2022 Communication on Progress

Altavia

  • Governance

    Policies and Responsibilities

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

    Optional comment
    In line with France's DPEF regulation, we issue extensive non-financial reporting, which which we use to support us in monitoring our ESG performance and is verified by a 3rd party and our Executive Committee. More recently, for early 2022, our Head of Risk has submitted a risk analysis to our Audit Committee for arbitration and action plan review as part of a newly implemented review process.

    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
    Based on our core activities and operating markets, the Human Rights topic has been considered a relatively low impact area for us, however we do plan to address this topic with regards to our value chain- particularly in our procurement function within the next two years.

    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
    We consider that our Human Capital policy, indicates an adherence to labor rights, human rights via guiding principles around a healthy working environment, a commitment to diversity, equity, and inclusion. It also includes our working principles and best practices for reducing our environmental impact. It also includes a whistleblowing policy. Our Responsible Business Partner Policy (RBPP) is our baseline code of ethics for our supply chain, which touches on all of these topics.

    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
    For labor rights our Director of Human Capital, is a member of the COMEX, and all other sustainability topics sit under the executive direction of our General Secretary with a Group-level CSR Team.

    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
    All sustainability themes are managed through a Group-level, Corporate CSR Team and arbitrated through a series of committees (depending on the topic): Audit Committee, a CSR Committee, a Steering Committee (including executive representatives from all business units) and for strategic projects, the COMEX.

    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
    Our risk and CSR team will be addressing this topic via a materiality, risk and saliency mapping project this year.

    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
    Our risk and CSR team will be addressing this topic via a materiality, risk and saliency mapping this year. Once we have identified priority areas of risk/impact, we will begin to address each one with an action plan.

    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
    We have a dedicated email address designated to a Human Capital representative and the General Secretary by which formal concerns can be issued and addressed.

    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
    Anonymous alerts are not currently implemented in our whistleblowing process. Nevertheless, any alerts are treated confidentially by our Human Capital Directory and General Secretary.

    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 do not consider this a potential risk for our scope of work.

    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 are in the early stages of capturing this information on a YOY basis for both the environmental piece and the anti-corruption piece. (ex. Simplified Carbon Footprint analysis, CDP participation, and whistleblower protection in line with Sapin 2.)

    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

    Optional comment
    We have started rolling out certain sustainability-linked objectives to some of our business units Managing Directors, but not all. The aim will be to determine the most relevant KPIs based on the the profile of the business unit, and then link this to set objectives across the entire business.

    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 (#)

    15

    Male (%)

    73

    Female (%)

    27

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    Above 50 years old (%)

    87

    From minority or vulnerable groups (%)

    0

    Executive (%)

    27

    Independent (%)

    73

    13. Do you produce sustainability reporting according to:

    Optional comment
    As a French company, we report in accordance with with D.P.E.F. regulations.

    Data Assurance

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

    Our DPEF and annual management report is verified by a third party auditor.
  • Human Rights

    Materiality / Saliency

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

    Optional comment
    Our Responsible Business Partner Policy references these 5 materiality points with regards to our business partners, and the employee handbook, The Art and Style references the relevant topics as they pertain to our own operations and staff.

    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.

    With regards to digital security, a new GDPR training has been implemented as an awareness campaign. Other human rights topics to be addressed on materiality mapping exercise to be done before the end of 2022. If high degrees of salience are determined, an action plan to address these topics will be discussed.
  • 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

    A&S reviewed in March 2022.

    Occupational safety and health

    A&S reviewed in March 2022.

    Working conditions (wages, working hours)

    Optional comment
    We comply with all labor standards within the local jurisdictions of where we operate and do not consider that we are heavily exposed to risk on the topic of forced or child labor given our core activities. However, we address all these topics in our partner policy, where we do consider limited risk exposure. Our internal employee handbook document, The Art and Style does address discrimination, occupational safety from the perspective of mental health, and equal pay.

    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
    Our Responsible Business Partner Policy lays out a code of conduct which is expected of our partners and details each of these topics.

    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

    As a French company, we are, by default (French constitutional law) part of the National Collective Agreement in France. We don't necessarily address these topics at a Group-level in all markets where we operate, as each entity will also comply with local laws.

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    As a French company, we are, by default (French constitutional law) part of the National Collective Agreement in France. We don't necessarily address these topics at a Group-level in all markets where we operate, as each entity will also comply with local laws. Furthermore, as a professional services provider, we are not exposed to a high level of risk regarding child or forced labor, or infringing on the rights of collective bargaining systems, and so do not consider these topics particularly material for us. From a value chain perspective, we do engage suppliers on these topics via our code of ethics (Responsible Business Partner Policy) and aim to further address and monitor adherence the policy.

    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

    We have addressed in our recent HR policy, we have not had the opportunity to build any mitigation initiatives for this reporting period, but aim to do so in the coming year.

    Occupational safety and health

    We have addressed in our recent in our HR policy, we have not had the opportunity to build any mitigation initiatives for this reporting period, but aim to do so in the coming year.

    Working conditions (wages, working hours)

    Optional comment
    We have not taken any group-level preventative/mitigative measures on the first 3 topics, due to their lack of materiality. Regarding the following 2 topics, which we have addressed in our recently updated HR policy, The Art and Style, but we have not had the opportunity to build any mitigation initiatives for this reporting period, but aim to do so in the coming year.

    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
    We don't currently provide any training on these topics, however, we aim to have training modules in place for both Forced Labour, Discrimination (DEI), and Occupational health (preventing psychological risks) within the next two years. We have implemented a number of mental health awareness initiatives in the last two years, in response to the Covid crisis.

    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

    We monitor the number of business partners who agree to adhere to our code of ethics on which this topic is addressed.

    Forced labour

    We monitor the number of business partners who agree to adhere to our code of ethics on which this topic is addressed.

    Child labour

    We monitor the number of business partners who agree to adhere to our code of ethics on which this topic is addressed.

    Non-discrimination in respect of employment and occupation

    We monitor the number of business partners who agree to adhere to our code of ethics on which this topic is addressed.

    Occupational safety and health

    We monitor the number of business partners who agree to adhere to our code of ethics on which this topic is addressed.

    Working conditions (wages, working hours)

    Optional comment
    For the first 3 topics, we don't collect data on our own operations due to lack of exposure to risk and for the following topics, we have started to collect some relevant data (via the DPEF reporting) and aim to set and monitor some KPIs off the basis of our reporting output in the coming year.

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    Optional comment
    Because our global footprint extends to many markets, we comply with all local regulations around collective bargaining, but because each market requires a different approach, we do not have either a group-level policy, nor do we monitor this. As a French-based company with 60% of our workforce covered by a convention collective, we are required by law to adhere to the relevant collective bargaining stipulated by the industry.

    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
    Because our global footprint extends to many markets, we comply with all local regulations around trade unions, but because each market requires a different approach, we do not have either a group-level policy, nor do we monitor this.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    Non-executive board

    45.8
    Optional comment
    There is not a current, definitive ranking of senior leadership, so we don't monitor this at a group level. We consider that our Non-executive board is composed of our leadership committee for each of the BUs (Or Steering Committee.) We aim to set specific KPIs and definitions for managerial positions/levels in the coming year.

    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 (%)

    Optional comment
    Our current salary gap analysis does not factor equal job profiles, but is based on ratio of men to women across the business.

    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

    Optional comment
    We report annually on the number of work accidents across the business, but we don't currently capture the overall number of hours worked for each employee, and each market (as there is no global definition of number of hours equating to an FTE contract.)

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    Optional comment
    As with the injury frequency, we do not measure the incident rate in correlation to the number of hours worked.

    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
    We consider that we have limited, direct exposure to any of the listed topics and have had no reported incidents concerning these labor rights impacts.

    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.

    We consider our biggest exposure to to human and labor rights risks to be associated with our extended, multi-tiered supply chain. To address this risk, we have enforced a code of conduct to our suppliers and are aiming to reach a 90% signatory rate in the coming two years.
  • 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

    Oceans

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Given our core activities and their related impact, our current policies have a focus on Climate Action and Forests, but our plan is to strengthen and expand those policies in 2022/2023, in order to have a more encompassing and clear policy & strategy focused on environmental impact and action. Our pillar around forests is based on international standards FSC and PEFC, and our pillar around climate action will be based on the SBTi. The commitments we take are impacting both our own operations (Simplified Carbon Footprint) and our value chain (partners, products, etc.). All the information around these topics are public, notably thanks to our COP, DPEF reporting, and approved and supported by our COMEX.

    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

    Optional comment
    Our pillar around forests is based on the international standards FSC and PEFC, and our pillar around climate action will be based on the SBTi. The commitments we take are impacting both our own operations (Simplified Carbon Footprint) and our stakeholders (supply chain, products). All the information around these topics are public, notably thanks to our COP, and it's approved by our COMEX.

    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
    Concerning climate, in 2021, we began to create a comprehensive continuous improvement process, with an expanded program of assessments and footprints, complete with a review of some key actions and good practices in the different business units to further reduce our impacts, and build a roadmap to improve ourselves. The program will be further expanded in 2022, with a Scope 3 carbon footprint assessment for a large, representative part of our group, including a viable action plan in collaboration with our stakeholders. Concerning Forests, we historically work with our business units, suppliers, paper mills, clients, auditors... to manage our level of risk prevention, thanks to the FSC and PEFC standards. We conduct annual external and internal audits supported by a 3rd party auditor, that allow us to identify and mitigate non-conformities and and have a clear vision and process surrounding the topic.

    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
    We work off a multitude of support materials and content, like ready to use toolkits or presentations, in order to engage and onboard our stakeholders on several environmental topics. In the case for the Climate & Forests topic, for example, we develop knowledge share with documents and workshops linked to our methodology and objectives about Carbon Footprint, or our process and good practices around the FSC and PEFC certifications. The "Simplified Carbon Footprints" program are our way to perform some internal audits on the CO2 impact of our business units. With the resulting output, we give provide advice and good practices to reduce this impact. On FSC-PEFC, we conduct both internal and external audits every year to guarantee the responsible supply of paper-based products made thanks to wood coming from sustainably managed forests. We are also part of the Climate Ambition Accelerator of the Global Compact France, a group of companies working on a continuous improvement roadmap concerning their climate action. Concerning forests, we have worked for years with a third party auditor to support our FSC/PEFC credentials and processes.

    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
    Our Responsible Business Partner Policy covers most of these topics from a supply chain perspective, where the majority of the risk sits, however we monitor our impacts through various policies and initiatives based on the 5 SDGs that we have committed to. We run a series of CO2 footprint calculations that cover a significant piece of our scope 1 & 2 emissions and in 2022 we will have a scope 3 analysis performed on our largest and most representative business unit.

    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)

    151

    Scope 2 Emissions

    Emissions (tCO2e)

    421

    Scope 3 Emissions

    Emissions (tCO2e)

    872
    Optional comment
    Guided by action and continuous improvement, Altavia Group is building a climate roadmap sequenced in several steps. The first step is to carry out so-called "simplified" carbon footprints (accounting for the internal scope of our offices, i.e. energy consumption, employee travel, purchases of IT equipment, etc.) in order to easily accelerate the process for our business units. Our methodology includes Scope 1, Scope 2, and a minor part of Scope 3. In 2021, we measured the Simplified Carbon Footprint of 15 of our business units, representing 75% of the group revenue. The results here, in terms of emissions of CO2, are extrapolated from our datas, to be representative for a theoretical 100% coverage rate.

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

    Percent of revenue (%)

    Optional comment
    We don't follow this KPI for now. We have many internal initiatives, eco-design approach, first steps of R&D about low carbon products, brainstorming sessions with some experts to reduce our impact. The ambition is is to quantify and monitor these efforts via a series of indices, covering a range of product categories and services.

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

    Optional comment
    Concrete actions to reduce GHG emissions are developed at the business unit level. The first step is to limit the impact related to the travel of our employees and to our direct energy consumption. Our business units support a variety of sustainable projects around the world. In 2021, 13 of our business units supported 12 different projects of contribution to carbon neutrality, for an amount of 1193 tons of CO2 equivalent. We chose projects that are verified or certified, thanks for instance to the Gold Standard recognition. The projects are diverse, but they support reforestation, renewable energy, access to water, cookstoves efficiency, protection of the biodiversity... in countries like Guatemala, India, Turkey, Kenya, or Eritrea.

    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

    Optional comment
    We are not in a position to monitor this across the Group at this time as a number of business units operate out of rented office spaces, with limited visibility into energy providers.

    Technology

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

    Percent of total revenue (%)

    Optional comment
    We are not able to monitor this, at this time, however, our ambition is is to quantify and monitor our eco-designed products and services via a series of indices, which, in conjunction with their associated costs, would give visibility to the annual revenue stream.

    Sector-specific Questions

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

    Optional comment
    Please note that we are a B2B services provider, whose core activities are centered on retail communications and marketing.

    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.

    Our Group structures its environmental pillar around priorities linked to our activities and impacts : - Traceability of our raw materials, thanks to the FSC and PEFC standards, which guarantee that the paper and cardboard come from sustainably managed forests. - Climate responsibility, with a coherent and ambitious roadmap, with respect and in accordance with the limits set in the Paris Agreements. - The deployment of a common framework to all our suppliers thanks to a code of conduct, respecting the international standards. Moreover, Altavia encourages local initiatives and voluntary actions, as we view local actions as highly impactful and particularly relevant to the diverse profile of our business units. In this way, we ensure the diversity of ideas for the preservation of the environment echoes the diversity of our territories and activities. A significant proportion of our BUs have chosen to support carbon offsetting contribution projects: an opportunity to participate at their level in positive initiatives for the climate, but also to raise awareness of this issue among their stakeholders. As a federation of business units, operating out of over 40 markets, we see that building a cohesive approach to environmental topics is a particular challenge. While each BU is expected to comply with all laws, regulations, and standards appropriate to their local jurisdiction, we see a wide array of maturity in the different markets, especially in terms of environmental frameworks, priorities, etc. At a group level we seek to articulate a common framework and build upon best practices, by establishing a baseline of environmental policies and setting targets that are both impactful, but don’t simultaneously overburden our business units with topics that lack materiality to their core activities, or who operate out of less mature markets that lack the regulatory infrastructure to support ambitious targets.
  • Anti-corruption

    Commitment

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

    Optional comment
    In order to be compliant with the French regulation, Sapin 2, we plan to work on a corruption risk mapping to identify main risks and determine appropriate mitigation actions.

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

    Optional comment
    This topic is addressed in the Art and Style, employee handbook/Group code of conduct.

    Prevention

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

    Optional comment
    Both the Commercial and Purchasing departments have been trained in 2019.

    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
    Our aim is to have a yearly refresher training.

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

    We plan to implement a corruption risk mapping and subsequent action plan with dedicated process owners within the next two years. In the interim, the internal audit function may audit gifts & entertainment accounts for a panel of Business Units to ensure there is no significant or illegitimate pass through expenses that indicate acts of corruption. Our whistleblowing policy also offers an internal alert mechanism.

    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

    Confirmed during the current year, and related to this year

    Optional comment
    Nothing reported through alert mechanism so far.

    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?

    Optional comment
    We do not consider ourselves to be highly exposed to risk on this topic given our core activities and client and partner profiles.

    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.

    Our roadmap indicates a plan to implement a corruption risk mapping with action plan and dedicated process owners, with intent to review year on year. An annual anti-corruption training program will also be implemented and offered to all employees.