2022 Communication on Progress

ALFA S.A.B de C.V.

Published date

June 28, 2022

No. of questions

62

CEO 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?

    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

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    One of the business units started identifying and accounting for environmental risks during 2021. Other business units have started their analysis on this topic.

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

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

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

    Optional comment
    This is the link to our Transparency Helpline: https://alfa.com.mx/CONT/transparency.htm

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

    No

    Yes

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

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

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

    Are there processes in place to avoid retaliation?

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

    Other (Please provide additional information)

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    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 (#)

    12

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    8

    Above 50 years old (%)

    92

    From minority or vulnerable groups (%)

    0

    Executive (%)

    17

    Independent (%)

    67
    Optional comment
    There is one without a specific classification, for being the CEO of a public limited company in whose board of directors our President participates.

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

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

    In line with the programs of the International Labor Organization (ILO), ALFA encourages the respect and promotion of Human Rights through its Human Capital policies. These policies reject any discriminatory act, child labor and exploitation, forced labor, abuse, coercion, as well as threats and the prevention of union association or collective bargaining of collaborators in all its Business Units.

  • 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

    2016

    Forced labour

    2016

    Child labour

    2016

    Non-discrimination in respect of employment and occupation

    2016

    Occupational safety and health

    2016

    Working conditions (wages, working hours)

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

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

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No monitoring of progress

    Review issues on ad-hoc basis

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    32.8
    Optional comment
    This percentage covers all employees with permanent contract. This information does not include Campofrío's (Sigma) employees in Europe.

    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 (%)

    42.26
    Optional comment
    This percentage covers all employees regardless of their contract type.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    9

    Non-executive board

    0
    Optional comment
    This percentage refers to the executive population of the entire Company including Business Units.

    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 (%)

    ALFA offers the same initial salary and benefits for employees according to their skills, expertise and profile. It does not consider gender as a differentiative element. This has come to the top of the agenda and the Company is working on mechanisms to further foster gender equity.

    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

    7.6
    Optional comment
    Baseline 1 million man-hours.

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    233.71
    Optional comment
    Baseline 1 million man-hours.

    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)

    Optional comment
    When answering No in this question, it is because the Company and its subsidiaries have not caused adverse impact regarding the issues selected. Alfa integrates all the fundamental ILO principles and guidelines within their management, prevention and remediation systems, in order to fully comply and respect its employees' human and labor rights.

    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.

    For over 47 years, a philosophy focused on the care and development of employees has been continuously developed, which evolves to adapt to changes in the context and foster a respectful work environment of safety, support, well-being, and belonging. The investment in this area totaled US $39.5 million. This included both the usual programs offered to employees, as well as all the adaptations and equipment required to meet the specific needs of each business during the year. To meet the challenges presented by its various industries, a Human Capital vision has been developed, which integrates the essential elements in the relationship with collaborators: culture, attraction, development and retention of talent, and value creation. The focus is set on knowing and understanding the talent needed to achieve ALFA’s business vision. Building safe and adequate physical and psychological spaces, as well as processes and programs through which employees achieve their aspirations and personal success translating into tangible business results.

  • 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

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Water

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Oceans

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Forests / Biodiversity / Land Use

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Air Pollution

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

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

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Energy & Resource Use

    ALFA is a holding company that owns several business in very diverse industries. As each of these industries has specific impacts, risks and opportunities related to the environment, ALFA allows them to establish their own policies, according to their services nature. ALFA has an Environmental Stance, with guidelines and lines of action, found in https://alfa.com.mx/down/informes/AnnualReport21.pdf, page 59.

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    1380000

    Scope 2 Emissions

    Emissions (tCO2e)

    1470000

    Scope 3 Emissions

    Emissions (tCO2e)

    22470000
    Optional comment
    Scopes 1 and 2 are full. Scope 3 emissions data pertains to Alpek.

    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 (%)

    Optional comment
    Alpek (51% of ALFA's revenues) invested 0.10% of total revenues (US $7.7 billion) in R&D; 48% of revenues came from low-carbon products.

    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.

    % of total energy consumption

    3.5
    Optional comment
    This percentage includes: 13% of Alpek's total electricty consumption (estimate) 16.5% of Sigma's total electricity consumption (eolic) 5% of Axtel's total electricity consumption (Renewable photovoltaic)

    Technology

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

    Percent of total revenue (%)

    48
    This applies to Alpek only and includes 4 enviornmentaly friendly products, including recycled PET (rPET).

    Sector-specific Questions

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

    Sector-specific: Water

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

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    169435

    Groundwater:

    2100

    Surface water:

    145500

    Rainwater:

    0

    Wastewater:

    0

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

    0.3

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    65976

    Groundwater:

    2100

    Surface water:

    53300

    Rainwater:

    0

    Wastewater:

    0

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

    1
    Optional comment
    Sigma reports 12,776 megaliters of consumption in "Others" category.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Optional comment
    This information applies to Alpek only: Currently and publicly there is only 1 site in an extremely high-water stress area. The Water Intensity for this site is 7.5 m3/ton produced.

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    0

    Hectares

    0

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    Neither Alfa nor its subsidiaries use land that needs to be converted to run their operations successfully.

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    498

    SOx

    30

    Volatile Organic Compounds (VOC)

    711

    Hazardous air pollutants (HAP)

    283

    Particulate matter (PM10)

    None of Alfa's subsidiaries' operations emmit these emissions.

    Persistent organic pollutants (POP)

    None of Alfa's subsidiaries' operations emmit these emissions.

    Other (please specify in text box)

    None of Alfa's subsidiaries' operations emmit any other emissions.
    Optional comment
    The data provided pertains to Alpek.

    Sector-specific: Waste

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

    Waste Generated (t)

    219903

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    2

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Optional comment
    Alpek nos va a mandar, Sigma no lo tiene.

    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.

    Principle 7: Based on the shared vision in ALFA’s governance, Business Units establish their specific strategy to mitigate their impact and manage their environmental risks considering they all operate in different sectors. SIGMA: Its strategy is aimed at achieving sustainable growth of the business and the value chain by implementing initiatives in favor of the environment. The lines of action followed during 2021 were: 1) Reduce the environmental impact of its supply chain. 2) Move towards zero net carbon emissions. 3) Achieve greater efficiency in water use and management, and become better stewards of the resource. 4) Promote a circular economy These guidelines are deployed in each organizational unit of the Company to align efforts at a global level. ALPEK: After an exhaustive analysis, Alpek established objectives for each of its material issues. Its environmental strategy focuses on four main lines of action: 1) Carbon emissions reduction and eco-efficiency. 2) Circularity 3) Efficient water use and management 4) Pollution Alpek based its strategy on the structure proposed by TCFD, which includes four elements: • Governance: the role of management in the assessment and risks and opportunities related to climate change. • Strategy: initiatives implemented to reduce carbon emissions. • Risk management: identification, management and mitigation of risks related to climate change. • Metrics and objectives: establishment of goals and performance indicators in emissions reduction and energy efficiency. AXTEL: Axtel, being a telecommunications company, seeks to reduce its environmental impact through four areas: 1) Diversify energy sources. 2) Take advantage of high-efficiency lighting technologies. 3) Implement responsible material disposal processes. 4) Develop better cooling practices. All of them have establsihed targets regarding environmental efficiency and impacts reduction and mitigation. Please review https://alfa.com.mx/down/informes/AnnualReport21.pdf, pages 58 to 65.

  • Anti-corruption

    Commitment

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

    2022
    Optional comment
    We have anti-corruption, conflict of interest, donations policies, as well as the Code of Ethics. In addition and complementary to this policies, we have the transparency helpline, through which any situation that does not meet the required levels of transparency, trust, ethics and security can be reported and is available to employees, customers, suppliers, among others.

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

    Optional comment
    Conflict of Interests and Procurement Policies are not public.

    Prevention

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

    Optional comment
    All employees, including intenral audit staff and key executives.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Training is a permanent process for new employees and suppliers. New hires receive the policy and its explanation upon entry. There are ongoing campaigns to ensure its promotion and understanding. Internal channels are used, but also communicated through external publicly accessible physical and digital media.

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

    Optional comment
    Through the audit and internal control areas, transparency helpline, and conflict of interest letters. Twice a year by external auditors.

    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

    59
    Breach of policies and internal controls.

    Confirmed during the current year, and related to this year

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

    Administrative minutes, feedback, dismissal and temporary suspension.

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

    Optional comment
    Fighting against corruption is always a business priority for Alfa. However, to join the Collective Action international group is not being considered at the moment.

    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.

    The Anti-Corruption Policy is focused on reaffirming the mandate to comply with applicable anti-corruption legislation in the countries where ALFA operates. This includes adherence to the U.S. Foreign Corrupt Practices Act (FCPA). This policy establishes the basic rules and framework for preventing, detecting, investigating, remedying, and, where appropriate, sanctioning any person working for or representing the Company who has committed an act of corruption, in any of its manifestations and under any circumstances. We make sure to comply with the policy through diverse mechanisms such as audits, transparency helpline, communication of related policies and procedures, update of conflict of interest letter, among others.