Scope 1 Emissions
2022 Communication on Progress
TARKETT
Published date
June 28, 2022
No. of questions
64
Supplemental files
code-of-ethics-en.pdfanticorruption-code-of-conduct.pdfcode-of-conduct-for-tarkett-suppliers-en.pdfhuman-rights-statement.pdftarkett-2021-csr-report-en.pdfcompetition-policy-en.pdftarkett-2021-csr-report-en.pdftarkett-2021-csr-report-en.pdfcode-of-ethics-en.pdftarkett-2021-csr-report-en.pdftarkett-2021-csr-report-en.pdfanticorruption-code-of-conduct.pdfcode-of-ethics-en.pdftarkett-2021-csr-report-en.pdfcompetition-policy-en.pdfCEO Statement
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 commentHuman Rights Statement: https://www.tarkett-group.com/app/uploads/2022/01/28104845/human-rights-statement.pdf Code of Ethics https://www.tarkett-group.com/app/uploads/2021/12/code-of-ethics-en.pdf Anti-corruption Code of Conduct https://www.tarkett-group.com/app/uploads/2021/12/07100537/anticorruption-code-of-conduct.pdf Code of Conduct of Suppliers https://www.tarkett-group.com/app/uploads/2021/12/code-of-conduct-for-tarkett-suppliers-en.pdf Environmental Commitment displayed inside CSR Report 2021: https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en.pdf Competition Policy: https://www.tarkett-group.com/app/uploads/2021/12/competition-policy-en.pdf Whistleblowing Procedure: https://www.tarkett-group.com/app/uploads/2021/12/whistleblowing-procedure-en.pdf3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentHuman Rights Statement: https://www.tarkett-group.com/app/uploads/2022/01/28104845/human-rights-statement.pdf Code of Ethics https://www.tarkett-group.com/app/uploads/2021/12/code-of-ethics-en.pdf Anti-corruption Code of Conduct https://www.tarkett-group.com/app/uploads/2021/12/07100537/anticorruption-code-of-conduct.pdf Code of Conduct of Suppliers https://www.tarkett-group.com/app/uploads/2021/12/code-of-conduct-for-tarkett-suppliers-en.pdf Environmental description inside CSR Report 2021: https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en.pdf Whistleblowing Procedure: https://www.tarkett-group.com/app/uploads/2021/12/whistleblowing-procedure-en.pdf4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
6.1. During the assessment of risk, which business relationships are reviewed?
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?
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 commentThe whistleblowing systems were implemented with the Compliance Hotline in 2018 complementing the Ethics Hotline deployed in 2016 in the United States and in Canada. The systems are supported by the Whistleblowing Procedure to enable employees, business partners and other third parties to report any kind of concern: https://www.tarkett-group.com/app/uploads/2021/12/whistleblowing-procedure-en.pdf > The procedure and the compliance hotlines can be accessed on the internet and the company intranet or by phone from 150 countries in 200 languages. > Accessible to all Tarkett’s employees, business partners (suppliers, clients, etc.) and other third parties. > To report any type of violation related to, for example, antitrust, conflict of interest, corruption, fraud, harassment, discrimination, environmental damage, etc. > Presented for consultation to Tarkett’s Works Councils in countries where local law enforces it. > Supported by a platform to ensure the protection of whistleblowers. > Guaranteeing the confidentiality of cases.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.
Optional commentThe whistleblowing systems were implemented with the Compliance Hotline in 2018 complementing the Ethics Hotline deployed in 2016 in the United States and in Canada. The systems are supported by the Whistleblowing Procedure to enable employees, business partners and other third parties to report any kind of concern: https://www.tarkett-group.com/app/uploads/2021/12/whistleblowing-procedure-en.pdf > The procedure and the compliance hotlines can be accessed on the internet and the company intranet or by phone from 150 countries in 200 languages. > Accessible to all Tarkett’s employees, business partners (suppliers, clients, etc.) and other third parties. > To report any type of violation related to, for example, antitrust, conflict of interest, corruption, fraud, harassment, discrimination, environmental damage, etc. > Presented for consultation to Tarkett’s Works Councils in countries where local law enforces it. > Supported by a platform to ensure the protection of whistleblowers. > Guaranteeing the confidentiality of cases. Find out more about the procedure in place: https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en.pdf9. 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 commentThe reduction of Scope 1 & 2 greenhouse gas (GHG) emissions and the circular economy (increase in the percentage of recycled materials used in the manufacture of our products) were included in the 2020-2023 and 2021-2024 LTIP (Long-term incentiveplan) criteria. The GHG emissions and circular economy objectives form part of Tarkett's strategy aiming to transition to a circular economy, a central part of Tarkett's response to climate-related risks and opportunities. In total, some 181 to 240 managers and executives worldwide, depending on the plan, have part of their LTI grant related to the achievement of these two objectives. Furthermore, all the members of the Executive Management Committee (EMC) have other CSR objectives depending on their areas of responsibilities. > At plant and Division level, Health, safety and environmental managers are responsible for the deployment of actions plans and programs on safety and environmental protection, including Tarkett’s climate-related strategy. As such their personal objectives may include safety targets, efficiency targets, emission reduction targets, energy reduction targets, ReStart® collection targets, waste management or other circular economy objectives depending on their specific local roles. > At plant level, some managers and operators may have their personal objectives related to the deployment of Tarkett’s strategy and the implementation of Tarkett’s World Class Manufacturing (WCM) program. This program includes procedures and actions to improve efficiency, energy reduction, emissions reduction, waste reduction and recycling and environmental incident reporting and analysis. Some managers in the sales network may also have their personal objectives linked to Tarkett’s ReStart® collection and recycling program – a key part of Tarkett’s circular economy and climate strategy.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentAt December 31, 2021, the Supervisory Board was made up of thirteen members, including two members representing employees and two observers. The composition of the Supervisory Board is designed to enable the Group to benefit from the diversified professional experience of its members and involve the representatives of the Company’s majority shareholders in the definition of the Group’s strategy and its implementation. Furthermore, at December 31, 2021, the proportion of women on the Supervisory Board stood at 44% (a rate higher than the legal requirements) and the proportion of independent members according to the Afep-Medef Corporate Governance Code was equal to the one third recommended by the Afep-Medef Corporate Governance Code for companies with majority shareholders. Agnès Touraine has informed the Chairman of the Supervisory Board of her intention to resign from her duties as a member of the Supervisory Board as of June 1, 2022 for personal reasons. The Supervisory Board will take note of this resignation at its next meeting and will decide on her replacement, in particular in her capacity as member of the Appointments, Compensation and Governance Committee. Therefore, the Supervisory Board is today composed of twelve members of which three independent members, two members representing the employees and two observers. For information, in accordance of applicable laws, the members representing employees and observers were not taken into account for the calculation of the gender and independent representations (calculated here above). They were taken into account for the calculation of the other representations.13. Do you produce sustainability reporting according to:
Optional commentTarkett’s commitment, as well as the CSR report, the dashboards, the 2025 and 2030 objectives and the robust reporting process, meet the European and French regulatory obligations, and are in line and consistent with the requirements of internationally recognized standards: > the European Union Directive and the French regulations on non-financial statement, known as the extra-financial performance declaration (“déclaration de performance extra-financière” or DPEF); > the French duty of care (“Devoir de Vigilance”) and anti-corruption law (“Loi Sapin 2”); > the European Data Protection Regulation on data privacy; > the ten principles of the United Nations Global Compact (UNGC), to which we communicate our results to comply with the “Advanced” level standard; > several Sustainable Development Goals (SDGs) defined by the United Nations; > the Global Reporting Initiative (GRI) Standards – see in particular section 3.11.3 GRI and DPEF concordance table; > the Task-force on Climate-related Financial Disclosures (TCFD); > the Carbon Disclosure Project (CDP) climate change questionnaire; > the calculation and reporting of greenhouse gas (GHG) emissions in line with the World Business Council for Sustainable Development (WBCSD) and the World Resources Institute (WRI) GHG Protocol; > the setting of a whole value chain GHG emissions (Scopes 1, 2 and 3) reduction target in line with the Paris Agreement's aim of limiting the global temperature rise to 1.5°C, following the Science-Based Target Initiative (SBTi) methodology and criteria > Cradle to Cradle® (C2C) principles for the design of our products, from material selection and product manufacturing, to installation, use, maintenance, end-of-use and product recovery; > the AFEP-MEDEF recommendations, notably regarding corporate governance and the DPEF.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?
Optional commentFind out more about Tarkett's materiality matrix assessment (page 33) & CSR risk mapping inside the 2021 CSR Report: (page 30): https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en-1.pdfResponse
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 2021 Tarkett prepared a Human Rights Statement to reconfirm and raise awareness to these commitments. The next step is to set up a dedicated human rights policy with associated action plans.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentThe Code of Ethics (https://www.tarkett-group.com/app/uploads/2021/12/code-of-ethics-en.pdf) displays all policy commitments to labour rights principles. In addition, the CSR Report explains in detail the commitment in the following chapters (see uploaded document): 3.10.5.2 Maintaining social dialogue & 3.10.5.3 Establishing collective agreements, .3.2.4 Remaining committed to high business and ethical standards, 3.10.3 Encouraging diversity and inclusion, 3.10.1 Developing a safety culture.1.1. For each labour rights 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 labour rights 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 this labour rights issue?
4. 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?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentTarkett is committed to respecting, in addition to the legal obligations specific to each country, employee freedom of association, collective bargaining and representation. We apply these principles without exception and in the same way in all countries where the Group operates. In line with this policy, 177 collective agreements are in place at Tarkett, and 14% of which cover issues related to occupational health or safety. The agreements cover a wide range of topics such as compensation and benefits, overall work time, work organization, remote working, and employment classification. They apply in 16 countries where Tarkett engages in sales and / or industrial activity.7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentThe regulatory scope of dialogue between employers and employee representatives varies from one country to another. However, in addition to respecting local labor legislation, Tarkett applies in all the countries in which it operates the same respect for its fundamental values and principles of freedom of association, and in particular respect for trade unions. The Tarkett Forum, the Group’s European works council, provides a platform for social dialogue in Europe. Several times per year, this council brings together trade union representatives of our main European sites to dialogue with Group Management, including our CEO. This council strengthens cooperation and social dialogue and focusses on issues pertaining to the general functioning of the company and discusses HR issues common to different sites and countries in Europe. In 2021, the Tarkett Forum held four meetings virtually, to discuss among the other topics, the COVID-19 pandemic, its repercussions on the business and financial situation as well as Tarkett’s response to safeguard employee health. Other topics discussed include safety, raw material inflation and the consequences for the business, the results of the 2021 employee feedback survey, and Division strategic projects such as ongoing restructurings. In addition to Tarkett's activities in Europe, agreements are regularly negotiated at certain sites in the United States and Canada.8. In the course of the reporting period, what was the percentage of women in:
Optional commentAt Tarkett, the share of women among top executives, executives, and the next 2 management levels (senior directors and directors) was 26% in 2021. Lastly, the share of women in Tarkett's Supervisory Board (non-executive) is stable with 44% (in compliance with French regulations and Afep-Medef Corporate Governance Code). Find out more inside 2021 CSR Report, section 3.10.3 Encouraging diversity and inclusion.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?
Optional commentIn France, Tarkett calculates and publishes each year, in accordance with the legislation on gender equality (French “Act for the freedom to choose one’s future career”), the “Gender Equality Index” for its three legal entities. The index is comprised of five indicators covering gender pay gaps, differences in individual salary rises, promotion differences, the percentage of female employees with salary rise following maternity leave and female representation in the top 10 salaries. In 2021, Tarkett (corporate teams in France) scored 96/100 (vs 92 in 2020 and 90 in 2019), Tarkett France (teams from flooring activities in France) scored 90/100 (vs 87 in 2020 and 82 in 2019) and FieldTurf France scored 91/100 (vs 92/100 in 2020 and 2019). These results demonstrate Tarkett’s commitment and continuing efforts on gender equality and notably gender pay equality in France. For several years, part of the pay rise budget in France has been allocated to reducing the pay gap between men and women.10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional comment0,059: Lost day rate due to LTA – accident severity rate [TG0t] for all employees: # of working days lost for LTA x 1000 / worked hours. This includes scheduled work days, counting immediately after the accident, excluding diseases.11. In the course of the reporting period, what was the company’s incident rate?
Optional commentThe Recordable Lost Time Accident (LTA) Frequency Rate (FR1t) for all Tarkett employees is stable at 2.56 in 2021 (compared to 2.62 in 2020 and 2.19 in 2019). This indicator (FR1t) measures the number of accidents with lost time < & > 24 hours per million worked hours. Tarkett’s goal is to reduce this frequency rate to 1.0 by 2025. Find out more inside the 2021 CSR Report on section 3.10.1 Developing a safety culture.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?
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.
%Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentAll relevant topics and the associated policies are disclosed in Tarkett's 2021 CSR Report: https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en.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 commentThe 2021 data referring to Scope 1 is Gross direct (Scope 1) GHG emissions (tCO2equivalent). The 2021 data referring to Scope 2 is Gross market-based indirect (Scope 2) GHG emissions (tCO2equivalent) . Scope 3 data is based on 2020 activity data. Data disclosed is relevant to purchased goods and services and end-of-life treatment of sold products. In addition, Tarkett reviewed in 2021 its climate objective, engaging on reducing whole value chain emissions by 30% by 2030 compared to 2019. This is in line with Paris Agreement objective of limiting the global temperature rise to 1.5°C. Approval of these climate targets is currently ongoing by independent third-party Science-based Targets initiative (SBTi). For additional detailed scope 3 data, please read section 3.7.2 Limiting upstream and downstream greenhouse gas emissions (Scope 3) of 2021 CSR Report: https://www.tarkett-group.com/app/uploads/2022/03/23120608/tarkett-2021-csr-report-en-1.pdf7. 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.
Optional commentThe share of renewable electricity increased to 65% (vs 41% in 2020 and 42% in 2019). In 2021, four additional plants, in Sweden (Ronneby and Hanaskog), Poland (Orzechowo) and Germany (Abtsteinach) began sourcing renewable electricity, bringing the total to 12 plants that source 100% renewable electricity. Collectively this prevents some 63.1 kt CO2e per year of greenhouse gas emissions (base 2021 for these plants), the equivalent of 35.5% of total 2021 Scope 1 and 2 GHG emissions. The share of other renewable energies, such as biomass, in Tarkett’s energy mix remained stable bringing the overall share of renewable energies to 38% in 2021. Overall, the use of biomass, biofuel and the purchase of renewable electricity avoids the equivalent of some 77.7 kt CO2e of GHG emissions, which corresponds to 44% of Tarkett’s 2021 total Scope 1 & 2 GHG emissions. Tarkett continued to decrease the share of fossil-based energy, with the share of low carbon energy (renewable energy and electricity from nuclear power) progressing by 4% to 43% in 2021.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 commentIn 2021, total water consumption increased compared to 2020, however is 2.7% lower than 2019 pre-COVID-19 levels (0.71 million m³ in 2021 which equals 705 million liters of water, against 0.63 million m³ in 2020, and 0.73 million m³ in 2019). Water intensity, measured as water consumption per m² of manufactured product, increased slightly compared to 2019 (2.7 l/m² in 2021, 2.4 l/m² in 2020, and 2.6 l/ m² in 2019). One of the main solutions to reducing water intensity and water consumption is equipping our industrial sites which use water in their industrial process with a closed loop water system, in other words reusing a minimum of 98% of the water used. To date, the implementation of closed loop water systems and other water efficiency solutions has enabled 56% water savings (vs 2010) and significantly improved water intensity (-51% l/m² vs 2010). The proportion of sites using closed loop water systems or not consuming any water in their manufacturing remained constant in 2021 at 71%.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?
Optional commentTarkett does not operate in areas of high biodiversity value such as natural protected areas and does not develop new activities in pristine areas. As such, our activities do not have a direct impact on sensitive biodiversity features. We can however have an indirect impact on biodiversity, e.g. through natural resources consumption, air emissions or waste generation – topics which are duly addressed in the 2021 CSR report.16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
Optional comment24 200 tons of total waste to landfill in 2021. 57% of the total waste from our plants (including both production related waste as well as office and canteen waste) is effectively recycled, with 14 plants not disposing of any waste to landfill in 2021. A further 8 other plants do not dispose any industrial waste to landfill, with only office and canteen waste being sent to landfill.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.
2021 climate action was achieved through increased energy efficiency at production sites, renewable energy sourcing and eco-designed products. Through eco-design, Tarkett teams are selecting and using high-quality materials with a low carbon footprint. In 2021, Tarkett has reached strong progress with ReStart®, its take-back and recycling program, by transforming end-of-use flooring and recycled materials into new floors. This helps reducing waste and carbon footprint, diminishing the need for virgin raw materials while avoiding landfill and incineration. In the last 11 years, the company has collected the equivalent of 11 Eiffel Towers (112,000 tons) of flooring as part of its ReStart® program in Europe, North America and Brazil, inside eight recycling centers. In 2021, 15% of Tarkett’s raw materials (147,000 tons) were recycled materials, the goal is to reach 30% of recycled materials by 2030.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional comment2. 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 commentThese policies are described and displayed in detail in the following documents: - Code of Ethics https://www.tarkett-group.com/app/uploads/2021/12/code-of-ethics-en.pdf - Anti-corruption Code of Conduct https://www.tarkett-group.com/app/uploads/2021/12/07100537/anticorruption-code-of-conduct.pdf - Section 3.2.4.1 Ensuring business ethics and integrity of 2021 CSR report -Whistleblowing Procedure: https://www.tarkett-group.com/app/uploads/2021/12/whistleblowing-procedure-en.pdf Supplier Code of Conduct: https://www.tarkett-group.com/app/uploads/2021/12/code-of-conduct-for-tarkett-suppliers-en.pdfPrevention
3. Who receives training on anti-corruption and integrity?
Optional commentThe compliance training consists of customized e-learning modules which are organized for employees considered most at risk by their function (e.g. over 5,000 employees enrolled for each of the training modules on ethics, anti-corruption and antitrust). Anti-corruption issues addressed include bribery, relations with intermediaries, gifts and invitations, charitable donations and the whistleblowing systems available to employees as well as third parties. Regarding competition law, the program covers in particular horizontal (competitors) and vertical (suppliers and sub-contractors) restrictions of competition such as the exchange of information in the framework of professional trade organizations. A user-friendly tool with improved look and feel was deployed in 2021 with modules shortened but conducted more regularly. Face-to-face training sessions have also continued in 2021 via dedicated compliance workshops (mostly virtual) tailored to groups of employees more exposed to the previously mentioned risks. In addition, a code of ethics training is being delivered to all employees that do not have access a computer.3.1. How often is such training provided?
Optional commentFor other stakeholders such as sub-contractors, anti-corruption training is provided every two years. 6 e-learning sessions are organized per year for enrolled employees and in-person trainings every two years. In 2021, 97.3% of enrolled employees completed e-learning training on ethics, 96.2% on anti-corruption, and 99.4% on antitrust. In general, 97.6% of targeted employees completed e-learnings on Business Ethics in 2021.4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
The Anti-corruption Code of Conduct was updated in 2021, building on the principles of the Code of Ethics. This Code has been translated into 17 languages and deployed throughout the Group with employee representative bodies being consulted when necessary. Guidelines of good behavior practices when joining trade associations and more generally when attending meetings where competitors are present were developed in 2018 and are now included in the training sessions. Several controls were made in 2021. An Anti-corruption Accounting Control Procedure relating in particular to gifts, invitations, business meals, donations, sponsorships and intermediary commissions was set up in 2020 and is deployed throughout the Group in 2021. The whistleblowing systems implemented with the Compliance Hotline in 2018 complementing the Ethics Hotline deployed in 2016 in the United States and in Canada. The systems are supported by the Whistleblowing Procedure to enable employees, business partners and other third parties to report any corruption-related concern. Tarkett performed an assessment of its suppliers as part of our Responsible Sourcing Program (see CSR Report section 3.9.1.1 Deploying our responsible sourcing program) as well as anti-corruption due diligences on some of its intermediaries, clients and suppliers. In 2019, Tarkett retained a specialized service provider to assist with the anti-corruption evaluation of its business partners. This thirdparty due diligence program continued in 2021 with additional IT resources. Strong anti-corruption compliance training was enhanced during 2021. A user-friendly tool with improved look and feel was deployed in 2021 with modules shortened but conducted more regularly. Face-to-face training sessions have also continued in 2021 via dedicated compliance workshops (mostly virtual) tailored to groups of employees more exposed to the previously mentioned risks. Tarkett has changed the approach to its training programme by targeting those most at risk in terms of compliance. This new methodology allows for more thorough monitoring of participation and easier consideration of disciplinary action for non-compliance.