2022 Communication on Progress

DEF - Detection Electronique Francaise

Published date

June 30, 2022

No. of questions

59

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

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

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Specifically for anticorruption policy, the internal control Manager hold a monthly meeting with the CEO in order to give him a feedback about latest audits and proposes him relevant actions to manage the potential risks.

    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

    6.1. During the assessment of risk, which business relationships are reviewed?

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

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

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

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    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?

    Optional comment
    Processes are in place for anti-corruption with a dedicated whistleblowing line. Nevertheless it is not yet in place for human rights, labour rights or environment.

    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)

    All this topics are adressed in the Directors Guide '"Guide du Dirigeant".

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    DEF has only one stakeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Male (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Female (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Non-binary (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Under 30 years old (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    30-50 years old (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Above 50 years old (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    From minority or vulnerable groups (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Executive (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    Independent (%)

    DEF has only one staekeholder. No board for DEF company. The board is managed at the higlest level, i.e. DEF network, including all companies in the group.

    13. Do you produce sustainability reporting according to:

    ECOVADIS

    Data Assurance

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

  • Human Rights

    Materiality / Saliency

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

    Response

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

    Refer to "DEF 2021 CSR Annual Report"

  • 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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    2022

    Working conditions (wages, working hours)

    2000

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

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

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    No monitoring of progress

    Review issues on ad-hoc basis

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

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

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    Optional comment
    Since it is not mandatory for the employees to inform the company they belong to a trade union, it is therefore not possible to know the percentage of employees in a trade union.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    13

    Non-executive board

    Optional comment
    The company has no non-executive board. According to french regulation and type of company, the company belongs to one owner. Therefore the question about the non-executive board is not applicable.

    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 (%)

    2.3
    Optional comment
    L'écart de rémunération est un écart pondéré, tel que calculé dans l'index d'égalité hommes femmes.

    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

    8.06

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0.07

    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

    Not selected in HR1

    Forced labour

    Not selected in HR1

    Child labour

    Not selected in HR1

    Non-discrimination in respect of employment and occupation

    Not selected in HR1

    Occupational safety and health

    Working conditions (wages, working hours)

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

    Please refer to our DEF 2021 CSR Report. DEF has mainly taken mainy actions regarding diversity and inclusion, training and career, occupational safety and health and working conditions. Our objectives for 2022 are : Diversity & inclusion (Promoting equality and diversity, fighting against all discrimination related to visible and invisible differences), Training & Career (Develop employee loyalty by committing to the development of skills and career development of our employees), Working conditions (Ensuring that our employees have working conditions that ensure their safety, well-being and development).

  • 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

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

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

    No monitoring of progress

    Review issues on ad-hoc basis

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

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

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    2835

    Scope 2 Emissions

    Emissions (tCO2e)

    102

    Scope 3 Emissions

    Emissions (tCO2e)

    4515
    Optional comment
    The data for scope 1, 2 and 3 are calculated in our 2018 reporting. Next reporting for GHG emission will be calculated in 2022 as per french regulation.

    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 (%)

    The R&D is done by another company of the DEF Network. Therefore it is not applicable.

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

    Energy / Resource Use

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

    % of total energy consumption

    Technology

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

    Percent of total revenue (%)

    Sector-specific Questions

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

    Sector-specific: Water

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

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    No withdrawal

    Groundwater:

    No withdrawal

    Surface water:

    No withdrawal

    Rainwater:

    No withdrawal

    Wastewater:

    0

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

    No withdrawal

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Groundwater:

    0

    Surface water:

    0

    Rainwater:

    0

    Wastewater:

    0

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

    0
    Optional comment
    Our company provides services for other companies. Therefore there are no need for water withdrawal.

    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/$):

    We only operate in France. There are no 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

    2687

    SOx

    No emission of SOx

    Volatile Organic Compounds (VOC)

    No emission of VOC

    Hazardous air pollutants (HAP)

    No emission of HAP

    Particulate matter (PM10)

    No emission of PM10

    Persistent organic pollutants (POP)

    No emission of POP

    Other (please specify in text box)

    Optional comment
    Emission of HFO Gaz for maintenance of fire systems

    Sector-specific: Waste

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

    Waste Generated (t)

    Optional comment
    The total weight of waste is not calculated yet.

    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 (%)

    Optional comment
    Since we do not calculate the total weight of wate, we are not able to calculate the ratio. However, we do track the hazardous waste : 32 t.

    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)

    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.

    Refer to our DEF 2021 CSR Report. DEF has taken many actions regarding the environment : Implementation of the new LOTA range, continuation of homeworking and reduction of travel (videoconferencing), implementation of CSR governance, promoting electric vehicles (objective: end of thermal-only vehicles).

  • Anti-corruption

    Commitment

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

    2021
    Optional comment
    The program has been launched in january 2021, as well as the creation of the creation of the internal control manager position.

    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?

    Prevention

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

    Optional comment
    First we have began to train commercial teams on the concept of limitation of the competition.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Learning program has been built for new general managers. The first session will take place in september 2022.

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

    Optional comment
    Internal audits are lead during the fiscal year and key points of main processes (purchasing...) are reviewed. Some actions are defined following the audits and implemented in business units.

    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 incident

    Confirmed during the current year, and related to this year

    0
    No incident
    Optional comment
    No corruption case has been identified, detected or reported by employees in 2021.

    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?

    The DEF Network code of conduct has been communicated to each Director by the CEO, and to all employees using the Electronic Document Management System.

    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.

    Three main actions have been launched in 2021: The first one consisted in verify that most of General Directors have no capitalistic link with another company which may represent a conflict of interest. Second one is to control the level and the nature of Customer's invitations from Salespeople. Finally is to check the Purchasing Process of the Company (numbers and quality of Subcontractors, ....).