• Governance

    Policies and Responsibilities

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

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

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    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
    Assessing risks is part of our human rights due diligence. We have a HRDD in place, however the main focus is own operations and direct suppliers.

    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 aim to scale our HRDD to cover all of our direct suppliers but until then, we focus on our key direct suppliers where we also have a stronger leverage.

    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
    See the Human Rights Policy for description of our Human Rights Due Diligence. We follow the UNGP and OECD Guidelines, although the focus now is on own operations and direct suppliers.

    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
    We aim to scale our HRDD to cover all of our direct suppliers but until then, we focus on our key direct suppliers where we also have a stronger leverage.

    Concerns and grievance mechanisms

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

    Optional comment
    Please see our whistleblower platform - SpeakUp! - where all stakeholders can raise any issues, including doing so while remaining anonymous. https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=14nor18&c=-1&language=eng

    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)

    Our SpeakUp! mechanism is aligned with the requirements of international organizations, including the UNGPs.
    Optional comment
    Please follow the link for SpeakUp! and the details: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=14nor18&c=-1&language=eng

    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?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Executive pay in the future linked to a number of sustainability related KPIs - but are unsure about which exactly (besides environment).

    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 (#)

    3

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    66

    Above 50 years old (%)

    33

    From minority or vulnerable groups (%)

    0

    Executive (%)

    3

    Independent (%)

    0

    13. Do you produce sustainability reporting according to:

    Optional comment
    The CSRD will apply to us from 2024 and we are currently preparing for this. Aligned with NFRD in the Nordics.

    Data Assurance

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

    ETS
  • 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?

    Optional comment
    This question is bugging for us and we are not able to select all of our salient human rights issues. Please see the NZ Human Rights Policy for the salient issues we have identified or see here: Occupational health and safety, • Forced labour and modern slavery, • Child labour, • Working conditions and discrimination, • Right to association, • Land rights, • Water contamination and contribution to climate change.

    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.

    We undertake r human rights due diligence to identify, prevent and mitigate human rights risks. The above-identified salient human rights are a focus of our Country Risk Assessments that are conducted prior to taking up any new activities in countries where Nordzucker has no previous experience in and reviewed periodically, especially in countries that have been identified as high risk or medium risk. We further evaluate our direct business partners, particularly in emerging markets, through Suppliers Desktop Questionnaires and undertake audits of our most risky suppliers. As a minimum, Nordzucker always audit key suppliers from regions where we do not have prior experience, and where repeated business is intended. Where we identify that they have caused or directly contributed to adverse human rights impacts, we will engage in appropriate remediation processes by ourselves or in cooperation with other stakeholders. The biggest challenges we currently face is to scale our HRDD across the whole direct supplier base, ensure that reported practice by supplier is truthful and provide meaningful engagement with suppliers to improve capacities on sustainability topics.
  • 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 - as part of our Human Rights Policy

    Forced labour

    2021 - as part of our Human Rights Policy

    Child labour

    2021 - as part of our Human Rights Policy and also a dedicated policy on Child Labour and Child Labour Remediation from 2017

    Non-discrimination in respect of employment and occupation

    2021 - as part of our Human Rights Policy

    Occupational safety and health

    2021 - as part of our Human Rights Policy but also as a stand alone policy on Safety and Health

    Working conditions (wages, working hours)

    2021 - as part of our Human Rights Policy
    Optional comment
    Please note that we have a human rights policy which coveres all topics above (which are also identified salient human rights issues for us). Moreover, all topics above are also part of our Supplier Code of Conduct and Code of Conduct.

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    technical comment - lot of issues ticking the boxes (keeps bugging up and "ticks" keep disappearing)

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    87.4

    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 (%)

    Optional comment
    We do not have the ability to provide exact numbers on the Group level of who is in or not in a Trade Union – we would potentially breach national legislations if we were to ask each individual if they were in a Trade Union.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    18.6

    Non-executive board

    16.7
    Optional comment
    21.7% = Percentage of women employed in relation to the whole organization

    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

    8.81
    Optional comment
    KPI: Lost time injury (LTI) frequency rate for direct workforce - (total number of lost time injury events) x 1,000,000 / total hours worked company wide

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    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

    We have not been involved in any cases linked to freedom of association and collective bargaining, and therefore, N/A for this question.

    Forced labour

    We have not been involved in any cases of actual or potential forced labour, and therefore, N/A for this question.

    Child labour

    We have not been involved in any cases of actual or potential child labour, and therefore, N/A for this question.

    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.

    Nordzucker is committed to developing an organizational culture and a general conduct of respect and support for internationally recognized human right and labor rights and seeks to avoid complicity in any human rights and labor rights abuse through its activities and business relationships. We support the principles contained within the UN Guiding Principles on Business and Human Rights, the OECD Guidelines and the UN Global Compact. Additionally, all of our sites are Sedex SMETA audited on periodic basic. We are now working on expending the scope of our human rights due diligence, which also includes labor rights. Furthermore, we are in the process of updating our Code of Conduct to emphasis stronger language around the protection of labor rights principles. Challenges we see predominantly lie within our supply chain, around the questions of how to ensure broader reach and better transparency. In direct operations, main challenges regarding labor rights lie within the area of safety and health, and continuing to embedded safety culture practices across the organization.
  • 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

    Oceans

    Forests / Biodiversity / Land Use

    2021

    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

    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

    50% reduction of scope 1 and 2 in 2030 with 2018 baseline

    Energy & Resource Use

    33% energy reduction in 2030 with 2018 baseline

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    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

    No actual negative impact associated with this environmental issue.

    Water

    No actual negative impact associated with this environmental issue.

    Oceans

    No actual negative impact associated with this environmental issue.

    Forests / Biodiversity / Land Use

    No actual negative impact associated with this environmental issue.

    Air Pollution

    No actual negative impact associated with this environmental issue.

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

    No actual negative impact associated with this environmental issue.

    Energy & Resource Use

    No actual negative impact associated with this environmental issue.

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    1118523

    Scope 2 Emissions

    Emissions (tCO2e)

    45875

    Scope 3 Emissions

    Emissions (tCO2e)

    3306400

    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 (%)

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

    Optional comment
    We are committed to the Science Based Target initiative and report through CDP since 2010. We are also one of the key members of the SAI FSA and the recent SAI Regenerative Agriculture project.

    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

    47

    Technology

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

    Percent of total revenue (%)

    95
    RedCERT certified beets. Organic beet production and SAI FSA verification

    Sector-specific Questions

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

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    4836

    Groundwater:

    1193

    Surface water:

    3642

    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

    0

    Groundwater:

    0

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    0

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

    0
    Optional comment
    The reason why we reported our water consumption as 0 is because Nordzucker is a net water producer. We discharge more water than we consume as we utilize the water from the beet in our production. The beet is made of up to 75% of water, which is extracted and used in our production. The wastewater is then sent to water treatment processes before discharge back to the nature. In 2021, our treated wastewater discharge was 11.331 megaliters. Please note that under water withdrawal, surface water is both water from municipal sources (1082 megaliters) and rivers, lakes, wetlands and oceans (2560 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/$):

    We do not operate in regions with high or extremely high water stress.

    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

    0

    Hectares

    0
    Optional comment
    We do not own, leas or manage land in protected and /or key biodiversity areas (KBA).

    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)

    0
    Optional comment
    We do not own, leased or manage any natural ecosystems outside of factory premises.

    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

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Optional comment
    We are part of the SAI Regenerative Agriculture work group. Furthermore, we invest in our own agricultural research focusing on pesticide reduction and biodiversity projects (such as flower strips), and develop farmer decision making support tools (such as an app for farmers).

    Overall Environment

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

    We have set ourselves ambitious targets for the reduction of our carbon emissions through our Science Based Targets initiative (SBTi). We want to reduce our emissions by 50 per cent by 2030 as compared with 2018 levels. This reflects the target set out in the Paris Agreement to avoid global warming exceeding 1.5°C. We are working under the assumption that our targets will be confirmed by the SBTi in 2022. Largest challenges we face at the moment is switching to less emission intensive fuels and renewable fuels, mainly due to Ukraine war as well as the questions surrounding the usability of biomass.
  • Anti-corruption

    Commitment

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

    2021
    Optional comment
    As of 2021, we have a new Anti-corruption and Compliance Officer. We have published a new Anti-Corruption Guideline which provides very practical processes of how to avoid and proceed when dealing with sensitive transactions that could lead to fraud, bribery, corruption or other unethical behavior.

    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?

    Prevention

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

    Optional comment
    All employees receive Code of Conduct training, which anti-corruption and integrity (and other Business Ethics) are also part of. Selected employees (white collars mainly) then receive a more detailed training.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

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

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    None of the cases submitted via our grievance mechanism (SpeakUp! and other whistleblower procedures) were confirmed as corruption incidents in 2021.

    Confirmed during the current year, and related to this year

    0
    None of the cases submitted via our grievance mechanism (SpeakUp! and other whistleblower procedures) were confirmed as corruption incidents in 2021.

    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?

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

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

    Over the course of last year, we have taken several steps to strengthen our anti-corruption efforts. We know have a dedicated Anti-corruption and Compliance officer, and have published new comprehensive Anti-corruption Guidelines and Anti-corruption leaflet for employees. We have also provided and undertook trainings on the topic of Business Ethics. Moreover, we have a dedicated ethics committee, which ensures compliance with our values and investigates individual cases where necessary. One of our goals is to establish a network of value ambassadors at all of our sites, who will serve as an interface with our employees.