Report - COP Prototype

2022 Communication on Progress

Societe Tunisienne de Banque

Published date

June 28, 2022

No. of questions

Supplemental files

CEO Statement

Signed

Governance

Policies and Responsibilities

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

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

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

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

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

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

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

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

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

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Prevention

6. Does the company have a process or processes to assess risk?

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

Optional comment

In line with the United Nations' Sustainable Development Goals (SDGs), STB believes that healthy economic growth should not be achieved at the expense of inclusive societal prosperity, environmental protection or decent working conditions. STB undertakes to adopt an environmental and social policy that is articulated both around the framework of its business lines, as well as its own management. STB is committed to implementing an environmental and social risk management system to take into consideration : -the environmental and social aspect and risks in financing decisions. - investments aimed at environmental protection -the financial inclusion

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

Concerns and grievance mechanisms

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

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

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

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

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

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

Executive Pay

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

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 (#)	11
Male (%)	82
Female (%)	18
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	45
Above 50 years old (%)	55
From minority or vulnerable groups (%)	9
Executive (%)	0
Independent (%)	18

Data Assurance

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

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2020
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

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

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

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

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

The bank integrated the SAWI project (Support and Accelerate Women's Inclusion) in order to draft and adopt more inclusive policies for the recruitment, retention and promotion of women.

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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

In order to improve the well-being of students, the bank concluded a partnership with UN Habitat to create a prosperous unrban space around schools. Also, in the framework of a sectoral initiative, a rehabilitation of sanitary blocks was provided. During the pandemic period, the bank donated oxygen concentrators to hospitals. In order to promote sport and physical education, STB sponsored ROTARACT CLUB to create a playground for children.

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
2017
Forced labour
The bank respects the regulations provided by Tunisian legislation and all standards of the International Labour Organization.
Child labour
The bank respects the regulations provided by Tunisian legislation and all standards of the International Labour Organization.
Non-discrimination in respect of employment and occupation
2017
Occupational safety and health
2017
Working conditions (wages, working hours)
2017

Optional comment

In terms of labour rights, the bank respects the labour code, the collective agreement and the code of ethics.

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

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

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

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

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

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
The bank respects the legal obligations of the relevant regulators and the international labour organization principles.
Occupational safety and health
The bank respects the legal obligations of the relevant regulators and the international labour organization principles.
Working conditions (wages, working hours)
The bank respects the legal obligations of the relevant regulators and the international labour organization principles.

Performance

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

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

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	63

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

	Percent of women (%)	Unknown
Senior leadership level position	34
Non-executive board	18

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

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

	Incident rate	Unknown	Choose to not disclose
Incident rate

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
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.

In order to implement a new human ressources evaluation system: -A training has been provided to managers to insure the annual performance review based on a competence approach. - A training has been provided to employees to identify their personal strengths and weaknesses through a personal skills assessment.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
2021
Oceans
2021
Forests / Biodiversity / Land Use
2021
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use
2021

Optional comment

All the environmental topics are included in our environmental and social policy

1.1. For each environmental policy, is it:

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

Optional comment

Our ES policy carries our formal commitment to environmental and social issues. among other things, our ES policy presents our clear strategic commitment to put in place an environmental and social risk management system related to customer financing, in order to be able to better manage the environmental, climatic and social risks of our customers, monitor and evaluate as well as carry out the necessary restrictions and corrective actions. our system takes into account all SFI standards including the exclusion list for financing

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
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Water
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Oceans
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Forests / Biodiversity / Land Use
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Air Pollution
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.
Energy & Resource Use
As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.

Optional comment

As we have specified, we are in the process of setting up our environmental and social risk management system which will allow us, among other things, to set and update corrective actions.

Climate Action

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

Scope 1 Emissions

Full

None

The STB is not concerned by scope 1 since it is not directly responsible for greenhouse gas emissions, but we are rather concerned by scopes 2 and 3.

Emissions (tCO2e)

Scope 2 Emissions

Full

None

The calculation of emissions are not available for the year 2021, we plan to do the calculations at the end of 2022.

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

The calculation of emissions are not available for the year 2021, we plan to do the calculations at the end of 2022.

Emissions (tCO2e)

Optional comment

The STB is not concerned by scope 1 since it is not directly responsible for greenhouse gas emissions, but we are rather concerned by scopes 2 and 3. The calculation of emissions are not available for the year 2021, we plan to do the calculations at the end of 2022.

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

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

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

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

We have worked to forge solid partnerships with influential actors and with respectable experience in the subject of climate change, and this will allow us in the near future to finance adaptation and mitigation projects.

Unknown

Optional comment

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

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.

The STB works to reduce the environmental impact linked to its activity and that of its customers, through initiatives aimed at reducing and controlling the consumption of paper, energy, the emission of greenhouse gases, pollution due to fire or other and overall to the protection and preservation of a healthy and prosperous environment. 1- Reduction of paper consumption : A new information system supporting a workflow that digitizes daily banking operations and a new HR platform have enabled the bank to achieve a remarkable reduction in the use of paper. The STB also worked on the design, development and implementation of digital applications dedicated to customers to control paper consumption. 2- Reduced consumption of printer cartridges The bank has reduced the number of printers per floor. STB replaced office printers with only two centralizing printers per floor. 3- Control of energy consumption : The bank has launched an energy efficiency study to optimize its energy consumption. Following this study, a call for tenders will be launched in order to create a self-production unit in photovoltaic energy. In addition, the STB has created green financing products for these customers, the purpose of which is to encourage them to work for an energy transition towards green energies. 4- Minimize greenhouse gas emissions related to transport : The STB is concerned about the challenges of climate change, which is increasingly becoming a global emergency and a responsibility for everyone. The bank has worked to reduce fuel consumption and greenhouse gas emissions by implementing Microsoft 365 solutions (Teams, etc.) for meetings and online document sharing. This approach has made it possible to minimize travel for meetings and missions, as well as travel for sending letters. 5- Responsible and Sustainable Finance ; An Environmental and Social Risk Management System : The STB strives to support and meet the needs of these customers while limiting their environmental and social impacts. The implementation of an environmental and social risk management system (ESMS) within the STB enables it to anticipate these risks by identifying them prior to the granting of financing and to monitor them throughout its reimbursement. . Prior to the implementation of the ESMS, awareness raising and training workshops are aimed at the various businesses and the managers of the financial subsidiaries to harmonize the financing decisions of the STB Group. 6- Green and ECO Products / Offers : The STB developed specific products (Loans) for ECO construction, ECO consumption (Energy Consumption Reduce) and ECO cars (Electric and hybrid cars).

Anti-corruption

Commitment

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

Optional comment

The members of the board of directors and all the bank's senior executives adhere to a set of ethical and deontological principles which tend to prevent and fight against corruption. Accordingly, the Bank has adopted a code of ethics , a policy for combating money laundering, the financing of terrorism and an anti-corruption policy. Indeed, the anti-corruption policy provides a conceptual framework for understanding the cases involving corruption, the risks for the production of such acts in the bank's operations and measures to prevent and fight against corruption. however,the bank is aware of the importance and the obligation to implement an anti-corruption compliance programme, thats why it will launch a tender for an assessment and support mission for the implementation of an anti-corruption and fraud prevention system.

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

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

The bank have an anti-corruption policy witch outlines the strategy adopted by STB in preventing and combating corruption. This policy illustrates the principals cases involving corruption, which are : the payment of a bribe/gifts and invitations /influence peddling/conflict of interest/sponsorship and charitable donations

Response and Reporting

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

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
no incidents detected
Confirmed during the current year, and related to this year	0
no incidents detected

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

Optional comment

The permanent governance and compliance body shall report, to the Board of Directors, on the results of the investigations concerning acts and risks of corruption. An appropriate action plan,agreed with the Internal Audit Committee, will be prepared and presented to the Board of Directors accordingly. Based on the results of the investigation, every allegation of corruption will appropriate disciplinary action.

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

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

STB will set up a centralised internal alert system to receive and process internal and external reports, by filling in an incident form on the "risk incident declaration" portal. Employees, suppliers and third parties will be able to report violations of the anti-corruption policy, fraudulent practices and malfeasance. To encourage the reporting of suspected cases of corruption, the bank is committed to protecting the whistleblower against the risk of reprisals or discrimination that the employee may suffer because of his or her report, and this, in accordance with the organic law n° 2017-10 of 7 March 2017.