Scope 1 Emissions
2022 Communication on Progress
TITAN Cement International
Published date
June 28, 2022
No. of questions
72
Supplemental files
Human Rights Policy (September 2020).pdfGroup H&S Policy (March 2020).pdfDiversity-Equity-and-Inclusion-Policy-March-2022.pdfTITAN-Group-Code-of-Conduct-February-2021-Ext (1).pdfCEO Statement
Signed
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?
Optional commenthttps://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf (pages 4-5)3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commenthttps://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Code-of-Conduct-February-2021-Ext.pdf4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentSee also the chapter Good governance, transparency and business ethics (p.36-39) in TITAN's Integrated Annual Report as well as the Corporate governance statement . Link : https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentSee also the chapter "Good governance, transparency and business ethics " (p.36-39) in TITAN's Integrated Annual Report as well as the "Corporate governance statement" . Link : https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdfPrevention
6. Does the company have a process or processes to assess risk?
6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentApproximately 25% of the total number of 'key suppliers' of TITAN have been already assessed according to TITAN ESG Criteria which cover the above areas.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?
7.1. During the due diligence process, which business relationships are reviewed?
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 commenthttps://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf (see p.95)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.
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?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentFor more details, please see the Remuneration Report in TITAN's integrated Annual Report (p.65-70) as well as the subchapter: Integrating ESG criteria in executive remuneration (p.38) . Link to the Report : https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdfBoard Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentFor more information, please see p.36-37 and also p.55-59 of the Group's Integrated Annual Report. https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf13. Do you produce sustainability reporting according to:
Optional commentFrameworks of: GCCA Charter and Guidelines, CDP, UN SDGs 2030, UNCTAD Guidance (ISAR) https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf (see 'About the Report', and pages 22, 23, and 98)Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commenthttps://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf (pages 229-231)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 commentSee inside the TITAN IAR 2021: "Focusing on material issues TITAN’s approach to sustainability is based on the principle of double materiality assessment, an integrated, on-going process of mapping and assessing the impact of our operations on society and the environment, as well as the financial impacts of socio-environmental risks on the Group. Impacts may become material for financial reporting purposes over time, leading to what is known as dynamic materiality assessment process. A full cycle of materiality assessment at TITAN has a duration of five years. We use the resulting prioritization of material issues at local level as input for the materiality assessment at Group level and vice versa. The latest assessment at Group level, which was conducted in 2020, yielded nine material issues grouped in four focus areas, all underpinned by good governance, transparency and business ethics. In 2021, all TITAN business units completed a new cycle of materiality assessment, by updating their priorities following the process established by the Group in 2020. This milestone marks the completion of our fourth materiality assessment cycle. The Group harmonized and further developed its materiality assessment process in alignment with the ten principles of the UN Global Compact and the SASB Materiality Map for our sector. Based on this methodology, both sector-agnostic and sector-specific material issues, as well as country-specific material issues, were identified and are presented in Table 1 of the ESG Statements. The issues that are most material for the majority of our business units are: Future-ready business model in a carbon-neutral world, safe and healthy working environment, positive local social, economic and environmental impact, and continuous development of our people. Following the completion of this exercise, TITAN set and announced its ESG targets for 2025 and beyond (see pages 20-21). We are engaging with our stakeholders across our locations to obtain a deeper understanding of their expectations and needs. Mapping what is most material to them and to the business through a double materiality process helps us develop sustainable business strategies and create value that lasts. TITAN's Material Issues: (1) Future-ready business model in a carbon-neutral world (2) Innovation with emphasis on digitalization and decarbonization (3) Safe and healthy working environment (4) Continuous development of our people (5) Diverse and inclusive workplace (6) Positive local social, economic and environmental impact (7) Resource efficiency, recycling, and recovery, contributing to the circular economy (8) Reliable and sustainable supply chain (9) Good governance, transparency and business ethics Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages 18 and 19.Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentPolicies mostly related to the 'Rights of women and/or girls': - TITAN Human Rights Policy (2020), and - TITAN Diversity, Equity and Inclusion Policy (2022) Source: https://www.titan-cement.com/about-us/corporate-governance/group-policies/#1653286889111-a4efb43a-412d2.1. For each human rights policy, is it:
Optional commentTITAN Policies mostly related: - TITAN Human Rights Policy (2020) Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Human-Rights-Policy-September-2020.pdf And - TITAN Diversity, Equity and Inclusion Policy (2022) Source: https://www.titan-cement.com/wp-content/uploads/2022/05/Diversity-Equity-and-Inclusion-Policy-March-2022.pdfPrevention
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?
Optional commentTITAN Policies mostly related: - TITAN Diversity, Equity and Inclusion Policy (2022), already in effect for the main principles since 2021 Source: https://www.titan-cement.com/wp-content/uploads/2022/05/Diversity-Equity-and-Inclusion-Policy-March-2022.pdf And - TITAN Human Rights Policy (2020) Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Human-Rights-Policy-September-2020.pdf See inside the TITAN IAR 2021: "5. Diversity and Inclusion TITAN is committed to offering equal opportunities and encourages diversity and inclusion at every level of employment in the Company. Diverse and inclusive workplace has been recognized as a material issue for the Group. Diversity includes gender, age, nationality, disability, ethnic origin, sexual orientation, culture, education and professional background. At Group level, particular attention is given to monitoring the implementation of our Human Rights Policy, part of which refers to the promotion of diversity and to ensuring consistent improvement of diversity across the organization. Improving the gender mix at all levels is always an area of focus. Likewise, we focus on inclusion and on creating a working environment that maximizes the potential of all employees. Currently, the number of women on the Board is 3 out of 15. However, the Company intends to comply with the 1/3 gender diversity rule, earlier than provided by law, by increasing the number of women serving on the Board. The Board has also promoted diversity in the composition of the Board Committees, by appointing a woman as Chair of the Remuneration Committee and another woman as a member of the Nomination Committee. TITAN monitors gender diversity in management at both Group and local levels (see ESG Performance statements, table 2.2 Focus area growth enabling work environment). In 2019, an assessment of Group policies was conducted by the Group Human Resources Department to define priorities and future targets accordingly. Our Group Code of Conduct, Human Rights and CSR policies were updated to incorporate clearer references to diversity and inclusion. Diversity at the Board level has also been promoted through a balanced mixture of academic and professional skills. More specifically, the Board includes directors from a variety of sectors, including, among others, banking and insurance, corporate/ business, audit services, public policy and political history, the cement sector, emerging markets and finance, legal services, technology and IT. As far as residence is concerned, six Board members have their permanent residence in Cyprus, two in the USA, four in Greece, one in Egypt and two in the UK. The Group focuses on fostering diversity and inclusion awareness through workshops, training and development programs in the various regions. The results of diversity promotion in 2021 are published in the ESG Performance review and statements, table 2.2 Focus area growth enabling work environment." And: "Human Resources, Diversity and Inclusion Cement companies, including ΤΙΤΑΝ face a multitude of potential risks related to their human resources and talent management. Existing processes to recruit, develop and retain talented individuals and promote their mobility may not be sufficient, thus potentially giving rise to risks of employee and management attrition, difficulties in succession planning, and an inadequate pipeline of future talent, potentially impeding the continued realization of high operational performance and future growth. Moreover, success in enforcing its Human Rights and Diversity and Inclusion policies is increasingly crucial in determining how the Group is perceived by key stakeholders, such as current and prospective employees, consumers, and investors. Greater diversity in the Group’s human capital increases the likelihood of innovation that contributes to business growth, and higher degrees of inclusion foster better employee engagement, productivity, and company loyalty, resulting in higher talent retention rates and overall employee engagement. ΤΙΤΑΝ is actively pursuing a rich agenda of actions to develop its talent management, including the updating and diffusion of its relevant HR policies (such as its Human Rights and Diversity and Inclusion policies) and people development processes. Relevant measures pursued include employee surveys, focus groups for feedback, training and capability-building programs, adoption of Diversity and Inclusion global best practices, provision of ubiquitous access to the TITAN Group reporting platform EthicsPoint®, and the fostering of a continuous dialogue on industrial relations with all relevant stakeholders." Source of the above: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages 63, 64, and 76. Also, The areas of Human Rights were investigated for the importance to TITAN's operations across the BUs, during the process of Materiality Assessment on Group level and - separately - on BU level, which was concluded in 2020-2021. Source : https://www.titan-cement.com/TITAN_Cement_Group_IAR_2020_EN.pdf, see page 112.4. 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?
Optional commentSee the below references in the TITAN IAR 2021: "Human Resources, Diversity and Inclusion Cement companies, including ΤΙΤΑΝ face a multitude of potential risks related to their human resources and talent management. Existing processes to recruit, develop and retain talented individuals and promote their mobility may not be sufficient, thus potentially giving rise to risks of employee and management attrition, difficulties in succession planning, and an inadequate pipeline of future talent, potentially impeding the continued realization of high operational performance and future growth. Moreover, success in enforcing its Human Rights and Diversity and Inclusion policies is increasingly crucial in determining how the Group is perceived by key stakeholders, such as current and prospective employees, consumers, and investors. Greater diversity in the Group’s human capital increases the likelihood of innovation that contributes to business growth, and higher degrees of inclusion foster better employee engagement, productivity, and company loyalty, resulting in higher talent retention rates and overall employee engagement. ΤΙΤΑΝ is actively pursuing a rich agenda of actions to develop its talent management, including the updating and diffusion of its relevant HR policies (such as its Human Rights and Diversity and Inclusion policies) and people development processes. Relevant measures pursued include employee surveys, focus groups for feedback, training and capability-building programs, adoption of Diversity and Inclusion global best practices, provision of ubiquitous access to the TITAN Group reporting platform EthicsPoint®, and the fostering of a continuous dialogue on industrial relations with all relevant stakeholders." Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 76. And: "Diversity and inclusion are also identified as priorities for the Group, and are important for the business and for key stakeholders, including suppliers, customers and local communities in addition to employees. We seek to maintain an environment where everyone has a strong sense of belonging and inclusion, preserving ethnic diversity and not to tolerate discrimination, bullying or harassment. Our Diversity, Equity and Inclusion Policy was approved by the Group Executive Committee in 2021 and launched in 2022." Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 94.5. Who receives training for the following human rights issues?
Optional commentSee inside the TITAN IAR 2021 for the implementation of Training programs for Compliance (including the Human Rights Policy) which have complete coverage for TITAN's employees: "Compliance Program and Group Policies Compliance risks are proactively addressed at Group level through the TITAN Group Compliance Program, an integrated system of relevant activities, mechanisms and controls that aim to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated. The Compliance Program reinforces compliance culture, ensures adherence to compliance requirements and fosters ethical behavior. The set of Code of Conduct and Group Policies, applicable to all TITAN Group operations, covers all strategic areas and provides guidelines to employees and external business collaborators (i.e. vendors, customers), to ensure compliance with the applicable internal and statutory rules. Group Policies include, but are not limited to, Anti-Bribery and Corruption, Conflict of Interest, Competition Law, Sanctions, Corporate Social Responsibility, Whistleblowing, Environmental and Climate mitigation, Protection of Personal Data, Human Rights, Occupational Health and Safety. All TITAN Group employees have free and unrestricted access to the Group Policies, which are available on the Group Policies Repository in the Group Intranet. A separate section offers translations of Group policies in all local languages. Group policies are also communicated to our internal and external stakeholders through our website (https://www.titan-cement.com/about-us/ corporate-governance/group-policies). Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 94. See also pages 39 and 74.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Optional commentSee inside the TITAN IAR 2021: Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages 30 and 31 (for TITAN Group Targets), and 77 and 94 (for the Compliance program of TITAN).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)?
Optional commentNo cases were reported in the reporting period related (directly or indirectly) to adverse impact(s), associated with the issue of 'Rights of women and/or girls', and which could have been caused by the operations of TITAN. More information is provided about the different incidents which were recorded by implementing the Whistleblowing Policy and framework, and the EthcisPoint platform. Also the fines and penalties paid (and other, non-monetary sanctions). In no case we had (directly or indirectly) cases of adverse impacts to the Rights of women and girls' See references below: Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 95: "The EthicsPoint platform, a uniform, anonymous and strictly confidential channel for reporting incidents of non-compliance, reiterates TITAN’s openness and transparency, safeguarding good governance and integrity. The platform, to which all Group employees have free access, ensures that incidents are reported, examined and resolved with a remedy plan when necessary. A five-member Supervisory Committee at Group level, including the Chairman of the Audit and Risk Committee, oversees the investigation and handling of reports, ensuring confidentiality and non-retaliation for whistleblowers. In 2021, 11 cases in total were reported through the EthicsPoint platform, 10 of which were classified as allegations and one as an Inquiry - complaint (see ESG performance statements 2021 for more details)." More details are found: In page 124, Table 'Good Governance, Transparency and Business Ethics', in specific see the information under Note 3. In page 128, Table 2.5.5 'Political contributions and Fines and other non-monetary sanctions', in specific see the information under Note 2. Also see page 134, for Criteria 3-5, and page 135, for Criteria 6-8.8. 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.
See inside the TITAN IAR 2021: "Commitment to human rights Consistent with the United Nations Guiding Principles on Business and Human Rights, TITAN is committed to respecting and supporting human rights with regard to its employees, the communities where it operates and its business partners. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. To intensify our efforts to ensure compliance not only with regulatory but also with ESG requirements, and to ensure a responsible supply chain, a comprehensive Third-Party Due Diligence system, supported by an online tool, was developed in 2021 and is ready to be put into operation. Our Whistleblowing Policy, introduced in 2020, encourages employees to report possible misconduct, fraud or abuse. In parallel, EthicsPoint, the Group reporting platform launched in 2020, provides a uniform, anonymous and strictly confidential channel, through a globally available digital tool, to facilitate the confidential reporting of any concern and ensure that incidents are reported, examined and resolved with a remedy plan, if and when necessary, thus fostering a culture of integrity and ethical conduct." Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 39. And: "Human rights is a material issue for employees and TITAN suppliers, local communities, but also regulators and civil society organizations. TITAN Group is committed to respecting fundamental human and labor rights, in full alignment with international norms and standards in all operations. Accordingly, an overview of potential risks to be addressed both in the workplace and in the supply chain is an integral part of the materiality assessment process that covers all countries in which the Group currently operates. As a follow up, a country-specific risk assessment is planned for 2022, as there are considerable differences in the enforcement of international human rights norms from country to country. A certain priority for the Group is the protection of labor rights and safe working conditions among contractors’ employees, particularly under the extraordinary conditions of COVID-19. We have not identified consequences in the areas of environment, human rights or/and anti-bribery and corruption compared to the pre-pandemic period. We measure the progress on these objectives through a set of key performance indicators, corresponding to advanced criteria which satisfy the Communication on Progress requirements of the UN Global Compact Network. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. The set of commitments, are clearly articulated in the TITAN Group Human Rights Policy. Among the practices that are strictly prohibited are forced labor (including slave labor), human trafficking, and inhumane treatment of workers, child labor and discrimination. The TITAN Group Procurement Policy, released in 2021, clearly sets as a prerequisite for our suppliers to comply with all laws and regulations and respect human and labor rights in their business activities, and to establish a safe working environment. Contractual clauses embedded in contracts describe in detail the above requirements. Diversity and inclusion are also identified as priorities for the Group, and are important for the business and for key stakeholders, including suppliers, customers and local communities in addition to employees. We seek to maintain an environment where everyone has a strong sense of belonging and inclusion, preserving ethnic diversity and not to tolerate discrimination, bullying or harassment. Our Diversity, Equity and Inclusion Policy was approved by the Group Executive Committee in 2021 and launched in 2022. Intensifying our efforts to ensure compliance not only with regulatory but also with ESG requirements, a comprehensive Third-Party Due Diligence system, supported by an online tool, was fully developed in 2021 and is ready to be put in operation. The objective is to provide across the Group the possibility for effective, fast, reliable and efficient due diligence, through a risk-based selection of counterparties, providing adequate assurance and ongoing monitoring over sanctions risks, ESG risks, other regulatory concerns and reputational risks. The EthicsPoint platform, a uniform, anonymous and strictly confidential channel for reporting incidents of non-compliance, reiterates TITAN’s openness and transparency, safeguarding good governance and integrity. The platform, to which all Group employees have free access, ensures that incidents are reported, examined and resolved with a remedy plan when necessary. A five-member Supervisory Committee at Group level, including the Chairman of the Audit and Risk Committee, oversees the investigation and handling of reports, ensuring confidentiality and non-retaliation for whistleblowers. In 2021, 11 cases in total were reported through the EthicsPoint platform, 10 of which were classified as allegations and one as an Inquiry - complaint (see ESG performance statements 2021 for more details)." Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages 94 and 95.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentThe reference documents are the below: - TITAN Group Human Rights Policy (2020), which covers the areas: Freedom of association and the effective recognition of the right to collective bargaining, Forced labour, and Child labour (among many others). More input: Our Human Rights policy establishes a framework for protecting and advancing human rights, both in our work and in our sphere of influence. Respect for human rights is one of TITAN’s core values, as reflected in our Code of Conduct. Our policy is guided by the principles in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights. The policy aims to raise awareness on human rights issues and ensure the commitment of all TITAN employees to the protection of human rights throughout the Group. Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Human-Rights-Policy-September-2020.pdf - TITAN Group Diversity, Equity and Inclusion Policy (2022), which covers the area: About Non-discrimination in respect of employment and occupation: More input: Our Diversity, Equity and Inclusion (DE&I) Policy sets out TITAN Group’s principles, definitions, scope and approach to diversity and inclusion. At TITAN, we recognize that achieving our aspirations for DE&I in the work we do and the way we work is an on-going process that requires awareness, action, responsibility and accountability from everyone in our business. Depicting our commitment to creating an environment where all differences are valued and where everyone has the opportunity to flourish and experience a sense of belonging, the Policy applies to all employees of TITAN Group, while it is expected to also be applied by our partners and business associates. And: - TITAN Group Occupational Health and Safety (2020), which covers all OHS matters. More input: Our Health & Safety policy aims to achieve a healthy work environment free of incidents, injuries and accidents for all of our direct and indirect employees. It is aligned with all applicable laws and directives where TITAN is active. At TITAN, Health and Safety is managed as an integrated system of goals with clear responsibilities and accountabilities. Our aim is to continuously improve and create an environment where every TITAN employee is responsible for their own and their colleagues’ safety. TITAN’s (Occupational) Health & Safety policy also includes sharing our know-how with stakeholders, suppliers, contractors and third parties to adopt similar health and safety policies. Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-HS-Policy-March-2020.pdf1.1. For each labour rights policy, is it:
Optional commentWe have referenced under the Question 1 (above) the Policies: - TITAN Group Human Rights Policy (2020), which covers the areas of Freedom of Asociation and the effective recognition of the right to Collective Bargaining, Forced labour, and Child labour (among many others). Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Human-Rights-Policy-September-2020.pdf And: - TITAN Group Diversity, Equity and Inclusion Policy (2022), which covers the areas about Non-discrimination in respect of Employment and Occupation. And: - TITAN Group Occupational Health and Safety (2020), which also covers the areas of Occupational Safety and Health for Suppliers (including Contractors), Customers and other Business Partners. Source: https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-HS-Policy-March-2020.pdf We add here the reference to an additional source of Policy alignment: - TITAN Group Procurement Policy (2021), which covers the areas of: Forced labour, Child labour, and Non-discrimination in respect of employment and occupation. More input: Our Procurement Policy establishes a framework for the fundamental principles governing procurement, which TITAN Group employees must follow and suppliers are expected to be aligned with, when engaged in procurement activities involving the Group. Our key objective through the procurement of goods and services is to meet all the needs of our plants and operating units with a view to optimizing the cost, improving the competitiveness of TITAN Group, and enhancing our commitment of being a socially responsible, ethical and environmentally sensitive business organization. Source: https://www.titan-cement.com/wp-content/uploads/2021/09/Group-Procurement-Policy_July-2021.pdfPrevention
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?
Optional commentAreas of TITAN's efforts are (among the most important): - Trainings of TITAN employees (in areas of Health and Safety, Human Rights, and Diversity, Equity an Inclusion. - Collective Bargain Agreement with Trade Unions (Workers Unions) - On-going, open dialogue with TITAN employees and contractors for continuous improvement on matters around Occupational Health & Safety conditions in the workplace - Development of a framework of assessing ESG risks and enforcing ESG Criteria for the prequalification and systematic assessment of Suppliers and Contractors. Human Rights and Labor Rights are inherent to the TITAN approach to the ESG Criteria.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?
Optional commentWe provide explanation and additional information about our answer under 'Other' for the specific area 'Occupational safety and health': - Sectoral initiatives of TITAN for Occupational Safety and Health: TITAN is a founding and active member and contributor to the below collaborative initiatives on international and European level, which promote the enforcement of guidance frameworks for measuring and reporting on H&S and improving performance overtime : - Global Cement and Concrete Association (GCCA) - European Cement Association (Cembureau) - About the GCCA, the Association has developed the "GCCA Sustainability Guidelines for the monitoring and reporting of safety in cement and concrete manufacturing (edition 2020)" since 2019, taking over the role and legacy work areas of the WBCSD/CSI which was active until 2018. The above Guidelines, complemented by the documents of: (a) “GCCA Recommended good practices for contractor safety“, Oct 2016, (b) "GCCA Health Management Handbook" focusing on dust and noise, and (c) "GCCA Road Safety Handbook", constitute the basis of good reference and framework of the compliance for Health and Safety performance monitoring and reporting for cement and concrete companies (sectoral approach). - Source for the Guidelines and more info is provided here, in the web site of GCCA: https://gccassociation.org/sustainability-innovation/sustainability-charter-and-guidelines/#:~:text=GCCA%20Sustainability%20Guidelines%20The%20GCCA%20sustainability%20guidelines%20include,shall%20have%20their%20data%20verified%20and%20reported%20publicly. And: https://gccassociation.org/wp-content/uploads/2020/03/GCCA_Guidelines_Safety_V1.0_Feb2020.pdf4. Who receives training for the following labour rights issues?
5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentCommitment to human rights Consistent with the United Nations Guiding Principles on Business and Human Rights, TITAN is committed to respecting and supporting human rights with regard to its employees, the communities where it operates and its business partners. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. To intensify our efforts to ensure compliance not only with regulatory but also with ESG requirements, and to ensure a responsible supply chain, a comprehensive Third-Party Due Diligence system, supported by an online tool, was developed in 2021 and is ready to be put into operation. Our Whistleblowing Policy, introduced in 2020, encourages employees to report possible misconduct, fraud or abuse. In parallel, EthicsPoint, the Group reporting platform launched in 2020, provides a uniform, anonymous and strictly confidential channel, through a globally available digital tool, to facilitate the confidential reporting of any concern and ensure that incidents are reported, examined and resolved with a remedy plan, if and when necessary, thus fostering a culture of integrity and ethical conduct. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 39. And: The EthicsPoint platform, a uniform, anonymous and strictly confidential channel for reporting incidents of non-compliance, reiterates TITAN’s openness and transparency, safeguarding good governance and integrity. The platform, to which all Group employees have free access, ensures that incidents are reported, examined and resolved with a remedy plan when necessary. A five-member Supervisory Committee at Group level, including the Chairman of the Audit and Risk Committee, oversees the investigation and handling of reports, ensuring confidentiality and non-retaliation for whistleblowers. In 2021, 11 cases in total were reported through the EthicsPoint platform, 10 of which were classified as allegations and one as an Inquiry - complaint (see ESG performance statements 2021 for more details)”. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 95.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentSource: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 124 (KPI)7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentSource: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 124 (KPI 5.13)8. In the course of the reporting period, what was the percentage of women in:
Optional commentFor: Senior leadership level position, the source is: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 110 (KPI 2.73). For: Non-executive board, the source is: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 37.9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentIt refers to Lost Time Injuries Frequency Rate (LTIFR) for TITAN employees in 2021. TITAN follows the Global Cement and Concrete Association (GCCA) Sustainability Framework Guidelines, and the Sustainability Guidelines for the monitoring and reporting of safety in cement and concrete manufacturing (last edition in February 2020). This document has been agreed within the GCCA to have extended application to concrete and other related activities. Source for the GCCA Guidelines: https://gccassociation.org/sustainability-innovation/sustainability-charter-and-guidelines/ In more specific for the Sustainability Guidelines for the monitoring and reporting of safety in cement and concrete manufacturing: https://gccassociation.org/wp-content/uploads/2020/03/GCCA_Guidelines_Safety_V1.0_Feb2020.pdf (For reference only, the UNCTAD/IAR Guidance provides: C.3.2. Frequency/incident rates of occupational injuries - Frequency rates: number of new injury cases divided by total number of hours worked by workers in the reporting period; - Incident rates: total number of lost days expressed in terms of number of hours divided by total number of hours worked by workers in the reporting period)11. In the course of the reporting period, what was the company’s incident rate?
Optional commentIt refers to Lost Time Injuries Severity Rate (LTISR) for TITAN employees in 2021. TITAN follows the Global Cement and Concrete Association (GCCA) Sustainability Framework Guidelines, and the Sustainability Guidelines for the monitoring and reporting of safety in cement and concrete manufacturing (last edition in February 2020). This document has been agreed within the GCCA to have extended application to concrete and other related activities. Source for the GCCA Guidelines: https://gccassociation.org/sustainability-innovation/sustainability-charter-and-guidelines/ In more specific for the Sustainability Guidelines for the monitoring and reporting of safety in cement and concrete manufacturing: https://gccassociation.org/wp-content/uploads/2020/03/GCCA_Guidelines_Safety_V1.0_Feb2020.pdf (For reference only, the UNCTAD/IAR Guidance provides: C.3.2. Frequency/incident rates of occupational injuries - Frequency rates: number of new injury cases divided by total number of hours worked by workers in the reporting period; - Incident rates: total number of lost days expressed in terms of number of hours divided by total number of hours worked by workers in the reporting period)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?
Optional commentIn 2021, 11 cases in total were reported through the EthicsPoint platform, ten of which were classified as allegations and one as an Inquiry (complaint). Of the ten (10) cases classified inside the TITAN EthicsPoint as allegations, nine (9) cases were thoroughly examined by the respective regional committees and reviewed by the Group Supervisory Committee, while one (1) case is still in process of examining. Out of these nine (9) cases, two (2) were found fully substantiated, one (1) was partially substantiated and six (6) were unsubstantiated. For each of the substantiated cases an action plan for remediation was implemented. In more specific, the cases with action plans related to the areas of 'Environment, Health & Safety’, and ‘People, Diversity and Workplace Respect'. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 124.13. 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.
Commitment to human rights Consistent with the United Nations Guiding Principles on Business and Human Rights, TITAN is committed to respecting and supporting human rights with regard to its employees, the communities where it operates and its business partners. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. To intensify our efforts to ensure compliance not only with regulatory but also with ESG requirements, and to ensure a responsible supply chain, a comprehensive Third-Party Due Diligence system, supported by an online tool, was developed in 2021 and is ready to be put into operation. Our Whistleblowing Policy, introduced in 2020, encourages employees to report possible misconduct, fraud or abuse. In parallel, EthicsPoint, the Group reporting platform launched in 2020, provides a uniform, anonymous and strictly confidential channel, through a globally available digital tool, to facilitate the confidential reporting of any concern and ensure that incidents are reported, examined and resolved with a remedy plan, if and when necessary, thus fostering a culture of integrity and ethical conduct. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 39. And: Human rights is a material issue for employees and TITAN suppliers, local communities, but also regulators and civil society organizations. TITAN Group is committed to respecting fundamental human and labor rights, in full alignment with international norms and standards in all operations. Accordingly, an overview of potential risks to be addressed both in the workplace and in the supply chain is an integral part of the materiality assessment process that covers all countries in which the Group currently operates. As a follow up, a country-specific risk assessment is planned for 2022, as there are considerable differences in the enforcement of international human rights norms from country to country. A certain priority for the Group is the protection of labor rights and safe working conditions among contractors’ employees, particularly under the extraordinary conditions of COVID-19. We have not identified consequences in the areas of environment, human rights or/and anti-bribery and corruption compared to the pre-pandemic period. We measure the progress on these objectives through a set of key performance indicators, corresponding to advanced criteria which satisfy the Communication on Progress requirements of the UN Global Compact Network. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. The set of commitments, are clearly articulated in the TITAN Group Human Rights Policy. Among the practices that are strictly prohibited are forced labor (including slave labor), human trafficking, and inhumane treatment of workers, child labor and discrimination. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 94.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentThe policy can be found to the following link https://www.titan-cement.com/wp-content/uploads/2021/09/TITAN-Group-Environmental-Policy-June-2018.pdf1.1. For each environmental policy, is it:
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?
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?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
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)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentScope 1 10490000t Scope 2 792000t Scope 3 1573000t7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
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):
Water consumption (volume of water in megaliters):
Optional commentAlthough total consumed quantities are available, quantities per category are not currently available to be reported.13. Please provide details about the company’s water intensity of products 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).
15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Optional commentAll the above are implemented according to the Rehabilitation Plans and the Biodiversity Management Plans at our Group Quarries. Although total restored areas are available, sub-totals per category are not available.Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
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.
Addressing climate change remained at the top of our sustainability agenda, as we were among the first cement companies worldwide with decarbonization targets validated by the Science Based Targets initiative (SBTi). Ahead of COP26, we signed the “Business Ambition for 1.5°C” Commitment letter, joining a number of leading companies seeking to keep warming to 1.5°C and reach net-zero emissions by 2050. To improve our disclosure of climate-related risks, we started implementing the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). And we were recognized by the CDP as a global climate leader for our transparency and actions to mitigate climate change and transition to a net-zero economy. Our net CO₂ emissions declined in line with our 2030 goals, as we ramped up our consumption of alternative fuels and accelerated the transition to greener products. The investment for a pre-calciner at our Kamari plant in Greece, which will enable the utilization of greater quantities of waste-derived fuels, is progressing according to schedule. Meanwhile, since September, approximately half of Titan America’s cement output consists of the lower-carbon Type IL cement. We continued to invest in innovation and to contribute to the activities of the Innovandi research network of the Global Cement and Concrete Association (GCCA). We evaluated a number of novel decarbonization and carbon capture and utilization technologies, and we experimented with the use of hydrogen as a fuel enhancer in our process in Greece and Bulgaria. On the other side of the Atlantic, we commissioned the world’s first industrial-scale plant to reclaim, dry and electrostatically separate landfilled fly ash.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional comment(TITAN Group) Compliance Program and Group Policies Compliance risks are proactively addressed at Group level through the TITAN Group Compliance Program, an integrated system of relevant activities, mechanisms and controls that aim to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated. The Compliance Program reinforces compliance culture, ensures adherence to compliance requirements and fosters ethical behavior. The set of Code of Conduct and Group Policies, applicable to all TITAN Group operations, covers all strategic areas and provides guidelines to employees and external business collaborators (i.e. vendors, customers), to ensure compliance with the applicable internal and statutory rules. Group Policies include, but are not limited to, Anti-Bribery and Corruption, Conflict of Interest, Competition Law, Sanctions, Corporate Social Responsibility, Whistleblowing, Environmental and Climate mitigation, Protection of Personal Data, Human Rights, Occupational Health and Safety. All TITAN Group employees have free and unrestricted access to the Group Policies, which are available on the Group Policies Repository in the Group Intranet. A separate section offers translations of Group policies in all local languages. Group policies are also communicated to our internal and external stakeholders through our website (https://www.titan-cement.com/about-us/ corporate-governance/group-policies) Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 942. 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 commentTITAN GROUP POLICIES Our strategy is driven by our aspiration to do the right thing. To ensure that we conduct our business with respect, accountability and responsibility, we have developed the TITAN Group Code of Conduct, which provides the framework of the core operating principles guiding our daily business, and a series of group-wide policies that help every person at TITAN make the right decisions. You can find out more about our aims through our Code of Conduct and our policies, below. Anti-Bribery and Corruption policy Our Anti-Bribery and Corruption policy aims to ensure compliance with the respective rules prohibiting bribery and corruption. The policy applies to all TITAN Group employees, representatives and agents, all of whom are expected to follow the highest standards of professional and personal conduct at all times. Dealing with a range of issues related to bribery and corruption, our policy complies with all applicable laws and contains TITAN Group’s global standards. TITAN complies with all applicable anti-bribery laws, including the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and the local laws in every country in which we do business. Source: https://www.titan-cement.com/about-us/corporate-governance/group-policies/Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentTITAN Group’s Compliance Program and business ethics A TITAN Group Compliance Program has been in place since 2020, as an integrated system of activities, mechanisms and controls, aiming to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated, so that the possibility of a significant compliance failure is minimized. The Compliance Program facilitates the effort to maintain and foster a strong compliance culture, ensuring adherence to compliance requirements and promoting consistent and responsible ethical behavior. It is a risk-based program with dynamic elements and incorporates monitoring and oversight, compliance awareness, training, risk assessment and third-party due diligence components. Consistent with our values and culture, and as clearly articulated in the TITAN Code of Conduct and relevant Group Policies, the Group follows a zero-tolerance approach towards bribery, fraud and any other corruptive practice. The Anti-Fraud Program Framework was developed during 2021 and widely communicated throughout the Group promoting openness and transparency, providing standards and guidelines, and clarifying roles, expectations and responsibilities on the subject of occupational fraud. TITAN launched in 2021 the second phase of its “Group Policies Awareness” program, with the aim to raise awareness and understanding around our Code of Conduct and the set of Sustainability and Social Responsibility Policies – the tools that foster ethical behavior and represent “Our Culture in Practice”. 8,974 Compliance training hours completed in 2021. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, page: 39 And: About our approach for the 'Regulatory compliance risk' The Group is subject to many local and international laws and regulations, including those related to competition law, corruption, and fraud, across many jurisdictions of operation and is therefore exposed to changes to those laws and regulations and to the outcome of investigations conducted by governmental, international or other regulatory authorities. Potential breaches of local and international laws and regulations in the areas of competition law, corruption, and fraud, among others, could result in the imposition of significant fines and/ or sanctions for non-compliance, and may inflict reputational damage. Compliance risks are proactively addressed at Group level through the TITAN Group Compliance Program, an integrated system of relevant activities, mechanisms and controls, aiming to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated. The Compliance Program reinforces compliance culture, ensures adherence to compliance requirements, and fosters ethical behaviour. Moreover, all operations are continuously monitored at local and Group level by the Group Legal and Group Internal Audit, Risk and Compliance departments. Also, relevant reports provided by experts and independent organizations such as Transparency International, are taken in account. The set of Code of Conduct and Group Policies, applicable to all TITAN Group operations, cover all strategic areas and provide guidelines to employees and external business collaborators for compliance with the applicable internal and statutory rules. Such Group Policies include but are not limited to Anti-Bribery and Corruption, Conflict of Interest, Competition Law, Sanctions, Corporate Social Responsibility, Whistleblowing, Environmental and Climate mitigation, Protection of Personal Data, Human Rights, Occupational Health and Safety. Regular training of employees is conducted to ensure that the Group’s Code of Conduct and relevant Group Policies are effectively adhered to. All employees also have free and unrestricted access to the Group Policies, which have been uploaded on the Group Intranet and on our website (https://www.titan-cement.com/about-us/ corporate-governance/group-policies). Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page: 77 And: Compliance Program and Group Policies Compliance risks are proactively addressed at Group level through the TITAN Group Compliance Program, an integrated system of relevant activities, mechanisms and controls that aim to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated. The Compliance Program reinforces compliance culture, ensures adherence to compliance requirements and fosters ethical behavior. The set of Code of Conduct and Group Policies, applicable to all TITAN Group operations, covers all strategic areas and provides guidelines to employees and external business collaborators (i.e. vendors, customers), to ensure compliance with the applicable internal and statutory rules. Group Policies include, but are not limited to, Anti-Bribery and Corruption, Conflict of Interest, Competition Law, Sanctions, Corporate Social Responsibility, Whistleblowing, Environmental and Climate mitigation, Protection of Personal Data, Human Rights, Occupational Health and Safety. All TITAN Group employees have free and unrestricted access to the Group Policies, which are available on the Group Policies Repository in the Group Intranet. A separate section offers translations of Group policies in all local languages. Group policies are also communicated to our internal and external stakeholders through our website (https://www.titan-cement.com/about-us/ corporate-governance/group-policies). Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 94 And: A key hallmark of the TITAN Group Compliance Program is awareness, training and continuous advice, as we consider it imperative that our people are adequately informed and supported in this continuous effort. To this end, the second phase of the TITAN Group Policies Awareness Program, comprising e-learnings, and assessment tests for the Code of Conduct and the set of Sustainability and Social Responsibility Policies, was implemented during 2021. The e-learnings were assigned to the general population through the learning management system platform and during the year around 1,500 employees took part in 6,400 training hours in total. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 943.1. How often is such training provided?
Optional commentTITAN's practices for providing Training on Compliance matters is a continuous (annual) effort. See references above, under Question 3. Group policies and Code of Conduct To ensure that we conduct our business with respect, accountability and responsibility, we have developed our Code of Conduct and Group Policies, applicable to all Group operations, which cover all strategic areas and provide guidelines to employees and external business collaborators, to ensure compliance with the applicable internal and statutory rules. Group Policies include, but are not limited to, Anti-Bribery and Corruption, Conflict of Interest, Competition Law, Sanctions, Corporate Social Responsibility, Whistleblowing, Environmental and Climate mitigation, Protection of Personal Data, Human Rights, Occupational Health and Safety. In 2021, we launched a new Procurement policy and at the beginning of 2022, we launched a new Diversity, Equity and Inclusion policy. All our policies are available on the Group corporate website (https:// www.titan-cement.com/about-us/corporate-governance/grouppolicies/). Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages: 35 and 38. And: TITAN Group’s Compliance Program and business ethics A TITAN Group Compliance Program has been in place since 2020, as an integrated system of activities, mechanisms and controls, aiming to provide adequate assurance that compliance risks are timely identified, properly assessed and effectively mitigated, so that the possibility of a significant compliance failure is minimized. The Compliance Program facilitates the effort to maintain and foster a strong compliance culture, ensuring adherence to compliance requirements and promoting consistent and responsible ethical behavior. It is a risk-based program with dynamic elements and incorporates monitoring and oversight, compliance awareness, training, risk assessment and third-party due diligence components. Consistent with our values and culture, and as clearly articulated in the TITAN Code of Conduct and relevant Group Policies, the Group follows a zero-tolerance approach towards bribery, fraud and any other corruptive practice. The Anti-Fraud Program Framework was developed during 2021 and widely communicated throughout the Group promoting openness and transparency, providing standards and guidelines, and clarifying roles, expectations and responsibilities on the subject of occupational fraud. TITAN launched in 2021 the second phase of its “Group Policies Awareness” program, with the aim to raise awareness and understanding around our Code of Conduct and the set of Sustainability and Social Responsibility Policies – the tools that foster ethical behavior and represent “Our Culture in Practice”. 8,974 Compliance training hours reported for 2021. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages: 39. And: About Suppliers, Contractors and Business Partners: To empower our business ecosystems to incorporate sustainability considerations in their business decisions and daily behaviors, a Sustainable Supply Chain Roadmap was developed with specific milestones to ensure that 70% of our key suppliers meet TITAN ESG Supplier standards by 2025. As a first step and in line with the roadmap, our first TITAN Group Procurement Policy was published, laying down the fundamental principles governing procurement, incorporating practices that enhance our commitment to be a socially responsible, ethical and environmentally sensitive enterprise. Our efforts to engage with our suppliers on climate change have been recognized by CDP with an “A-” score in the CDP Supplier Engagement rating, which is in the Leadership band of CDP. At current we do not have a process in place to for the Trainings on Anti-corruption and Integrity, for our Contractors and Suppliers in general, our Clients, and other Business Parties. Any such guidance and training is provided 'ad hoc', and not systematically or horizontally across our BUs' operations.4. Does the company monitor its anti-corruption compliance programme?
Optional commentIntensifying our efforts to ensure compliance not only with regulatory but also with ESG requirements, a comprehensive Third-Party Due Diligence system, supported by an online tool, was fully developed in 2021 and is ready to be put in operation. The objective is to provide across the Group the possibility for effective, fast, reliable and efficient due diligence, through a risk-based selection of counterparties, providing adequate assurance and ongoing monitoring over sanctions risks, ESG risks, other regulatory concerns and reputational risks. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see pages 94 and 95 And: TITAN has in place a process for annual performance appraisal of employees, where - in a manner of assessing the adherence of business conduct and promotion of TITAN's ethics behavior, through specific cases which are corporate/business related - each appraised employee receives feedback, guidance and plans for his/her correction and improvement.Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting 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?
Optional commentCommitment to human rights Consistent with the United Nations Guiding Principles on Business and Human Rights, TITAN is committed to respecting and supporting human rights with regard to its employees, the communities where it operates and its business partners. Human rights is one of the key subject areas of the TITAN Group Compliance Program, which provides a well-structured framework to address relevant activities in a disciplined and holistic way across the Group. To intensify our efforts to ensure compliance not only with regulatory but also with ESG requirements, and to ensure a responsible supply chain, a comprehensive Third-Party Due Diligence system, supported by an online tool, was developed in 2021 and is ready to be put into operation. Our Whistleblowing Policy, introduced in 2020, encourages employees to report possible misconduct, fraud or abuse. In parallel, EthicsPoint, the Group reporting platform launched in 2020, provides a uniform, anonymous and strictly confidential channel, through a globally available digital tool, to facilitate the confidential reporting of any concern and ensure that incidents are reported, examined and resolved with a remedy plan, if and when necessary, thus fostering a culture of integrity and ethical conduct. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 39. And: The EthicsPoint platform, a uniform, anonymous and strictly confidential channel for reporting incidents of non-compliance, reiterates TITAN’s openness and transparency, safeguarding good governance and integrity. The platform, to which all Group employees have free access, ensures that incidents are reported, examined and resolved with a remedy plan when necessary. A five-member Supervisory Committee at Group level, including the Chairman of the Audit and Risk Committee, oversees the investigation and handling of reports, ensuring confidentiality and non-retaliation for whistleblowers. In 2021, 11 cases in total were reported through the EthicsPoint platform, 10 of which were classified as allegations and one as an Inquiry - complaint (see ESG performance statements 2021 for more details)”. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, see page 95, and page 124 (KPI 124 and respective Notes).7. Does your company engage in Collective Action against corruption?
Optional commentReference: UNGC - Anti-Corruption Call to Action Source: https://www.unglobalcompact.org/take-action/action/anti-corruption-call-to-action Explanation: TITAN Group is a signatory since 2015. The document of "Call to Action" is available in the website of the UNGC Anti-Corruption Call to Action.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.
TITAN Group is an active participant in global collaborative initiatives and international organizations, aiming to contribute to the shaping of the sustainable world of tomorrow. We have aligned our strategy and operations with the Ten Principles on human rights, labor, environment and anti-corruption; and take strategic actions to advance the UN Sustainable Development Goals (SDGs), with an emphasis on collaboration and innovation. We submit annually the UNGC Communication on Progress (CoP) at an advanced level, providing valuable information with transparency to our stakeholders. As reported for closing of 2021: Anti-bribery and corruption Bribery and corruption constitute a threat for businesses and societies across the world, one that impairs ethical values, enables crime and illegal activity, undermines equal opportunities in doing business and imposes a huge financial cost on societies. Consistent with our values and culture, and as clearly articulated in the TITAN Code of Conduct and relevant Group Policies, the Group follows a zero-tolerance approach towards bribery, fraud and any other corruptive practice. All initiatives and efforts to fight corruption are supported by and effected through a strong organizational structure that sets clear roles and responsibilities and provides increased assurance for good governance and solid ESG performance. The Audit and Risk Committee, a Board Committee comprised by non-executive, independent board members, is delegated to oversee, among others, the risk of corruption and fraud. The Group Compliance and Anti-Fraud Department, as part of the Group Internal Audit, Risk and Compliance Department, maintains the overall responsibility to monitor compliance risks and to coordinate relevant controlling activities, in cooperation with management and the Legal Department. Our Anti-Bribery and Corruption Policy sets forth principles, rules and responsibilities, specifies high-risk areas in which bribery and corruption may most often occur during business activities and provides guidance for preventive and detective procedures, including the performance of risk assessment activities and due diligence of third parties who perform services for or on behalf of TITAN Group. The TITAN Group Anti-Fraud Program sets out our strategic priorities and efforts to deter and detect occupational fraud and corruption throughout the Group, aiming to provide a protection shield for assets and resources, corporate reputation and credibility, cultural strengths and operational efficiency. A comprehensive structure of anti-fraud initiatives and controls is deployed, contributing to the prevention and detection of occupational fraud as well as the response of the Group in such event. Responding to the need for enhanced anti-fraud awareness, the Anti-Fraud Program Framework was developed during 2021 and widely communicated throughout the Group. The Framework promotes openness and transparency, provides standards and guidelines, and clarifies roles, expectations and responsibilities on the subject of occupational fraud. Among preventive actions, the Fraud Risk Assessment projects, conducted in risk areas, aim to identify and remediate potential gaps and weaknesses in the applied anti-fraud preventive controls, through consistent and effective action plans. Source: https://www.titan-cement.com/TITAN_Cement_Group_IAR_2021_EN.pdf, pages 93 and 94.