2022 Communication on Progress

SERIS

Published date

June 30, 2022

No. of questions

59

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

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

    No, this is not a current priority

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

    Yes, and the commitment is focused on our own operations

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No, this is not a current priority

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

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Nevertheless, the Seris Group has several commitment charters (environmental charter, responsible purchasing charter, Group CSR policy, etc.)

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

    No one is specifically responsible for this topic

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

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

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No formal structure

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

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

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    However, the Group has a structure by countries.

    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
    The risk assessment process is carried out as part of our prevention and improvement systems. Concerning environmental risks, ISO 14001 certification is in place for some activities per country.

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

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

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

    Optional comment
    Group members can report their concerns on these issues via an email address, as well as a dedicated platform currently being deployed.

    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
    A dedicated platform for the Group is being deployed. Business partners will have access to this new platform.

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Major incidents are subject to root cause analysis with modification of internal and external processes according to the sphere of influence.

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

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

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    14

    Male (%)

    78.5

    Female (%)

    21.5

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    36

    Above 50 years old (%)

    64

    From minority or vulnerable groups (%)

    0

    Executive (%)

    50

    Independent (%)

    50
    Optional comment
    The governance of the Seris Group is based on two bodies: the Governance and Animation Board (7 members) and the Executive Committee (7 members).

    13. Do you produce sustainability reporting according to:

    Group CSR Report

    Data Assurance

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

    In accordance with regulations, all of the Group's European subsidiaries have carried out an energy audit (and for France a GHG assessment) by a third party.

  • Human Rights

    Materiality / Saliency

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

    Response

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

    In the conduct of its activities SERIS undertakes, in its sphere of influence, to respect and to promote the implementation of the universal principles of human rights and laws in each country where the group is present, regardless of the local context. In General and in all circumstances, SERIS undertakes within its organisation to observe international, national and local regulations as well as the rules of professional conduct related to its activities, and expects all employees and stakeholders of the group to demonstrate the same commitment.

  • 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

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    Forced labour

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    Child labour

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    Non-discrimination in respect of employment and occupation

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    Occupational safety and health

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    Working conditions (wages, working hours)

    Group CSR Policy (April 2018) / Responsible Purchasing Charter (Nov. 2017)

    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

    Forced labour is not a material issue for our security services firm.

    Child labour

    Child labour is not a material issue for our security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    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

    Forced labour is not a material issue for a security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    Child labour

    Child labour is not a material issue for a security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    With regard to working conditions, the Group is committed to the stakeholders concerned in accordance with the regulations applicable in each of the countries where it operates.

    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

    The actions undertaken in terms of Freedom of association and the effective recognition of the right to collective bargaining are local and directly linked to the regulatory context in force in each country.

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    The actions undertaken in terms of non-discrimination in respect of employment and occupation are local and directly linked to the regulatory context in force in each country.

    Occupational safety and health

    Working conditions (wages, working hours)

    The actions undertaken in terms of working conditions are local and directly linked to the regulatory context in force in each country.

    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
    Forced labour and child labour are not material issues for a security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    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

    Forced labour is not a material issue for a security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    Child labour

    Child labour is not a material issue for a security services firm. Nevertheless, our strategic suppliers are committed to respecting this issue via our responsible purchasing charter.

    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 (%)

    46

    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 (%)

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    14

    Non-executive board

    28

    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 (%)

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

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    8.8
    Optional comment
    The frequency rate is calculated in the following way: Number of recordable work-related injuries / total number of hours worked by workers in the reporting period.

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    2.76
    Optional comment
    The incident rate is calculated in the following way: Total number of lost days / total number of hours worked by workers in the reporting period * 1000 (0.00276 * 1000).

    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

    Forced labour is not a material issue for our security services firm.

    Child labour

    Child labour is not a material issue for our security services firm.

    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.

    Anyone working for or with SERIS is entitled to a safe and healthy working environment. The preservation of health and safety of employees and third parties as part of its benefits is a top priority for SERIS. We undertake to take all necessary measures to prevent accidents. All subsidiaries and SERIS personnel are aware of and involved in the prevention approach of the Group. Security is everyone’s business. SERIS group’s aim is to consolidate human capital by giving meaning to the work of the men and women who have chosen this business, by offering the most favourable working conditions possible to attract and retain talent and encourage a continued and qualitative social dialogue.

  • 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

    Group Environnemental Charter

    Water

    Oceans

    Forests / Biodiversity / Land Use

    The topic "Forests / Biodiversity / Land Use" is not material to our activities (security services)

    Air Pollution

    The topic "Air Pollution" is not material to our activities (security services)

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

    The topic "Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)" is not material to our activities (security services).

    Energy & Resource Use

    Optional comment
    In our security services activities, the use of energy and resources is very limited. For this reason, this issue is not a dedicated policy within our organisation.

    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
    Seris Group's environnemental charter is available on our group website.

    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
    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    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
    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    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

    Regarding Energy, the Group's subsidiaries have carried out an energy audit.
    Optional comment
    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    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

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Water

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Oceans

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Forests / Biodiversity / Land Use

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Air Pollution

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

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

    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Energy & Resource Use

    Optional comment
    These environmental issues are not material to our organization, as a security services provider. However, in the course of its activities, the SERIS Group takes into account the environmental and monitors its main impacts while seeking to limit them.

    Climate Action

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

    Scope 1 Emissions

    Seris' global gross greenhouse gas emissions are not measured in all country subsidiaries and therefore cannot be reported globally on a consolidated basis.

    Emissions (tCO2e)

    Scope 2 Emissions

    Seris' global gross greenhouse gas emissions are not measured in all country subsidiaries and therefore cannot be reported globally on a consolidated basis.

    Emissions (tCO2e)

    Scope 3 Emissions

    Seris' global gross greenhouse gas emissions are not measured in all country subsidiaries and therefore cannot be reported globally on a consolidated basis.

    Emissions (tCO2e)

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

    Percent of revenue (%)

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

    Energy / Resource Use

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

    % of total energy consumption

    Technology

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

    Percent of total revenue (%)

    As a security service provider, we do not sell environmentally friendly products or services.

    Sector-specific Questions

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

    Optional comment
    Seris is a security services provider

    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

    Water is not a material topic for Seris, as a security services provider.

    Groundwater:

    Water is not a material topic for Seris, as a security services provider.

    Surface water:

    Water is not a material topic for Seris, as a security services provider.

    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 is not a material topic for Seris, as a security services provider.

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

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

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

    Water intensity of products (cubic meter/$):

    Water is not a material topic for Seris, as a security services provider.

    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

    The amount of pollution generated by Seris is negligible.

    SOx

    The amount of pollution generated by Seris is negligible.

    Volatile Organic Compounds (VOC)

    The amount of pollution generated by Seris is negligible.

    Hazardous air pollutants (HAP)

    The amount of pollution generated by Seris is negligible.

    Particulate matter (PM10)

    The amount of pollution generated by Seris is negligible.

    Persistent organic pollutants (POP)

    The amount of pollution generated by Seris is negligible.

    Other (please specify in text box)

    The amount of pollution generated by Seris is negligible.

    Sector-specific: Waste

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

    Waste Generated (t)

    The amount of solid waste generated by Seris is negligible.

    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 (%)

    Seris does not generate hazardous waste in the course of its activities.

    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)

    The amount of plastic waste generated by Seris is negligible

    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.

    Within the framework of its activities, the SERIS Group takes into account the environmental dimension and monitors its main impacts, although these are very limited, while seeking to control them. SERIS Group's Environmental Policy is based on the following guiding principles: - To reduce the impact of our activities on the environment - To recycle our waste and participate in the enhancement of our materials - To invest in opportunities to reduce our environmental footprint - To raise awareness of Eco-gestures and encourage internal initiatives - To integrate environmental criteria into our supplier and partner relationships - To participate in the correct application of our clients' on-site environmental policies To continually improve its environmental performance, the SERIS group keeps track of the effective implementation of the above principles and their results. These principles are deployed by all our subsidiaries through concrete actions in accordance with the rules applicable in each of the countries in which the Group operates.

  • Anti-corruption

    Commitment

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

    Set up of program in 2018. Regularly reviewed and adjusted to be in line with changes within the Group

    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
    Code of conduct dedicated to anti-corruption

    Prevention

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

    Optional comment
    Information and awareness program to all employees Specific training program dedicated to employeed deemed "at risk" (commercial department, supply department) and management board members

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

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

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    no confirmed incident

    Confirmed during the current year, and related to this year

    0
    no report (yet) this year

    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?

    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.

    Corruption risk mapping currently reviewed Implementation of a new whistleblowing platform on-going Code of conduct to be updated after completion of nex risk mapping Governance of compliance matters to be reviewed (Ethics comittee)