Report - COP Prototype

2022 Communication on Progress

Etapak Baski ve Ambalaj Sanayi ve Ticaret Anonim Sirketi

Published date

June 29, 2022

No. of questions

Supplemental files

Etapak 27001

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

Optional comment

Board of Directors of Özgörkey Group is the highest governing body. The Governance Scheme is located on our web site. https://ozgorkeyholding.com/en/index.cfm?action=sustainability

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

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

Optional comment

Chairman's Letter is on our web site. https://ozgorkeyholding.com/en/index.cfm?action=sustainability

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

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

Optional comment

Code of Conduct covers principles on human rights, labor rights, decent work, environment and 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

Optional comment

Human Rights: Discipline and Ethics Committee Labor Rights /Decent work: HR Department Environment: OHSE Department Anti-Corruption: HR Department

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

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

Optional comment

Governance scheme is on our Özgörkey Holding web site.

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

Özgörkey Holding has a Risk Committee to assess social and environmental risks along with financial 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

Integrated Managements Systems are in place.

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

Optional comment

Notices regarding unethical conduct can be sent to the address stated in our Code of Ethics.

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)

Optional comment

Code of Conduct is in place.

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

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

Optional comment

We enable access to effective remedy to all affected right holders / stakeholders as defined in relevant legislation and further provide additional remedies through insuring risks. We also include social responsibility clauses in our contracts with the providers of outsourced services.

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

Optional comment

We conduct investigations to understand the causes of any negative outcomes regarding the four topics and change policies and procedures when necessary.

Executive Pay

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

Optional comment

YES: Timely realization of employee engagement survey actions is part of executive performance criteria.

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 (#)	2
Male (%)	50
Female (%)	50
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)	0
Executive (%)	50
Independent (%)	0

Optional comment

Non-executive: 50%

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)

Optional comment

We do not have any plans for data assurance in 2022.

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
2022
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Policy on Freedom of Expression is placed in our updated Code of Ethics. Code of Ethics is placed under the below link. https://ozgorkeyholding.com/en/index.cfm?action=sustainability Digital Security and Privacy policies are Personal Data Protection Policy (KVKK) and ISO 27001 Information Security Policy.

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

Optional comment

Personal Data Protection Policy is a legal requirement for corporations in Turkey.

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

Optional comment

Freedom of Expression: We ran a prioritization survey on human rights issues with the participation of our sustainability team. Digital Security and Privacy: We provide IT security trainings to all employees, at least biannually.

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
Employee Engagement Survey
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

An outsourced consultant regularly serves the company regarding digital security runs risk assessments biannually. We also have 3rd party ISO 27001 audits annually. Improvement areas from both assessments are applied immediately. Our group company Etap Enjeksiyon also uses the IT infrastructure of Etapak and benefit from the consultant mutually.

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

Optional comment

All employees are invited to the IT risks awareness training in 2021 and about 90% participated and completed the trainings.

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

Optional comment

Our target is zero security cases, and we use ISO 27001 standard as external guidance. For 2022, we have plans to better improve network infrastructure and to be prepared to current digital risks.

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

Optional comment

Freedom of Expression: No complaints or cases occurred during the reporting period on human rights issues, so no remedy is needed or required. Digital Security and Privacy: No complaints or data loss cases occurred during the reporting period, so no remedy is needed or required.

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.

Freedom of Expression: Freedom of expression came up as a new issue during materiality assessments. Soon later, we started an internal program named Care as a core corporate value and launched it with a kick-off workshop. One of the objectives of the program is to strengthen internal communication and enhance open dialogue among employees and executive team. Digital Security and Privacy: Documentation on Personal Data Privacy Act is completed. We organized IT awareness trainings for employees, run external audits for risks regularly and benefit from Consulting services for risk management and mitigation.

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
We already have collective bargaining agreement with labor union.
Forced labour
Under Turkish Law, forced labor constitute criminal violation and strictly prohibited in our operations.
Child labour
Under Turkish Law, child labor constitute criminal violation and strictly prohibited in our operations.
Non-discrimination in respect of employment and occupation
HR and General Labor Practices Guideline - 01.01.2016
Occupational safety and health
Integrated and Product Safety Management Systems Policy QDMS Date: 09.12.2021
Working conditions (wages, working hours)
HR and General Labor Practices Guideline 01.01.2016

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)

Optional comment

OHS Etapak OSH team joined meetings organized by workers’ association to share and benchmark OSH performance and related impacts of different sectors and organizations and learn about best practices to mitigate risks. OHS team organized gatherings with the participation of Office employees and workers regarding 12 OHS topics. The meeting format included question and answer sessions which helped to refresh OSH knowledge of both groups. Working Conditions We run salary benchmark biannually with HAY Group. After the reviews, we update and improve our salary and side benefits scale for each position. Improvements also include flexible working hours since Covid 19 pandemic started. For blue collar employees we engage and collaborate with labor union to improve general working conditions.

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)

Optional comment

OHS Integrated Management System audits and trainings were held. Our OHS team audits the production site monthly through a questionnaire, reports and plans the actions to be taken. Employees record the near miss cases on our digital board which is placed for general improvement feedback and suggestions. We regularly run emergency drills. Working Conditions We run salary benchmark biannually with HAY Group. After the reviews, we update and improve our salary and side benefits scale for each position. Improvements also include flexible working hours since Covid 19 pandemic started. For blue collar employees we engage and collaborate with labor union to improve general working conditions. We voluntarily go through social impact and ethics assessment of SEDEX annually, where a third party audits our working conditions in our group companies. So far, no significant evidence of cases and misconduct are reported.

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)

Optional comment

OHS Contractors include catering, security, waste collection and cleaning services companies. Working Conditions We continue with salary salary and side benefits benchmark Works. We plan to transparently share the results with our employees and provide them with information.

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
Monitored under legal compliance.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

OHS We have zero accident target. We monitor accident frequency and accident severity rates Working Conditions We continue with salary and side benefits benchmark works. Our target is to keep salary levels above general market conditions. We also have overtime procedure, and we have a goal to keep our overtime hours 5% below legal limits. SEDEX reports provide us road map for improvements on side benefits and overtime.

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	69.13

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 (%)	69.13

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

	Percent of women (%)	Unknown
Senior leadership level position	38.46
Non-executive board	50

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 (%)	100

Optional comment

In general women's salaries are %40 higher than men's.

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0.0000036

Optional comment

3.6 per 1 million hour

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

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

No cases with long term incapability of work occurred during the reporting period. So no remedy is needed or required. Working Conditions Etapak always pays full salary in cases where an employee has a report to rest after an accident regardless of the duration of the resting. We voluntarily go through social impact and ethics assessment of SEDEX annually, where a third party audits our working conditions in our group companies. So far, no significant evidence of cases and misconduct are reported.

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.

OHS We provided trainings and ran risk assessments covering all employees. To strengthen OHS culture we assessed risks on 10 topics and set targets for improvements. Working Conditions Salary benchmark biannually with HAY Group. Collaboration with labor union to improve general working conditions for blue collar employees. We voluntarily go through social impact and ethics assessment of SEDEX annually.

Environment

Commitment

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

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use
Integrated and Product Safety Management Systems Policy QDMS Date: 09.12.2021

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

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

Optional comment

Etapak developed and produced helical labels using recycled PET and won the “WorldStar 2022” award from World Packaging Organization among 440 projects from 37 countries. With this Project, OPP which is a petrochemical product is avoided in production and so the labels can be recycled after 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

Optional comment

Climate Action: Internal training to all employees Air Pollution: *Ministry of Environment and Climate Change audits every two years Waste: *Government licensed waste companies collect our wastes. Energy & Resource Use: *Integrated management system audits.

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

Optional comment

We have targets on water, air pollution, waste and energy. Regarding legal risk of zero waste act, we also started to separately collect and dispose wastes created by our employees

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

Optional comment

To recycle certain wastes instead of incineration we looked for the right waste recycling company. The process took 3-4 months and we succeeded to recycle some of our waste instead of incineration.

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

2171558

Scope 2 Emissions

Full

None

Emissions (tCO2e)

3159167

Scope 3 Emissions

Full

Partial

None

We do not keep track of Scope 3 data.

Emissions (tCO2e)

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

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

2020 investments (0.002%) returned in 2021 as 0.003%.

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)

Unknown

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 (%)

0.003%

Unknown

Not applicable (Please provide additional information)

Optional comment

In 2022 a new envinormentally friendly product has been launched as a result of innovation studies carried out in this field. Thanks to this initiative, in the first five-month period the share of environmentally friendly products in total revenues reached 0.75%

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	18.6
Groundwater:	0
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water withdrawn in regions with high or extremely high water stress (%)	0

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	18.6
Groundwater:	0
Surface water:	0
Rainwater:	0
Wastewater:	0
Percentage of water consumed in regions with high or extremely high water stress (%)
We do not operate in a region with high or extremely high water stress.

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/$):

Unknown

Not applicable (Please provide additional information)

We do not operate in a region with high or extremely high water stress.

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	1.7
SOx	0
Volatile Organic Compounds (VOC)	15
Hazardous air pollutants (HAP)	0
Particulate matter (PM10)	0
Persistent organic pollutants (POP)	0
Other (please specify in text box)	0

Sector-specific: Waste

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

Waste Generated (t)

2211

Unknown

Not applicable (Please provide additional information)

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 (%)

Unknown

Not applicable (Please provide additional information)

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)

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.

At Etapak, our priority issue was to reduce pollution due to emissions by 90%. Additionally, we worked with one of our major customers to develop recyclable packaging. Recycled waste efforts are explained in E5.

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

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

Our Code of Ethics is placed on our web site. https://ozgorkeyholding.com/en/index.cfm?action=sustainability

Prevention

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

Optional comment

All 235 employees of Etapak Ambalaj attended a training session on ethics.

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

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

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Optional comment

The Discipline and Ethics committee meets at least once every six months.

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
Confirmed during the current year, and related to this year	0
No incidents

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

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.

We provided ethics training to all our employees that included anti-corruption content. As we did not have any incidents we did not face any challenges.