

Emissions (tCO2e)

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

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

We don't produce items nor direct logistics services (we work with transporters and maritime and air freight fowarders but do not have our own fleets). Due to the small size of our company, we don't have R&D department either

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

Optional comment

We are planning to collect this kind of information with our energy service providers starting this year.

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

All our printing paper is PEFC and EU Eco Label certified.

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

Optional comment

We intend to measure these information starting 2022

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)

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
Intellectual service providers
SOx
Intellectual service providers
Volatile Organic Compounds (VOC)
Intellectual service providers
Hazardous air pollutants (HAP)
Intellectual service providers
Particulate matter (PM10)
Intellectual service providers
Persistent organic pollutants (POP)
Intellectual service providers
Other (please specify in text box)
Intellectual service providers

Optional comment

We have no direct emissions of pollutants in our company activity

Sector-specific: Waste

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

Waste Generated (t)

Unknown

Not applicable (Please provide additional information)

Optional comment

We intend to measure these information starting 2022

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

We intend to measure these information starting 2022

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)

Optional comment

We intend to measure these information starting 2022. But we already have a policy of Zero single use plastic in our eco-responsible gestures (no single plastic bottle used, water fountain, individual isothermal bottles, etc. )

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.

Continuous eco-friendly gestures and procedures applied by our employees regarding use of water, electricity, heat and air-con, paper, bottles, waste management.

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

2022

Optional comment

Existing certified ISO37001 management system since July 2019, full audit for certification renewal scheduled on July 11 & 12.

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

Yes, we have a specific Gifts and invitations, as well as donations and sponsorship policy included in our Anti-Corruption Charter and we have related policies in our Anti-Corruption management system.

Prevention

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

Optional comment

All our employees, including in our subsidiary in Morocco are trained on anti-corruption, at different levels, depending of the level of exposure to corruption risks attached to their job position and function. Our main contractors and parners are asked to view a specific webinar on anti-corruption. We have many training contracts about corruption prevention wiht our clients, from implementing systems answering French LOI SAPIN 2 requirements to complete ISO37001 management system implementation.

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?

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

Complete ISO37001 management system with related system and operational procedures.

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
No incident this year.
Confirmed during the current year, and related to this year	0
No incident this year.

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)

We are members of CIAN (Conseil Français des Investisseurs en Afrique - French Council of Investors in Africa) and have actively contributed in the framework of the Commission Ethics and Compliance to the Practical Guide "How to resist to resist to undue solicitations in the tax and customs field" published in February 2020. This Guide is publically available on their site, used and distributed by major French companies working in Africa.

Optional comment

https://www.cian-afrique.org/publications/guides-pratiques-cian/

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.

Our Anti-Corruption Code is shared with all our clients, suppliers, service providers. It is publically available on our website (https://www.acte-international.com/web/aw_32171/fr/code-anticorruption-acte-international). Our logistics partners (core business partners) sign our charter "Log' Ethics" to abid by our CSR commitments. Every employee has signed the commitment letter to the Code as well as a Declaration of absence (or existence) of conflict of interest. We have several ongoing missions with Morrocan and African companies to help them implement certified ISO37001 Anti-Corruption Management systems (among them last year, central bank of Morroco Bank Al Maghrib). In the field of social audit services, our auditors are trained on corruption prevention and sign our Anti-Corruption Code. During opening meeting of each audit, they remind the factory management about our Zero Tolerance policy against any corruption attempt and sign a common agreement.