Report - COP Prototype

2022 Communication on Progress

Telefonica Colombia

Published date

July 6, 2022

No. of questions

Supplemental files

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

For more information visit: https://www.telefonica.co/informes-anuales

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

For more information: https://www.telefonica.co/informes-anuales https://www.telefonica.com/es/wp-content/uploads/sites/4/2021/03/NuestrosPrincipiosdeNegocioResponsable.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

For more information: https://www.telefonica.co/informes-anuales https://www.telefonica.com/es/wp-content/uploads/sites/4/2021/03/NuestrosPrincipiosdeNegocioResponsable.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

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

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

Prevention

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

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

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

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

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

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

Concerns and grievance mechanisms

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

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

For more information visit: https://www.telefonica.co/informes-anuales

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)
All communications received shall be treated in accordance with the principles of respect, confidentiality, substantiation and completeness, and shall be governed by a procedure for the handling and repetition of communications received. https://www.telefonica.com/es/wp-content/uploads/sites/4/2021/08/Canal-Negocio-Responsable-Proceso-Recepcion-y-Tramitacion-Comunicaciones.pdf For more information (125-130): https://www.telefonica.co/documents/1285851/415004464/Informe+Gesti%C3%B3n+Responsable+2021+-+Reporte+Gesti%C3%B3n+BIC+%281%29.pdf/a6ac4109-f183-df9f-3b42-c0a6de74e097

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

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

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

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

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

Board Composition

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

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	10
Male (%)	90
Female (%)	10
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	20
Above 50 years old (%)	80
From minority or vulnerable groups (%)	0
Executive (%)	70
Independent (%)	30

Optional comment

For more information: https://www.telefonica.co/junta-directiva ; https://www.telefonica.co/informes-anuales

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)

https://www.telefonica.co/documents/1285851/415004464/Informe+de+Seguimiento+Financiaci%C3%B3n+Sostenible+2021.pdf/4cf3ccfb-9a0b-8d84-df0b-87bdbcadb518

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	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
Rights of women and/or girls
2021
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
2021
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights 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 human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
https://www.telefonica.com/es/sostenibilidad-innovacion/privacidad-seguridad/seguridad/
Rights of women and/or girls
https://www.telefonica.com/es/talento/diversidad-e-inclusion/
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Optional comment

*Human Rights: https://www.telefonica.com/es/sostenibilidad-innovacion/sociedad/derechos-humanos/ *Value Chain: https://www.telefonica.com/es/sostenibilidad-innovacion/como-trabajamos/cadena-de-valor/

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human 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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human 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 to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human 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.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human 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)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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.

Gestionar de forma responsable el respeto y la promoción de los derechos humanos de las comunidades en las que estamos presentes, en nuestras operaciones y cadena de suministro estableciendo procesos, políticas y normas que velan por el respeto y aplicación de derechos humanos sociales, económicos y culturales internacionalmente reconocidos. Utilizamos la debida diligencia para identificar, prevenir y evitar la vulneración de los derechos humanos también en entornos digitales y nos comprometemos a proporcionar un remedio justo y equitativo en el caso de provocar un efecto adverso sobre los derechos humanos. Esta gestión en línea con el marco de los Principios Rectores sobre las Empresas y los Derechos Humanos. (Pages 133-139): https://www.telefonica.co/documents/1285851/415004464/Informe+Gesti%C3%B3n+Responsable+2021+-+Reporte+Gesti%C3%B3n+BIC+%281%29.pdf/a6ac4109-f183-df9f-3b42-c0a6de74e097

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
2022
Forced labour
2022
Child labour
2022
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
2018
Working conditions (wages, working hours)
2020

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

https://www.telefonica.com/es/wp-content/uploads/sites/4/2021/03/NuestrosPrincipiosdeNegocioResponsable.pdf https://www.telefonica.com/es/wp-content/uploads/sites/4/2021/02/PoliticaSostenibilidadCadenaSuministro.pdf

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	0

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 (%)	0

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

	Percent of women (%)	Unknown
Senior leadership level position	38.8
Non-executive board	10

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 (%)	0.8

Optional comment

In 2021, the equal pay indicator stood at -0.80%, which presents the comparison between the average total compensation of men vs. to the average total remuneration of women. As the indicator is negative, it refers to the fact that the average remuneration of women was higher to the average total of 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	0.73

Optional comment

Constante K=200.000

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0.81

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.

The Responsible Business Principles guide the actions of the Company, including labor rights. The Responsible Management Report elaborates on the management carried out in 2021: https://www.telefonica.co/documents/1285851/415004464/Informe+Gesti%C3%B3n+Responsable+2021+-+Reporte+Gesti%C3%B3n+BIC+%281%29.pdf/a6ac4109-f183-df9f-3b42-c0a6de74e097

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
2019
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

Telefónica's Environmental Policy is the reference document that guides the Company in the medium and long term in the development of its environmental strategy. Designed in accordance with ISO 14001:2015, setting out our commitments to caring for natural resources.

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

This Policy is based on three converging goals: − Risk management and legal compliance in environmental matters. − Improvement of eco-efficiency within the organisation. − Promotion of digital solutions to help our customers to rise to the great environmental challenges which face the whole of society. This Policy establishes the principles which guide the Company on a global and local level to support and improve its environmental performance. It is therefore a point of reference for all staff, while enabling Telefónica's public position on environmental matters to be strengthened, responding to the demands of our principal stakeholders.

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

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

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

We pay special attention to legislation in areas such as waste management, efficient use of resources, respect for the landscape and the measurement of electromagnetic fields. We share facilities with other carriers or companies which manage the communication towers. The result is less visual impact and reduced energy consumption, as well as reducing waste. We promote energy efficiency and use renewable energy to reduce CO₂ emissions as part of our strategy to be part of the solution to climate change. We shut off old networks so that they no longer consume energy,and we recycle all the materials derived from their decommissioning. We respect biodiversity with precautionary measures during construction, locating base stations outside protected areas whenever possible and through corrective measures when necessary.

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

In order to control our footprint, we ensure compliance with environmental legislation and prevent risks, we have an Environmental Management System which enables us to ensure global standards in all homogeneous processes and indicators for rigorous monitoring.

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

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

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

14101

Scope 2 Emissions

Full

None

Emissions (tCO2e)

20970.93

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

131624.34

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

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

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

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

We have taken action to increase resilience in our supply chains

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

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

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

Other (Please provide additional information)

Unknown

Energy / Resource Use

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

% of total energy consumption

Unknown

Technology

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

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites	3
Hectares	10.0483

Optional comment

Tenemos 3 sitios en áreas protegidas de PNN con un área de 1004,83 m2

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

Ninguna

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

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.

https://www.telefonica.co/documents/1285851/415004464/Informe+Gesti%C3%B3n+Responsable+2021+-+Reporte+Gesti%C3%B3n+BIC+%281%29.pdf/a6ac4109-f183-df9f-3b42-c0a6de74e097

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

2022

Optional comment

The organization has implemented an anti-corruption compliance program in line with the requirements of ISO 19600 -Compliance Management Systems- and 37001 -Anti-Bribery Management Systems- standards. Our Anti-Corruption Compliance Program was reviewed as part of the internal audit and external certification audit of ISO 37001:2016.

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

Colombia Telecomunicaciones S.A. E.S.P. BIC has a procedure named CUM-DT-0100000002 Manual of Compliance Inbox, which establishes the guidelines for the formulation and attention of queries related to policies and regulations on ethics and Integrity issued by the Telefonica, including those associated with conflicts of interest, sponsorships, relationships with public officials and invitations and gifts, among others. Currently, the Compliance Inbox is managed by the Compliance Office and may be used by any person inside or outside the organization. Our Compliance Inbox is the e-mail ofc.cumplimiento.co@telefonica.com. Notwithstanding the above, the company also has the following consultation channels: (a) Conflict of Interest Declaration Tool. b) Register of Gifts and Invitations to Public Officials/Employees.

Prevention

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

Optional comment

Colombia Telecomunicaciones S.A. E.S.P. BIC has a procedure named CUM-IS-0100000002 Methodology for the Development of Compliance Training and Awareness Activities, which regulates the anti-corruption and integrity training activities carried out by the Compliance Office. The target audience of these activities includes all employees and allies or suppliers of the organization.

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

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

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Colombia Telecomunicaciones S.A. E.S.P. BIC supervises its anti-corruption compliance program through the following mechanisms: -Monitoring of authomatic reports and indicators based on the conflict of interest declaration tool and the register of invitations and gifts to public entities. -Internal and external audits of the Anti-Bribery Management System (SGAS). -Autonomous reviews carried out by the Compliance Office based on alerts or risks identified.

Response and Reporting

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

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
0
Confirmed during the current year, and related to this year	0
0

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)

Colombia Telecomunicaciones S.A. E.S.P. BIC has a Complaint Management Policy that establishes the guidelines about the reporting and investigation of internal wrongdoing, including those concerning acts of corruption. This policy includes the following stages: 1. Preliminary analysis of the facts reported. 2. Verification of the reported facts. 3. Resolution of the report. Additionally, when the wrongdoing is associated with a disciplinary infrigement, the results are reviewed by the Disciplinary Action Committee, whose members include the Compliance Office.

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)

Colombia Telecomunicaciones S.A. E.S.P. BIC is currently part of the following Collective Actions: -Global Compact -Alliance for Integrity -Latin American Compliance Network

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

In pursuit of the anti-corruption principle, in 2021 Colombia Telecomunicaciones S.A. E.S.P. BIC decided to set formally up an Anti-Bribery Management System (ABMS) according with the requirements of ISO 37001:2016. As part of the implementation process, the organization closed the existing gaps between its Compliance Program and the requirements of the standard. For that purpose, the implementation process involved all levels of the organization, from the Board of Directors to the operational staff associated with the processes under the scope of the ABMS. Additionally, the organization carried out awareness and training strategies to sensitize personnel about (i) the importance of ethics and integrity in business and (ii) the relevance of struggling against bribery in order to promote a fairer society.