Report - COP Prototype

2022 Communication on Progress

Kenya Electricity Generating Company (KenGen) PLC

Published date

June 30, 2022

No. of questions

Supplemental files

KenGen Communication on Progress report 2021.pdf WHISTLE BLOWING POLICY.pdf ISO 9001 2015 Certification sites.pdf ISO 9001 2015.pdf ISO 14001 2015 Certificate.pdf Kengen Intergrated annual Report and Finanacial statement for 2021.pdf ENVIRONMENTAL SUSTAINABILITY POLICY (3).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

Optional comment

KenGen publishes it's sustainability statement in the annual report. The statement is signed by the MD & CEO as well as the Board Chairman. Corporate Governance Statement Corporate Governance is a framework that defines how KenGen is governed, providing transparency and accountability for decision-making. It provides the basic principles that enable the Board to provide requisite oversight in the running of the Company. The framework provides guiding principles that lead to explicit lines of responsibility. This ensures that our business has appropriate ethical decision-making processes and controls to balance the interests of all stakeholders. KenGen has instituted systems to ensure that high standards of corporate governance are maintained at all levels of the organization. The systems comply with the requirements of all applicable laws and regulations including but not limited to the Capital Markets Act and Regulations, rules and guidelines thereunder on Corporate Governance and the Nairobi Securities Exchange (NSE) regulations, rules, policies, and procedures. Corporate Governance matters are described in the 2021 Integrated Annual Report & Accounts and COP 2021- on our website • https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf • https://www.kengen.co.ke/images/Communication.pdf

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

Related Links to our Commitments Code of conduct - https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=112:kengen-code-of-conduct-policy Environmental Sustainability - https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=32:environmental-sustainability-policy Whistle Blowing - https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=31:whistle-blowing-policy Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf COP 2021- https://www.kengen.co.ke/images/Communication.pdf

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

The Board has an approved Code of Conduct which is in addition to the staff Code of Conduct. For all tender bids, suppliers must submit a duly executed business questionnaire which includes declarations on criminal offence and conflict of interest The links below are provided for more information • Environmental Sustainability - https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=32:environmental-sustainability-policy • Whistle Blowing -https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=31:whistle-blowing-policy • Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf • COP 2021- https://www.kengen.co.ke/images/Communication.pdf

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

The company has nominated committee members to assist the Company to implement policies related to the four areas. However, the nominees report to their respective supervisors , for example Human rights and Labour issues are handled by Human Resource and Administration Department. The Environment and CDM division was reorganized and renamed Environment and Sustainable Development Division to ensure that the sustainability issues are specifically enforced and monitored by a designated division within the the Company's Organisation structure Environment matters are handled by Environment and Sustainable Development Division while anticorruption issues are handled by the Integrity office in the Managing Director and CEO's office. KenGen also has also an established Internal audit and Risk Function header by a Manager who oversees and advises the management on all risks across the business.

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

The following committees have been appointed to address various topics: 1. Environment Sustainability Committee 2. Gender Mainstreaming and Disability Committee 3.Communication on Progress Reporting Committee 4. Corruption Prevention Committee 5. National Values Committee 6. Trade Union 7. Central Joint Council for labour and related issues 8. Pink Energy Secretariat

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

KenGen has an established Internal Audit and Risk division which assesses the risks and provides quarterly and annual reports to the top management for action where required. In addition, the respective functional areas carry out self audits as well as regulatory audit as required by the law. The risk report is a standing agenda in the quarterly meetings of both Board Audit, Risk & Compliance Committee and the full Board meeting. The Board periodically reviews the Company's Risk Heat Map and Risk Profile and the Company has a Business Continuity Plan and Disaster & Risk Management Framework to address and mitigate risks. This was recently evident during the Covid 19 pandemic when the Company in March 2020, activated the Corporate Crisis Management Team to address staff protection & wellbeing, business sustainability, and operations & logistics. KenGen has an established Enterprise Risk Management Framework(ERM).

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

Optional comment

KenGen has an ERM for sustainability of the business. All the business relationships are reviewed and a matrix of status is included in the annual integrated report refer to links below • Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf • COP 2021- https://www.kengen.co.ke/images/Communication.pdf

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

The company carries out regularly statutory audits on Financial, business operations, legal & compliance, environmental and corporate governance. Our annual report and COP 2021 report has comprehensively covered these sustainability topics - refer to the links below:- • Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf • COP 2021- https://www.kengen.co.ke/images/Communication.pdf

7.1. During the due diligence process, 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

Optional comment

Our annual report and COP 2021 report has comprehensively covered these sustainability topics as detailed in the links below:- 1. Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf 2. COP 2021- https://www.kengen.co.ke/images/Communication.pdf

Concerns and grievance mechanisms

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

No, this is not a current priority

No, but we plan to within two years

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

Yes, we have a formal process

Optional comment

KenGen has an established Whistle blowing policy that is accessible to all employees as a guide to raise their concern on matters related to human rights, labour, environment or anti-corruption.

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

The company embraces anonymous reporting and has a whistle blowing policy https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=31:whistle-blowing-policy

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

KenGen has stakeholders communication committee (SCCs) in all its operation areas. Resettlement Action Plan (RAP) is one of our large-scale effective remedies for the Project Affected Persons. Also KenGen Foundation runs the Schools Green Initiative Challenge (GIC) program to address Environment issues alongside Community Education issues driven by the site communities for ownership & sustainability of the GIC program. https://www.kengen.co.ke/index.php/business/business-sustainability/stakeholders-relations.html

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

The lessons are captured in the Government of Kenya (GoK) performance contracting report , Audit reports , Gender and Disability Mainstreaming Committee reports, reports to Anti corruption Authority . KenGen Foundation prepares a Report on its activities, lessons learnt and wayforward. Annual Integrated report and COP report, Annual Report on National Values and Principles of Governance Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 https://www.kengen.co.ke/images/Communication.pdf

Executive Pay

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

Optional comment

The Company has a Board charter and Human resource policy on remuneration. The Company makes annual commitments through the Performance Contract that is signed with the Government of Kenya.

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 (#)	11
Male (%)	64
Female (%)	36
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	27
Above 50 years old (%)	73
From minority or vulnerable groups (%)	9
Executive (%)	9
Independent (%)	73

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

The CoP report and Annual integrated reports are accessible to the public

Other (Please provide additional information)

Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf

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
Optional comment
Additional information is available in the annual report , the COP 2021 and Human resource policies • Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf • Cop 2021 https://www.kengen.co.ke/images/Communication.pdf • Child and forced labour are outlawed in Kenya and they do not apply to KenGen Plc
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 are an equal opportunity employer that upholds the rights of every person as stipulated in our Human Resource Policy on recruitment, selection, appointment, promotions, and in line with the laws of Kenya, United Nations Global Compact (UNGC) principles on human rights and labour as well as Sustainable Development Goals (SDGs). We deliberately ensure all business units have appropriate representation of work experience, expertise, and gender to enhance capacity and productivity. During the year, we had a complement of 2,552 employees spread across all our business areas in Kenya, Ethiopia, and Djibouti. The turnover rate stood at 5.7% which is less than the global average of 10.9% owing to the comprehensive employee retention programs in place. Human Resource Policy Our Human Resource policy ensures employee rights are protected and proper benefits provided for their work. The policy has helped in addressing complaints, problems, and grievances. This is in line with the UNGC principle 10.4: ‘Adopt policies, especially fiscal, wage and social protection policies, and progressively achieve greater equality Strength in our diversity and inclusivity We believe in diversity and inclusivity irrespective of gender, physical ability, ethnicity, or age. In line with our human resource policy on gender mainstreaming, gender equality (SDG5), and reduced inequalities (SDG10), we are committed to ensuring gender equality at the workplace by embracing the 2/3rd genn. Equally, the policy on diversity stipulates the resolve to recognize and appreciate the unique beliefs, values, skills, attributes, and characteristics of all employees, in an environment that promotes an all-inclusive representation of people differently-abled We are committed to ensuring that our people with disabilities are accorded equal opportunities in the workplace, including equal employment opportunities. The Company has provided facilities to accommodate persons with disabilities and ensured provisions of the Persons with Disability Act and other laws and regulations governing persons with disabilities are adhered to. Currently, 1.1% of all our employees are persons with disabilities. To ensure better interaction among all employees, we trained 31 employees in basic sign language, 234 on disability awareness, and facilitated an accessibility audit by the National Council for People with Disability (NCPWD) at Olkaria, Naivasha. Gender Equality The company has made a deliberate effort to meet the two-third gender requirement by increasing the ratio of women to men from 23.3% to 24.5%. While we are proud of the progress towards gender parity, we recognize that there is more work to do to attain gender equality sooner rather than later by deliberately recruiting more women under affirmative action to meet the threshold of not less than 30% representation of either gender in the workplace. We are committed to increasing the numbers through partnering with institutions such as the Institution of Engineers of Kenya Women Engineers chapter, Kenya Association of Manufacturing; Women in Manufacturing, the Brands and Beyond Women in Energy Awards, Women in Engineering South Africa, Women in STEM launch in Makueni amongst others.

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
General Labour policy- October 2021. Collective Bargaining Agreement- January 2017 ( Under review)
Forced labour
General Labour policy- October 2021
Child labour
General Labour policy- October 2021
Non-discrimination in respect of employment and occupation
General Labour policy- October 2021
Occupational safety and health
July 2020
Working conditions (wages, working hours)
General Labour policy- October 2021

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
KenGen operates within the labour laws and does not engage employees on forced labour
Child labour
KenGen operates within the labour laws and does not engage employees on 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
Continuous engagement with the union
Forced labour
We engaged
Child labour
We sensitized local communities around our installations on matters relating to child labour. In addition our contracted vendors have signed a contract document declaring they will engage workers as per Kenyan labour laws.
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 (%)	35

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 (%)	35

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

	Percent of women (%)	Unknown
Senior leadership level position	28
Non-executive board	36

Optional comment

Senior level refers to CEO, General Managers and Managers

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)	100

Optional comment

Both men and women are remunerated equally based on each job category. KenGen Promotes equal pay for work of equal value.

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	7

Optional comment

To calculate this figure we divided to total number of reportable injuries in 2021 which were 7 injuries by the total number of man hours worked for the year for Full time employees (FTEs). # Number of man hours worked in 2021 = 8 hours a day * 5 days a week * 4 weeks a month * 2533 number of employees * 11 months ( note we use 11 months as each employee has 30 leave days in a year). # Number of man hours worked in 2021 =4,458,080 Injuries per hours worked in 2021 = 7 injuries/4,458,080 = 0.0000016 injuries/per hours worked.

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.0000016

Optional comment

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)

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.

Plans and Achievements 1. During the period we ran regular sensitization programs on labour rights through KenGen weekly magazine, workshops and trainings and community engagement. 2. Continuously carrying out and implementing training needs assessment. 3. Released circulars and memos on labour laws 4. Conducted informal forums and staff retreats to strengthen staff relationships and build trust. 5. Reviewed processes to identify synergies to incorporate good practices of labour laws 6. Continuously created awareness on existing gender and women empowerment policy. 7. Instituted forums for all employees (Pink Energy for women , Blue Energy for men, and Y-Gen for the youth). 8. Integration of gender parity targets in the company strategy to drive diversity and create a plan to achieve this. 9. Partnership programs with academic institutions that sponsor women to take up the technical courses. 10. Working with the World Bank to develop a Gender Strategy which is awaiting approval. 11. KenGen participates in Power Africa’s engendering utilities program. 12. KenGen shall continue developing partnerships with like-minded institutions such as UNGC, World Bank, Institution of Engineers of Kenya Women Engineers chapter, Kenya Association of Manufacturing, Women in Engineering South Africa to continue enhancing gender equity. 13. KenGen shall continue to implement Government procurement policy on Access to Government Procurement Opportunities (AGPO) to Special groups namely women youth and persons with disability. 14. KenGen shall engage in increased coaching, mentorship, and personal development to enable its employees to reach greater heights. 15. As the organization continues to monitor statistical data on the women, the Company shall continue to take action to increase the number of women in senior positions. 16. In living the spirit of one of the themes “building relationships”, the company recognizes Kenya Electrical Trade & Allied Workers Union (KETAWU) as a representative of the employees 17. KenGen has a robust performance management system which is key in monitoring employee performance at all levels. 18. KenGen is committed to providing and maintaining work conditions, equipment, and systems of work which are safe and healthy for all the employees and other stakeholders including, contractors, visitors, and persons at or near the operational areas. 19. Recognizing the need to improve the people’s welfare and retention strategies, the Company implemented a mortgage and car loan scheme in 2013. 20. KenGen’s Medicare Scheme was enhanced to cover testing and treatment costs associated with COVID-19 and professional counselling services procured to deal with the emerging mental health and psychosocial issues. 21. To ensure that the company has the requisite benchmark strength for the operations from generation to generation, we have developed a policy on succession planning. 22. The Company has developed a robust career framework that addresses skills gaps, skills growth, and employee general career development. 23. To enhance the employee skills and competencies and address challenges brought about by the COVID-19 pandemic, the company implemented blended learning by introducing e-learning to complement in-person classroom training. 24. To address issues affecting the young employees in the company, Young Generation (Y-Gen) forum was established with the purpose of maximizing the potential of employees who are 35 years and below towards performance excellence and ultimately achieve the G2G (Generation to Generation) strategy. 25. To address some of the issues affecting men, the Blue Energy forum was established with membership drawn from all male employees. This is a platform that helps men address issues that revolve around career, investments, family, relationships, and lifestyle among others to bring the best out of them. 2022 commitments: 1. Approve and implement the Gender Strategy. 2. Continued implementation of UNGC principles and SDGs. 3. More partnerships to improve the livelihoods of women and women’s participation in Science Technology Engineering & Mathematics (STEM). 4. Implementation of a leadership development framework. 5. Institutionalize succession management. 6. Embed Coaching & mentorship programs.

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
2019
Water
2019
Oceans
Forests / Biodiversity / Land Use
2019
Air Pollution
2019
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2019
Energy & Resource Use
2019

Optional comment

https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=32:environmental-sustainability-policy.

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

https://www.kengen.co.ke/index.php/about-us/corporate-governance.html?download=32:environmental-sustainability-policy

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

When carrying out the Environmental audits in all our power generation stations, the Environmental Impact Assessment and Environment Audit regulations 2003 requires that all the affected stakeholders are consulted. KenGen has complied with this and the reports are forwarded to the National Environmental Management Authority of Kenya . The reports are also published in their websites See the links below for additional information Annual Report https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 - https://www.kengen.co.ke/images/Communication.pdf

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

Annual Integrated Reports and COP 2021 reports are available through the links below; Annual Report- https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021: https://www.kengen.co.ke/images/Communication.pdf

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

Additional information is available on the annual report and the COP 2021 report through the links provided below. Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 https://www.kengen.co.ke/images/Communication.pdf

4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

	Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Climate Action	KenGen has committed to the 1.5 Degree goal of the UN Global Compact in is currently at the preparatory phase for establishing science based targets (SBTi).
Energy & Resource Use	Prudent energy efficiency is an important component of KenGen's business sustainability. Our Energy efficiency program is focused on putting in place measures that comprise energy-saving devices, rational saving methods, and using alternative energy sources. In this regard, we have developed and implemented an energy policy and energy management program to conform with Energy (Energy Management) regulations in 2012 and reap the benefits of energy management through cost savings. In the last one-year KenGen conducted energy audits in Kipevu I, Kipevu III, Masinga, and Gitaru power plants and is implementing the following recommendations: • Efforts that have been put in place to manage energy consumption in KenGen facilities include, • Implementation of solar PV project in Kipevu; Installation of solar street lights in Kipevu, Kamburu, and Gitaru; • Replacing high energy-consuming lighting fixtures with LED lighting in all KenGen facilities; and • Minimizing energy imports from the grid through load management during curtailment.
Water	Water abstraction targets are in cubic meters as in the Water abstraction Permit in each of our hydro power generating plants. The compliance with the permit limits are monitored on monthly basis
Forests / Biodiversity / Land Use	KenGen has annual Government targets of issuing 150,000 tree seedlings to the communities living around our operation areas. The number of tree grown within the catchment per year are provided in the annual report and the COP 2021 report Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 https://www.kengen.co.ke/images/Communication.pdf
Air Pollution	KenGen carries out the annual air emission tests for all thermal plants and Diesel generators. This are done internally on a quarterly basis and externally on annual basis in compliance with the Air quality emissions regulations of 2014
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)	All the waste generated in our business areas are recorded based on their categories track and disposed in accordance to EMCA 1999 Waste management regulations 2006. The main waste streams include oily rags, waste oil and organic waste. Additional information and data is available in the annual and COP 2021 reports. Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 https://www.kengen.co.ke/images/Communication.pdf
Oceans	N/a

Optional comment

Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 - https://www.kengen.co.ke/images/Communication.pdf

4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

	Progress is reviewed against goals annually or more frequently	Progress is reported internally to the most senior level	Progress is reported externally	Other (Please provide additional information)
Climate Action
Energy & Resource Use
Water
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

Optional comment

Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 - https://www.kengen.co.ke/images/Communication.pdf

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

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Annual Report - https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf Cop 2021 - https://www.kengen.co.ke/images/Communication.pdf

Climate Action

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

Scope 1 Emissions

Full

None

KenGen has committed to BUSINESS AMBITION FOR 1.5°C. During the period we undertook capacity building in preparation for establishment of science based targets initiates program (SBTi). Currently, we are undertaking pilot assessment for two business operation areas i.e. Central Office and Geothermal Business Areas.

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

More information on KenGens actions on climate change may be accessed in the annual report COP 2021 report and other links provided below 1. https://www.kengen.co.ke/images/2021/15-KenGen-IR.pdf 2. COP26 -https://www.kengen.co.ke/index.php/information-center/news-and-events/kengen%E2%80%99s-ceo-rebecca-miano-among-top-cop26-panellists-on-climate-action.html 3. COP26 - https://www.kengen.co.ke/index.php/information-center/news-and-events/kengen-outlines-three-year-plan-to-accelerate-deployment-of-renewable-energy.html 4. Carbon Credits - https://www.kengen.co.ke/index.php/information-center/news-and-events/kengen-set-to-benefit-from-climate-action-carbon-credits.html 5. Global warming - https://www.kengen.co.ke/index.php/information-center/news-and-events/kengen-becomes-kenya%E2%80%99s-1st-public-service-company-to-join-the-un-backed-campaign-against-global-warming.html

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)

KenGen PLC committed to supporting the implementation of the 2019-2029 Kenya Energy Sector Environmental Program (KEEP) Action Plan by contributing KShs.10,000,000.00 (Ten Million shillings only) to be spread over a period of ten (10) years with effect from 2019-2020 financial year. Since then, KenGen has continued to honor the commitment and has provided the requisite technical support to the program on several tree growing projects. The projects are being undertaken in various counties totaling to 407ha. KenGen committed to raise and grow 2 million tree seedlings spread out in 5 years from FY July 2021/22 to June 2025 in partnership with National Environmental Trust Fund (NETFund). The commitment translates to growing/planting 400,000 quality tree seedlings every financial year.

Unknown

Optional comment

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

Optional comment

Today, KenGen has an installed capacity of 1,818MW which is about 64% of the national installed capacity. Of the 1,818MW, about 86% is drawn from green or renewable sources namely: • Hydro 46%, • Geothermal 39%, • Wind is about 1%. No other Country in the world has this high share of clean energy. In Kenya we currently have an installed capacity of 2,840MW. Of this Installed Capacity, • Geothermal is 29%, • Hydro 29%, • Wind 12%, • Solar 2%, • Thermal 28%. Over 80% of the Energy consumed in the country is from Renewable Energy Sources.

Technology

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

Percent of total revenue (%)

KenGen is a power generating company with 86% of our dispatch being from renewable sources (Hydro, Geothermal and Wind sources.) More information is available in COP 2021

Unknown

Not applicable (Please provide additional information)

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
The water used for hydro power generation is non consumptive since the whole amount is returned back to the river.
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water withdrawn in regions with high or extremely high water stress (%)

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total
Water that is with drawn from the rivers is used for hydro power generation is non consumptive since all of it is returned to the river.
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)

Optional comment

https://www.kengen.co.ke/index.php/information-center/news-and-events/kengen-donates-water-tanks-to-naivasha-residents-to-curb-water-shortage.html

13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

Hydro power generation cater for over 40% of the total energy generated by KenGen, however during the water stress period in case of drought this percentage reduces and we turn to other modes of power generation including Geothermal, Wind and thermal in order to stabilize the grid.

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
N/A
SOx
N/A
Volatile Organic Compounds (VOC)
N/A
Hazardous air pollutants (HAP)
N/A
Particulate matter (PM10)
N/A
Persistent organic pollutants (POP)
N/A
Other (please specify in text box)
14% of the Power generated by KenGen comes from the thermal sources. As a result we comply with Air quality emission regulation through acquisition of annual air emission license's for our thermal generating plant and our back up diesel generators. These licenses are issued by the National Environment Management Authority in Kenya. All our licenses are updated. In the next COP reporting KenGen will report on the total emissions across all sources, in tonnes, for each pollutant category

Sector-specific: Waste

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

Waste Generated (t)

79.5

Unknown

Not applicable (Please provide additional information)

Optional comment

The waste comprises of paper, organic waste, lube oils and oily rags

19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

Hazardous Waste Ratio (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

This comprises of the waste lube oils and oily rags from our generating plants

20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

The main activity of KenGen is power generation and therefore the amount of plastic waste generated is negligible. This main source is domestic waste within the staff camps .

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.

Introduction The UN Global Compact has designated this decade the “decade to deliver” on the UN SDGs and the promise of a greener, more equitable future. Meaningful climate action requires collaboration between stakeholders including governments, multinational organizations and development partners. KenGen is committed to the development of renewable power projects that create value for the Nation considering that Energy is an enabler of the socio-economic pillar of Kenya’s Vision 2030 national blueprint. The energy sector is the most significant contributor to greenhouse gas emissions (GHG) globally and is responsible for nearly three-quarters of human-caused greenhouse gas emissions. These emissions must be reduced substantially while ensuring energy for all. This is vital in accelerating the attainment of Sustainable Development Goal 7 aimed at ensuring access to affordable, reliable, sustainable, and modern energy for all, and Goal 13 aimed at combating climate change and its impacts. Kenya Climate Strategies in Energy Sector In December 2015, the Paris Agreement (PA) was adopted at the 21st Conference of the Parties (COP 21) of the UNFCCC in Paris. The PA charts a new course in the global climate effort by building upon the UNFCCC and, for the first time, bringing nearly all nations into a common cause in combatting climate change. The PA’s central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2°C above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5°C through low carbon development. Parties are required to undertake and communicate ambitious efforts to contribute to the achievement of these goals in the form of Nationally Determined Contributions (NDCs) communicated to the UNFCCC. Kenya’s NDC, which was submitted to the United Nations Framework Convention on Climate Change (UNFCCC), includes mitigation and adaptation actions. Kenya is committed to tackling climate change and has pledged through its updated NDC submitted to the UNFCCC in December 2020 to reduce greenhouse gas (GHG) emissions by 32% by 2030. This pledge focuses on Energy Sector as one of the key contributing sectors through the deployment of more renewable energy sources especially geothermal, solar, and wind. Climate change impacts have been experienced in Kenya and notably in the Energy Sector where we have experienced prolonged droughts which led to electricity outages. Clean and sustainable energy is therefore essential for Kenya’s sustainable development and is considered one of the infrastructure enablers of the socio-economic pillar of Vision 2030. The National Climate Change Action Plan (NCCAP -2018-2022), the tool to implement Kenya’s NDC, indicates that Kenya’s energy sector contribution to GHG emissions is expected to increase sharply from 2015 to 2030. The energy sector (excluding transport and industry), accounted for 7.1% of total emissions in 2015 and is projected to rise to 29.7% of total emissions in 2030. The NCCAP 2018-2022, therefore, seeks to ensure an electricity supply mix based mainly on renewable energy that is resilient to climate change. The actions to achieve this objective are through the development of 2,405 MW of new renewables (Geothermal: 913 MW, Solar: 442 MW, Hydro: 93 MW, Wind: 800 MW, Biomass/Biogas: 157 MW and Distributed solar and mini-grids: 30 MW) by 2022. Our efforts towards Net-Zero transition The pledge to reduce greenhouse gas (GHG) emissions by 32% by 2030 focuses on Energy Sector as one of the key contributing sectors through the deployment of more renewable energy sources especially geothermal, solar, and wind. KenGen has adopted a green energy strategy in expanding its generation with an emphasis on renewable sources such as geothermal, hydro, wind, and solar. This is a critical role in moving Kenya towards a green economy trajectory, currently, we are developing an 83.3MW Olkaria I unit 6 Geothermal plant and undertaking rehabilitation and upgrade of Wanjii Hydro Power Station to 9.6 MW. KenGen has committed to aligning its activities to the ambition of keeping warming to 1.5°C through the implementation of renewable energy projects that contribute to emissions reductions, considering that over 80% of the energy consumed in the country is from Renewable Energy Sources. We have firmed up our path towards carbon neutrality by 2050 by joining the elite list of Global Multinational and becoming the first company in Kenya’s public sector to commit to business ambition for the 1.5°C campaign. On 8th June 2021, we received confirmation on admission to the Business Ambition for 1.5°C thus joining the list of visionary leaders on the UN Global Compact website and their partner websites at CDP- https://www.cdp.net/en and We Mean business - https://www.wemeanbusinesscoalition.org/ The Company is developing its Science Based Targets towards a 1.5°C campaign. We participated in the Climate Ambition Accelerator program from June to December 2021 and two of our Staff completed the program and were awarded Certificates. The Company is currently undertaking pilot Carbon Footprint analysis in two of its Business Areas namely Geothermal Division and Central Office covering Direct Emissions (Scope 1) and Indirect Emissions (Scope 2 and 3). This analysis will go into the establishment of a Baseline for the development of our science-based targets by 2023. Our Carbon Emission Reductions Portfolio In line with the United Nations Framework Convention on Climate Change (UNFCCC), we have developed and registered six Clean Development Mechanism (CDM) projects which contribute to approximately 1.5 Million tCO2e annually. To date, our verified projects have resulted in the issuance of 4,991,923 tCO2e Certified Emissions Reductions (CERs). During the period 2020/2021 we obtained 4,617,309.00 tCO2e Certified Emissions Reductions (CERs) issued; No Project Mode of Generation Issued CERs (tCO2e) 1. Kiambere Hydro 160,160 2. Tana Hydro 57,458 3. Ngong 5.1MW Wind 23,868 4. Olkaria II Geothermal 309,495 5. Olkaria I AU 4&5 Geothermal 2,040,515 6. Olkaria IV Geothermal 2,025,813 Environmental Sustainability Statement In an emerging economy gravely affected by a ranging pandemic, heavily regulated by stringent climate change policies and conflict adherence programs, KenGen weathered through its environmental sustainability agenda which is anchored on Environmental Social Governance (ESG) and interrelated conflict resolution mechanisms. Our environmental sustainability programs encompass responsible interaction with the natural resources in our business and avoid jeopardizing the ability of future generations to meet their needs. Responsible environment management, biodiversity conservation, projects monitoring & appraisal, and climate change services are at the core of various modes of sustainable energy generation. Global Leadership in Climate Change KenGen was invited by the UK Prime Minister to participate in the Leaders’ Summit at the COP26 Summit in Glasgow, United Kingdom, on November 2, 2021, with the focus being ‘Accelerating Clean Technology Innovation and Deployment’. KenGen Managing Director and other Panelists at the World Leaders Summit The Managing Director and CEO delivered her speech at the panel discussion at World Leadership Summit with a focus on power, road transport, hydrogen, and steel. She showcased the acceleration of Renewable Energy by KenGen in Kenya and the Region through the services we offer including Geothermal drilling and Consultancy. This is in line with Kenya’s commitment to have 100% Renewable Energy by 2030. KenGen MD & CEO participated in a panel discussion during the launch of the Carbon Dated Report by the Standard Chartered Bank on 15th July 2021 that looked at the risk & opportunities for suppliers as multinational corporations transition to Net-Zero. From left Executive Director, AFDB Eastern Africa, Cheptoo Amos Kipronoh, PS Environment, Dr. Chris Kiptoo, Energy CS, Dr. Monica Juma, KenGen CEO Rebecca Miano, KenGen Director, Mary Maalu, and other representatives of #TeamKenya at COP26. KenGen MD & CEO participated in a panel discussion during the launch of the Carbon Dated Report by the Standard Chartered Bank on 15th July 2021 Sustainable Environmental Management Our environment sustainability policy guides our operations and activities to comply with applicable environmental laws, regulations, standards, and requirements we subscribe to. KenGen has continued to implement an Environmental Management system that complies with International Standards and has maintained ISO 4001 Certification from 2009 to date with regular external certifications audits. In the year under review, we were recertified to both ISO 9001 and ISO 14001 Standards, demonstrating our commitment to running our business responsibly and sustainably. During the year under review the following environment management activities were accomplished; Environment Social Impact Assessment studies conducted and Environment Impact Assessment license issued insert infographic • Proposed Energy Research & Development Centre and Corporate Archive Building in Upper Tana • Proposed Ngong Wind Farm Borehole Project • Renewal of EIA license for Seven-Forks PV Solar Project (42.5MWe). Initial Environment audits • Olkaria Geothermal Wellheads (OW-37, OW-39, OW-905 & OW-919) • Turkwel Power Station facilities (Incinerator, wastewater treatment lagoon & asbestos bunker) Statutory self-annual audits carried out in 35 KenGen’s facilities and installations Pollution Control & Waste Management (Wastes stream) We have put in Pollution control measures and mitigated negative environmental impacts, while at the same time enhancing positive environmental impacts resulting from our activities, products, and services. Improve infographic The waste is managed and disposed of by firms registered by the National Environment Management Authority as required by waste management regulations of 2006. A culture of waste segregation has been inculcated through regular awareness sessions, signages, and the provision of appropriate waste bins. During the year under review, we acquired emission licenses for our incinerators and Thermal Plants (Muhoroni Gas Turbines 1& 2 and Kipevu I & III). We also acquired effluent discharge licenses for applicable facilities such as Turkwel lagoon, Muhoroni oil-water interceptor, Kipevu I, and III oil-water interceptors as provided in Kenya’s Water Quality Regulations, 2006. Stack emission monitoring and measurement We carried out quarterly monitoring & reporting of air quality emissions in 18 power generation and affiliated facilities in fulfillment of legal and regulatory requirements. Projects appraisals and Monitoring Our ongoing projects were appraised and monitored during the period under review including:- • Preliminary Environmental & Social Impact Assessment under feasibility for the Floating Solar PV. • Environmental &Social Impact Assessment studies for upgrading of Gogo Power Station • The Marsabit wind project Environmental &Social Impact Assessment • Scoping for the Raising of Masinga Dam project. • Waste to Energy Preliminary Environmental &Social Impact Assessment. • Environmental and Social Management Plan (ESMP) for Olkaria IV and I AU 4 &5 uprating. • 7 Forks Solar PV Stakeholder consultation and archaeological survey Biodiversity Conservation and Catchment Restoration KenGen recognizes the significance of ecological restoration and enhancement in key catchment areas of Mt. Kenya, Mau Complex, and Eburru Forest. In the year under review total of 181,031 trees were planted which have a net potential of absorbing 42,257 tons of CO2 annually. The 2 billion Trees Campaign KenGen continues to support the Government of Kenya’s commitment of planting 2 billion trees campaign to accelerate the achievement of the 10% tree cover by 2022 of the land area of Kenya. Towards this objective, KenGen has distributed to the communities and institutions over 1.9 million tree seedlings which are equivalent to 3,167 acres for the last 7 years to enhance the sustainability of the ecosystem Ngong hills catchment conservation project Partnerships KenGen during the year partnered with other National Institutions in the commemoration of the Word Desertification and Drought Day held at Dr. Ribeiro secondary. The national event was held at Marsabit County, Chalbi desert with the participation of 3 KenGen staff. 110 seedlings were issued and planted at Dr. Ribeiro secondary school in celebration of the World Drought and Desertification Day and in the national event for the commemoration of World Environment Day held on 5th June 2021 at Garissa University. KenGen during the year also hosted the Celebration of the World Habitat Day. The National Observance of World Habitat Day themed: “Accelerating Urban Action for a Carbon-free World,” was held at Olkaria Geothermal Spa where two Government Ministers graced the occasion. KenGen MD welcoming the Government Ministers to Olkaria Spa for the Celebration of the World Habitat Day The celebration aimed to amplify the global Race to Zero Campaign and UN-Habitat’s Climate Action for Cities and encourage local governments to develop actionable zero-carbon plans in the run-up to the International Climate Change Summit COP26 in November 2021. Partnerships for enhanced conservation KenGen is a key player in the implementation of the Kenya Energy Sector Environment Program (KEEP) project which is steered by the Ministry of Energy This project is supporting the achievement of the GOK agenda on attaining the 10% forest cover by 2022 and conservation of water catchment areas with a view of sustaining hydropower generation. During the year under review, 3 projects have been initiated and are at different levels of implementation • 100 ha of catchment rehabilitation in Aberdare catchment, • Restoration of 20km of riparian land along Mathioya river in Muranga County • Restoration of 107 ha at Londiani forest within Mau complex • Ngong hills soil conservation /land reclamation project procurement for the rehabilitation works underway. Rehabilitation to be affected in 2021/2022 FY Further, KenGen has committed to contributing 2 million seedlings to National Environment Trust Fund (NETFUND), 2 billion trees growing campaign between 2021-2025. Energy efficiency We regard prudent energy efficiency as an important component of business sustainability Our Energy efficiency program is focused on putting in place measures that comprise energy-saving devices, rational saving methods, and using alternative energy sources. In this regard, we have developed and implemented an energy policy and energy management program to conform with Energy (Energy Management) regulations in 2012 and reap the benefits of energy management through cost savings. In the last one-year KenGen conducted energy audits in Kipevu I, Kipevu III, Masinga, and Gitaru power plants and is implementing the following recommendations: • Efforts that have been put in place to manage energy consumption in KenGen facilities include, • Implementation of solar PV project in Kipevu; Installation of solar street lights in Kipevu, Kamburu, and Gitaru; • Replacing high energy-consuming lighting fixtures with LED lighting in all KenGen facilities; and • Minimizing energy imports from the grid through load management during curtailment. We are implementing a revamped technical assurance framework to support OPEX optimization, efficiency and improve maintenance practices. This is done by carrying out root cause analysis on recurrent O&M challenges to reduce revenue leakages (root cause analysis for Olkaria IAU currently ongoing) and execution support during major maintenance works to optimize the maintenance costs currently being done during Masinga Unit 2 rehabilitation • KenGen has so far realized total energy savings of 1,622,950kWh, amounting to CO2 reductions of 535,574Kg. annually. • Energy management teams in all the regions to oversee energy management programs • 40 employees have gone through the Certified Energy Manager training. Stickers We kept our promise 2020 Commitments Status in 2021 1. Enhance monitoring and evaluation of the environmental aspects and prepare a corporate report. Annual Monitoring and Evaluation of our Environmental Aspects was done during the year and reported during the Annual Environmental Self-Audits done from October to December 2021. 2. Carry out all the statutory environment audits. 28 environmental audit reports were done and submitted to the National Environment Management Authority. Environmental management plan being implemented on the issues raised 3. Register new green projects including three projects under implementation i.e. Olkaria V, Olkaria I additional unit 6, Olkaria I rehabilitation. The registration of the new projects was delayed due to the postponement of COP26 that was expected to determine continuity of Kyoto Protocol projects post-2020 due to the Covid 19 pandemic. A decision on Article 6 was finally agreed at COP26 in Glasgow, the UK including the transition of Kyoto Protocol projects Article 6 projects in November 2021. 4. Continue to engage in initiatives aimed at piloting operationalization of Article 6 of the Paris Agreement which is the successor to the Kyoto Protocol to take advantage of the emerging opportunities in the Climate Finance arena. During the period, we participated in a World Bank Pilot on the operationalization of Article 6 of the Paris Agreement. 5. Continue with the engagement of National Stakeholders including the Climate Finance Unit of the Government of Kenya National Treasury, the Climate Change Directorate, and Development Finance Institutions (DFI) to benefit from the emerging opportunities in the Climate Finance arena We participated in engagements organized by the Climate Change Directorate in the year 2021 including participating in the COP26 meeting at Glasgow, UK in November 2021. 6. Seek other avenues to trade the company’s CERs considering the changes in the global Climate Change arena which includes the end of the Kyoto Commitment period and coming into force of the Paris Agreement. KenGen is currently in the process of selling its issued carbon credits through an open international tender. 7. Enhance resource sustainability by growing 150,000 tree seedlings within the KenGen operation areas. 181,000 tree seedlings issued 8. Implement a 10-year tree planting project for schools with a target of 1,000 schools by 2023. 100 schools in Makueni, Kitui, and Machakos enrolled in the Schools Green initiative program, making a total of 700 schools that are participating. Our commitment in 2022 • Enhancement of Sustainability /Environmental Social Governance and Revenue Diversification • Implement UNGC Program on Business 1.5˚C Commitment by 2023 • Carry out environmental and social audits in all our installation • Support Conservation through enhanced partnership (KEEP, NetFund, KenGen Foundation) • Provide 180,000 tree seedlings to catchment area communities within our operation areas • Commemoration of 3 national environment conservation events • Enhance Operational Efficiency and Safety • Participate in at least 3 UNGC programs at national and Global levels • Create awareness on 50% of our employees on Sustainable development goals and the ten principles of UNGC.

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

This is supported by the Company's Anti-Corruption policy

Optional comment

This is supported by the Company's Anti-Corruption policy We are committed to conducting our business with honesty and accountability to the interest of all our stakeholders. The Company, therefore, adopted several strategies aimed at building a resistant culture to corrupting and unethical behaviour. We have demonstrated due care and diligence in the fight against corruption by developing policies that guide our employee’s board members and other stakeholders including vendors. Our Anti-Corruption & Bribery policy provides clear guidelines on prevention measures within which our employees, management, and other stakeholders operate. The policy defines our corruption prevention operating framework. Our Gift & Entertainment Policy guides our employees to make the right decisions when giving or accepting gifts, courtesy, entertainment or travel while conducting business on behalf of the Company. In the year under review, 35 employees declared gifts received. We have provided various channels of reporting actual or suspected wrong-doings committed by employees, suppliers, service providers, contractors, or other stakeholders dealing with the Company. Anonymous reporting is also done through our hotline number https://www.kengen.co.ke/index.php/anonymous-report22.html. Our Whistleblowing policy provides assurance that any employee or stakeholder making a report will be protected from reprisals, retaliation, or any adverse treatment. We developed a Conflict of interest Policy to give measures to identify, manage and avoid existing and potential conflicts of interest within our business environment and set out the roles and responsibilities of relevant parties. KenGen maintains a conflict of interest register that is updated on regular basis. Our Employees’ code of conduct & Ethics stipulates employees’ expected behaviour both with the Company and in Public as per the Public Officers Ethics Act. Every new employee is expected to sign the code of conduct and abide by it. All employees have signed the code of conduct. While suppliers are independent entities from our Company, the business practices and actions of suppliers, when conducting business with or on behalf of the Company, may significantly impact reputation and relationship of trust with our Company clients, employees, and other stakeholders. The Suppliers’ Code of Conduct outlines guidelines that suppliers must abide by while doing business with us. To ensure that the recruitment process is transparent and that the company attracts employees who are qualified, we usually carry out due diligence for all our recruits before joining the company. During the year under review, 185 due diligence was carried out on the recruitment process. • https://www.kengen.co.ke/index.php/anonymous-report22.html • Additional information is provided in the COP report 2021

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

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

We have stand alone policies on conflict of interest , gifts and donations and are available to all staff . Additional in formation is accessible through the link below; https://www.kengen.co.ke/index.php/anonymous-report22.html

Prevention

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

Optional comment

At KenGen Anti-Corruption training is actualized through awareness programs , publication of articles in an internal KenGen weekly newsletter, Integrity Structured information, education and communication materials and public sensitization programs. Further to the awareness programs the following initiatives have been implemented:- (i) Establishment of an Integrity Office To promote ethics & integrity in the Company, we have established a fully-fledged integrity office with the mandate of coordinating anti-corruption activities. The office is headed by a senior officer who reports to the top management. This ensures the top management is well versed with integrity-related issues. (ii) Corruption Prevention Committees: To monitor implementation of integrity activities, KenGen has established a vibrant corporate Corruption Prevention Committee (CPC) which has undergone integrity training. This committee was trained by the constitutionally mandated government anticorruption oversight agency (Ethics & Anti-Corruption Commission) to empower the committee with the latest skills in dealing with the ever-emerging forms of integrity breaches. The committee chaired by the Managing Director & CEO met regularly to monitor progress on the implementation of integrity initiatives. As part of ensuring that Integrity management is entrenched in all our business areas, we have established regional Corruption Prevention Committees which are chaired by the respective Region Managers. In the year under review, 6 meetings were held by the corruption prevention committees. KenGen conducts periodic sensitization sessions for the Access to Government Procurement Opportunities (AGPOs) . These include youth ,women and people living with disability More information in provided in the COP report 2021.

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

Integrity Champions : Employees drawn from our business areas are nominated as integrity champions. The officers are taken through comprehensive training by Ethics & Anti-Corruption Commission (EACC). The champions are tasked with the role of spearheading ethics and integrity within their functional areas. A total of 106 Integrity champions have been trained.

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

For employees, monitoring is done through quarterly progress meetings and administration of questionnaires to asses knowledge, attitude and practices. For automated control monitoring , we have anonymous reporting system. For external monitoring we submit quarterly reports to the Ethics and Anti corruption Commission of Kenya. We also submit annual Ethics compliance reports to Public Service Commission of Kenya and National Cohesion and Integration Commission .

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	13
The cases received during the calendar year 2021 were as follows: Forgery – 4 Vandalism/Theft 2 Unethical conduct/Malpractices(conflict of interest) -9 Sexual Harassment -1
Confirmed during the current year, and related to this year

Optional comment

The cases received during the calendar year 2021 were as follows: Forgery – 4 Unethical conduct/Malpractices -9

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)

Two cases of non-compliance were internally investigated in the period under review and conclusively closed

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)

We collaborate with UNGC, Kenya Anti-corruption agency , Kenya police, Directorate of Criminal Investigations, complaints Board on public procurement and parliamentary committees

Optional comment

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.

Inculcating a culture of ethical behavior through trainings, workshops and circulars from the Top Management. As part of processing the incidences received on integrity breaches, our Company has an established investigations process where incidences reported are investigated and disciplinary action instituted depending on the severity of the breach. During the period under review, 23 incidences were investigated and action taken. Disciplinary action is taken as part of enforcing the code of conduct. Disciplinary action is taken against the employees whose cases have been investigated and recommendations for disciplinary action has been given. During the period under review, 20 employees were put through the disciplinary process. Our partners in enhancing ethics and integrity KenGen understands the importance of partnering with other government agencies in enhancing the implementation of initiatives aimed at promoting ethics and integrity within the Company. The partners assist in awareness creation, law enforcement agencies and support in conducting investigations where members of the public are involved. Other programs implemented during the period include:- 1.Implementation of Vendors Code of Conduct- the code of conduct has been approved and dissemination has been done in Eastern Region, Western Region where 40 % of suppliers were reached. The pending areas are the Central office, Kipevu and Turkwel 2. Integrity Risks Management - Risk Assessment & Mitigation Plan was reviewed, 3. Staff awareness programs 12 integrity-related articles on KenGen weekly and One (1) virtual sensitization meeting was done . 4. Implementation of ISO 37000:2016(E) Anti-bribery Management system - The Standard was purchased for use within the organization and the training on the requirements if the ISO standards is still ongoing. The review of the Anti-Bribery Policy is pending approval of a model procedure from the Ethics & Anti-corruption commission. Commitments going forward: 1. Enhanced monitoring of corruption risks within the Company 2. Continue engaging stakeholders more e.g. suppliers on doing clean business with KenGen 3. Implement targeted awareness sessions for employees working in high-risk functions 4. Conducting an annual integrity week 5. Implement ISO 37000:2016(E) Anti-bribery Management system 6. Working with EACC in developing anti-bribery policy