2022 Communication on Progress

Keyassociados

Published date

June 27, 2022

No. of questions

51

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    Keyassociados is a small business sustainability consultancy, we have 11 employees and a horizontal business model that does not require the declaration or reporting of the above items, due to the nature of our business. We have a code of conduct where we declare our zero tolerance for corruption and our commitment to human rights and accountability for the possible environmental impacts of our business.

    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
    Keyassociados is a small company and we have no publicly declared commitments. Anti-corruption: Keyassociados has Information Security Guidelines and Confidential or Restricted Information, which were revised in July 2020 - Public document available at: https://www.keyassociados.com.br/Pol%C3%ADtica_Privacidade_Cookies.pdf Employees are made aware of the importance of confidentiality of information generated by the company and provided by its customers. We also prepared the Manual of Good Practices at Home Office, with guidelines and tips to ensure data security during remote work. Human rights: The company does not accept any type of discrimination, slave and/or child labor on its premises, sexual and moral harassment or offensive conduct in the work environment. It has a code of conduct where we express our support for internationally recognized human rights. Labor Rights / Decent Work: The company seeks to ensure a safe working environment for its partners and employees, and for suppliers (occasional consultants). Following the market trend, including small, medium and even large companies, in 2021 Keyassocaidos continued the home office activities regime, exclusively adopting the virtual office infrastructure. Environment: Due to the nature of our business, we are committed to being sustainably responsible. We have a code of conduct where we base our actions on respect for the environment and society.

    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
    Our code of conduct is focused on the performance of our employees, service providers and business partners. Our partners are not just our customers, but also our employees and associated companies. We encourage stakeholders to adopt ethical conduct and sustainable development, using our management practices as a reference. We have guidelines in support of human rights, guarantee of decent work, anti-corruption and environmental responsibility;

    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
    Keyassociados is a sustainability consultancy for small companies, we have 11 employees and a horizontal business model that does not require the delegation of an individual or group to be responsible for the aforementioned topics. We have a code of conduct where we declare our zero tolerance for corruption and our commitment to human rights and responsibility for the potential environmental impacts of our business. Such documents are applicable to all employees and business partners.

    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
    Keyassociados is a sustainability consultancy for small companies, we have 11 employees and a horizontal business model that does not require the delegation of an individual or group to be responsible for the aforementioned topics. We have a code of conduct where we declare our zero tolerance for corruption and our commitment to human rights and responsibility for the potential environmental impacts of our business. Such documents are applicable to all employees and business partners.

    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
    Keyassociados is a sustainability consultancy for small companies, we have 11 employees, due to the nature of our business, a formal risk assessment process related to our own operations and the entire value chain is not necessary. It is important to note that the risk assessment of our operations is carried out informally, according to the needs and different scenarios of our operations.

    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
    Keyassociados is a sustainability consultancy for small companies, we have 11 employees, due to the nature of our business, a formal risk assessment process related to our own operations and the entire value chain is not necessary. It is important to note that the risk assessment of our operations is carried out informally, according to the needs and different scenarios of our operations.

    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
    It constitutes an individual commitment of all employees of Keyassocaidos to comply with this Code of Conduct, in a coherent and adequate manner. The partial or total disrespect of the Code of Conduct implies in measures taken, aimed at investigating the cause and solving the situation, which may include the dismissal of the employee involved. Keyassocaidos seeks to informally guarantee the means for its stakeholders to request guidance on ethical and lawful behavior and on the integrity of the organization, or to communicate concerns about these issues. The company's Management is responsible for managing issues raised in our communication and reporting media and issues related to non-compliance with the Code.

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

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The partial or total disrespect of the Code of Conduct implies in measures taken, aimed at investigating the cause and solving the situation, which may include the dismissal of the employee involved.

    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
    Keyassociados is a sustainability consultancy for small companies, we have 11 employees and a horizontal business model that eliminates the need for executive compensation linked to their performance.

    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 (%)

    43

    Female (%)

    57

    Non-binary (%)

    0

    Under 30 years old (%)

    14

    30-50 years old (%)

    14

    Above 50 years old (%)

    71

    From minority or vulnerable groups (%)

    57

    Executive (%)

    100

    Independent (%)

    0
    Optional comment
    Keyssociados is a Private Limited Company, whose board is formed by associates: Alexandre Lopez Hernandez; Cristina Martins Silva; Fabia Beraldi de Melo; Francisco Roberto Ramires; Giovanna Zambrini and Talita Kanazawa Miranda ; and directed by the majority shareholder and corporate director William Eloy Abud

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

  • 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?

    The company does not acess it's material issues.

    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.

    The company does not take actions towards implementing human rights principles.

  • Labour

    Commitment

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

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

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

    Forced labour

    In its code of conduct, the company explains that it abolishes all types of child and/or slave labor.

    Child labour

    In its code of conduct, the company explains that it abolishes all types of child and/or slave labor.

    Non-discrimination in respect of employment and occupation

    In its code of conduct, the company explains its ethical position and does not admit any type of discrimination, slave and/or child labor within its premises, sexual and moral harassment or offensive conduct in the work environment.

    Occupational safety and health

    • As a quick response to the Coronavirus Pandemic scenario, in March 2020, through guidelines from the Corporate Board: o 100% of activities are now carried out at home office, including back office activities and partner consultants, as per the guidelines of the Corporate Board. o The Keyassociados office was closed, being released to be used in cases of extreme need, with prior notice to ensure that preventive hygiene and distancing measures were ensured. • Following the market trend, including small, medium and even large companies, in 2021 Keyassocaidos continued with the home office activities regime, exclusively adopting the virtual office infrastructure.

    Working conditions (wages, working hours)

    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
    Keyassociados is a small company, we do not have a formal published policy regarding labor rights. We use the Keyassociados Code of Conduct as a guide, which determines: Human rights: The company does not accept any type of discrimination, slave and/or child labor on its premises, sexual and moral harassment or offensive conduct in the work environment. It has a code of conduct where we express our support for internationally recognized human rights. Labor Rights / Decent Work: The company seeks to ensure a safe working environment for its partners and employees, and for suppliers (occasional consultants).

    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

    The nature of our activities does not present a risk of involvement in child labor.

    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

    The nature of our activities does not present a risk of involvement in child labor.

    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
    Optional comment
    Yes, 100% employees are covered by the Union of Employees of Autonomous Trade Agents and in Consulting, Expertise, Information and Research Companies and Accounting Services Companies in the State of São Paulo

    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 (%)

    100
    Optional comment
    Yes, 100% employees are covered by the Union of Employees of Autonomous Trade Agents and in Consulting, Expertise, Information and Research Companies and Accounting Services Companies in the State of São Paulo.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    0

    Non-executive board

    57
    Optional comment
    keyassociados does not have a Board of Directors, but has associated consultants.

    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

    0
    Optional comment
    There were no cases of injured workers.

    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
    There were no cases of incidents.

    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.

    ● Keyassociados' Code of Conduct explains its ethical position, whose main guidelines are based on transparency in relations with stakeholders; honesty and fairness in all functional and personal relationships; cooperation and teamwork; confidentiality in relation to the information acquired; independence in the assessment and auditing processes and compliance with the laws applicable to our business. ● The company is committed to maintaining an environment favorable to the practice of professional relationships with respect and dignity. ● Since the intellectual capital is fundamental for the provision of its services, Keyassociados encourages the full development and training of its employees. ● The company's objective is to guarantee everyone equality in terms of diversity, quality of life, distribution of profits and remuneration, benefits and opportunities.

  • 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

    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

    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

    We do not calculate the gross values of global greenhouse gases because our consulting work environment does not have a fixed office, each employee works from home, thus not allowing the calculation of GHG emissions.

    Emissions (tCO2e)

    Scope 2 Emissions

    We do not calculate the gross values of global greenhouse gases because our consulting work environment does not have a fixed office, each employee works from home, thus not allowing the calculation of GHG emissions.

    Emissions (tCO2e)

    Scope 3 Emissions

    We do not calculate the gross values of global greenhouse gases because our consulting work environment does not have a fixed office, each employee works from home, thus not allowing the calculation of GHG emissions.

    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 (%)

    We are a consulting company, we do not use any type of material for our type of work.

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

    We assist in CDP Latin America projects, ISE B3 and DowJhones reports, as well as sustainability reporting and greenhouse effect inventory.

    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

    Optional comment
    As our work style is given by working from home, we do not measure the amount of energy spent by each employee.

    Technology

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

    Percent of total revenue (%)

    60
    Among all the services that the company provides, we have 60% focused on corporate sustainability

    Sector-specific Questions

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

    Optional comment
    Business consulting.

    Overall Environment

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

    In 2021, we started to operate in a virtual office (coworking).

  • Anti-corruption

    Commitment

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

    The Associated Key Positioning Code explains its ethical position, in order to establish a transparent and integral relationship in the conduct of its activities, both with regard to employees and equal parties, considering the anti-bribery/anti-corruption policy based on standards 37001, AS 3806 ISO 19600 All partners have the company's overall results, a commitment by Keyassociados to the company's transparency and governance. In the period, there were no substantiated complaints with laws and regulations. Keyassociated with the legislation and health aspects respected by its business, including information security, social responsibility, occupational, environmental and quality safety and health.
    Optional comment
    The Associated Key Positioning Code explains its ethical position, in order to establish a transparent and integral relationship in the conduct of its activities, both with regard to employees and equal parties, considering the anti-bribery/anti-corruption policy based on standards 37001, AS 3806 ISO 19600 All partners have the company's overall results, a commitment by Keyassociados to the company's transparency and governance. In the period, there were no substantiated complaints with laws and regulations. Keyassociated with the legislation and health aspects respected by its business, including information security, social responsibility, occupational, environmental and quality safety and health.

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

    Optional comment
    Keyassociados' Code of Position explains its ethical position, in order to establish a transparent and integral relationship in the conduct of its activities, both with regard to employees and equal parties, considering the anti-bribery/anti-corruption policy based on standards 37001, AS 3806 ISO 19600 .

    Prevention

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

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

    We do not have any anti-corruption training or monitoring

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    Confirmed during the current year, and related to this year

    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.

    None