Report - COP Prototype

2022 Communication on Progress

Grupo Salinas

Published date

June 29, 2022

No. of questions

Supplemental files

COP_2022_VF.pdf COP_2022_VF.pdf COP_2022_VF.pdf Commitment Statement of Grupo Salinas Regarding the United Nations Global Compact.pdf Solid_Waste_Collection_Policy_of_Grupo_Salinas-2.pdf Human_Rights_Policy-3.pdf Effiency_Energy_policy-2.pdf Inclusion_and_Non_Discrimination_Policy-3.pdf Climate_Change_Policy-2.pdf COP_2022_VF.pdf Programa-de-Etica-Integridad-y-Cumplimiento-de-Grupo-Elektra-2019.pdf COP_2022_VF.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

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

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

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

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

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

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

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

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

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

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

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

Prevention

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

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

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

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

Concerns and grievance mechanisms

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

No, this is not a current priority

No, but we plan to within two years

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

Yes, we have a formal process

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?

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 (#)	10
Male (%)	80
Female (%)	20
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	0
Above 50 years old (%)	100
From minority or vulnerable groups (%)
Executive (%)	0
Independent (%)	40

Optional comment

On April 29, 2022, the Board of Directors is made up of ten members, of which four are independent directors; that is, they are not employees of or affiliated with our majority shareholders.

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

https://www.grupoelektra.com.mx/Documents/Es/Downloads/Informe-Sustentabilidad-EKT2020_EN.pdf#page=100

Other (Please provide additional information)

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?
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)
Freedom of expression
Access to culture
Access to water and sanitation
Digital security / privacy
Rights of women and/or girls
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Other
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.
We observe the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. We identify the main risks related to human rights and work on their prevention, thus implementing our due diligence process, from which we highlight our self-regulation through the guidelines reflected in the Group's Code of Ethics and Conduct and in the Human Rights Policy; applicable to all stakeholders: managers, employees, suppliers, partners, business allies and contractors. To guarantee that our suppliers comply with these principles, they are evaluated through the Supplier Circle Certification process, which takes into consideration social criteria and other social aspects (labor matters, work environment, employee training, etc.). We oppose to any conduct that violates the dignity and quality of life of our employees, and of people related to and/or involved in our activity. Child labor, forced labor, human trafficking, labor harassment, sexual exploitation, and discrimination are strictly prohibited.

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
2019
Forced labour
2019
Child labour
2019
Non-discrimination in respect of employment and occupation
2019
Occupational safety and health
2019
Working conditions (wages, working hours)
2019

Optional comment

The internal politic that applies is the Code of Conduct and Grupo Salinas Ethics, Integrity and Compliance Program Code of conduct: https://www.grupoelektra.com.mx/Documents/ES/Downloads/Codigo-de-Etica-y-Conducta-de-Grupo-Elektra-2019.pdf PEIC: https://www.grupoelektra.com.mx/Documents/ES/Downloads/Programa-de-Etica-Integridad-y-Cumplimiento-de-Grupo-Elektra-2019.pdf Grupo Salinas Commitment to the UN Global Compact https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/Declar_comp_PactoMundial_2.pdf Human Rights Policy https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/politica_derechos_humamos.pdf

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)

Optional comment

Code of conduct: https://www.grupoelektra.com.mx/Documents/ES/Downloads/Codigo-de-Etica-y-Conducta-de-Grupo-Elektra-2019.pdf PEIC: https://www.grupoelektra.com.mx/Documents/ES/Downloads/Programa-de-Etica-Integridad-y-Cumplimiento-de-Grupo-Elektra-2019.pdf Grupo Salinas commitment to the UN Global Compact https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/Declar_comp_PactoMundial_2.pdf Human Rights Policy https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/politica_derechos_humamos.pdf

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 (%)	1.3

Optional comment

Italika respects its employees’ right to belong to a union or to sign a collective bargain- ing agreement. The Company involves the union from the time its operating person- nel first join the company, giving them information and a form to join the union. Every year it holds a meeting with the union committee to review the collective bargaining agreement and transmit up-to-date information to all unionized personnel.

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 (%)
Italika respects its employees’ right to belong to a union or to sign a collective bargain- ing agreement. The Company involves the union from the time its operating person- nel first join the company, giving them information and a form to join the union. Every year it holds a meeting with the union committee to review the collective bargaining agreement and transmit up-to-date information to all unionized personnel.

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

	Percent of women (%)	Unknown
Senior leadership level position	7
Non-executive board	38

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 (%)	13

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

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury

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

	Incident rate	Unknown	Choose to not disclose
Incident rate

Response and Reporting

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

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

Grupo Salinas has not been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated

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.

The growth and performance of Grupo Salinas has been thanks to the group of employees that make up our company, making us an important generator of employment in the countries where we operate and the livelihood of thousands of families. We focus on development, empowering talent always under the principles and values that characterize us, eliminating any bias related to their origin, sex, religion, among others. We are promoters of diversity and inclusion, as we are convinced that a diverse team is a team rich in ideas and efficiency. Under the restructuring that has been taking place in the different areas of the Group, we are more than convinced that any change is synonymous with improvement and transformation; however, this transformation would not be possible without the commitment and trust that our employees have given us even in times of adversity. We remain aligned with the Grupo Salinas High Performance Model, which aims to reflect the way of thinking and execution of all the companies that make up Grupo Salinas. It is structured in 6 steps, which we homologate to Grupo Elektra's businesses. 1. strategy 2. Structure 3. Team 4. Information systems 5. Compensation and incentive system 6. Integrarion and assessment

Environment

Commitment

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

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

Optional comment

Grupo Salinas Commitment to UN Global Compact: https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/Declar_comp_PactoMundial_2.pdf Climate Change Policy: https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/Politica_Cambio_Climatico.pdf Waste Policy: https://www.gruposalinas.com/sustentabilidad/content/documents/es/descargas/Politica_de_Recoleccion_de_Residuos_Solidos.pdf

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

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

Optional comment

Right now we are implementing an analysis on risk and opportunities on climate change and aligned to the TCFD recommendations.

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

Full

None

Emissions (tCO2e)

44190

Scope 2 Emissions

Full

None

Emissions (tCO2e)

94483

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Grupo Salinas emissions Scope 1, 2 and 3 TV Azteca: https://www.irtvazteca.com/documents/es/Downloads/TV-Azteca-Informe-de-Sustentabilidad-2021-Esp.pdf#page=78 Grupo Elektra: https://grupoelektra.com.mx/documents/es/downloads/Grupo-Elektra-Informe-de-Sustentabilidad-2021-Esp.pdf#page=57 Totalplay: https://irtotalplay.com/es/sustentabilidad#page=59

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

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

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

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

We have taken action to increase resilience in our supply chains

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

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

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

Other (Please provide additional information)

Unknown

Optional comment

We start mapping the risks and opportunities for climate change on the financial sector, in order to identify potential risk and we can mitigate them.

Energy / Resource Use

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

% of total energy consumption

Unknown

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

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
Our successful business model, articulated in the financial, commercial, telecom, and entertainment segments are present in different countries in the Americas. We have operations in Mexico, Guatemala, Honduras, Panama, Peru, and the United States, with more than 7 thousand points of contact through our Elektra, Salinas y Rocha stores, Banco Azteca, and Purpose Financial branches. Our business and operating model give life to Grupo Salinas’ own purpose of inclusive prosperity. It is based on contributing to the development of the communities in which we operate and the quality of life of the people, respecting the environment -protected areas and biodiversity-, with profitable, inclusive and commercially successful solutions.
Hectares

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)

Unknown

Not applicable (Please provide additional information)

Our successful business model, articulated in the financial, commercial, telecom, and entertainment segments are present in different countries in the Americas. We have operations in Mexico, Guatemala, Honduras, Panama, Peru, and the United States, with more than 7 thousand points of contact through our Elektra, Salinas y Rocha stores, Banco Azteca, and Purpose Financial branches. Our business and operating model give life to Grupo Salinas’ own purpose of inclusive prosperity. It is based on contributing to the development of the communities in which we operate and the quality of life of the people, respecting the environment -protected areas and biodiversity-, with profitable, inclusive and commercially successful solutions.

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
Un nuevo bosque, from 2000 to date 51,000 hectares, on 2021 = 1,123 hectares
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

Optional comment

Limpiemos nuestro Mexico, since 2003 the program recollect 250,000 tons of trash, that has been recycled and reused.

Sector-specific: Waste

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

Waste Generated (t)

16390

Unknown

Not applicable (Please provide additional information)

Optional comment

Sustainability report 2021 Grupo Elektra: https://grupoelektra.com.mx/documents/es/downloads/Grupo-Elektra-Informe-de-Sustentabilidad-2021-Esp.pdf#page=59 Totalplay: https://irtotalplay.com/es/sustentabilidad#page=59 TV Azteca: https://www.irtvazteca.com/documents/es/Downloads/TV-Azteca-Informe-de-Sustentabilidad-2021-Esp.pdf#page=72

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 (%)

12.64

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)

850

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.

For the correct environmental management of Grupo Salinas, we aligned all environmental initiatives with the standards that the Energy and Environment area at Grupo Salinas level dictates for all the companies that make up the group, being the area responsible for articulating the measures to mitigate the environmental impacts of the different companies, including the necessary investment in technology and innovation. Furthermore, we have the Environmental Policy at the Salinas Group level, which sets the guidelines regarding the preservation and protection of the environment that the Group and its different business units undertake to implement within their operations. We complement our policy of Climate Change which is extensive to our businesses and our stakeholders, in order to act according the initiatives we are enrolled. All the companies which are part of Grupo Salinas have the Energy Management System (SIGEN for its acronym in Spanish). Through it, we record and monitor consumption, spending, and variations in both parameters, even at the store level. It also allows us to identify opportunities for improvement in processes, facilities, equipment, etc.

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

2019

Optional comment

https://www.grupoelektra.com.mx/Documents/ES/Downloads/Programa-de-Etica-Integridad-y-Cumplimiento-de-Grupo-Elektra-2019.pdf

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

Prevention

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

Optional comment

124,231 employees take the training on anti-corruption and integrity (PEIC) Grupo Elektra: https://grupoelektra.com.mx/documents/es/downloads/Grupo-Elektra-Informe-de-Sustentabilidad-2021-Esp.pdf#page=40

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

Grupo Elektra: https://grupoelektra.com.mx/documents/es/downloads/Grupo-Elektra-Informe-de-Sustentabilidad-2021-Esp.pdf#page=17

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
0
Confirmed during the current year, and related to this year	0
Deshonesty

Optional comment

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.

In Grupo Salinas we have a digital mailbox for complaints (Honestel) that is available at all times. In this mailbox we receive reports of all those acts that move us away from our commitment "Zero Tolerance to Bribery and Corruption" and to the best national and international practices in this area. This measure contributes to the strengthening of our culture of integrity, as it continuously self-regulates and corrects behaviors contrary to anti-corruption standards. The roles of the Audit, Gender Unit, Special Investigations and Human Capital areas were strengthened, depending on the type of incidents, so that the Audit, Gender Unit, Special Investigations and Human Capital areas can deal with them as appropriate. Care protocols were created for each of them, and improvements were made to the tools that help to get to know those involved prior to each investigation. Complaints received are passed to the compliance director, who is responsible for verifying, analyzing and resolving cases of corruption, who reports to the Integrity Committee, including those detected by the control system and internal audits. The channel for reporting complaints and compliance inquiries allows our employees, business partners and society in general, to be an integral part of the solution to any problem that may arise in the company. This adds to our culture of open and unreserved communication, such system allows us to:  Address the concerns of our employees, suppliers, business partners or anyone interested in helping us fight corruption.  Create an atmosphere of collaboration and visibility of compliance  Effectively deal with any type of risk.  Prevent conduct that harms the company and society as a whole.