Report - COP Prototype

2022 Communication on Progress

Tudor Rose

Published date

July 15, 2022

No. of questions

Supplemental files

TudorRose_Environ_Print.pdf TudorRose_CompanyHandbook_2021_v1.pdf TudorRose_CompanyHandbook_2021_v1.pdf Tudor Rose ICT Policy_May 2018.pdf TudorRose_Environ_Print.pdf TudorRose_CompanyHandbook_2021_v1.pdf TudorRose_Environ_Print.pdf TudorRose_CompanyHandbook_2021_v1.pdf TudorRose_CompanyHandbook_2021_v1.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

We have recently created a Sustainability Project team to advance our performance across all of the issues raised in this CoP questionnaire. These items will all be covered in our forthcoming Sustainaility Report the first edition of which will be completed in 2022. Other items are already addressed in our Audience Vision (for emedia growth with manages a gradual transition from printed materials), Company Handbook, Environmental Policy and Business Plan.

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

These issues are all addressed in our Sustainability Report and Environmental Policy

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

These topics are all addressed in our Company Handbook for employees. However, we hope to address some of these issues in our Sustainability Report to enable us to extend our focus to include suppliers and other business relationships.

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 managing director of the company is responsible for all of these topics and remains passionate about continuing to uphold the standards that the company has set since it formed 25 years ago.

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

These four pillars are managed by the company's board of directors - with support, as required, from other stakeholders in the business.

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 Board of Directors are continuously vigilant in identifying risks associated with human rights, labour rights, environmental risks and corruption risks and will convene an emergency meeting as soon as any risk concerning any of these topics (and others) is identified.

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

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

Optional comment

Our recent priorities have focused on management rather than prevention and so getting ahead of potential issues and risks is a current flaw. We have not been able to successfully design a system that can identify and prevent risk but we will continue to pursue this in the year/s ahead.

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

While we have a formal process, outlined in our Company Handbook, it is worth noting that we recognise the need to remind all staff that we are happy to receive notice of their concerns.

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

We aim to renew our Supplier and Freelance Agreements this year to extend the process to cover freelancer journalists and suppliers.

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

To date we have never had a cause to provide remedy against any of the four pillars but we are committed to providing it in the event that the company has caused or contributed to an adverse impact. We have indicated that remedy is available to some stakeholders but it is an informal provision until we have identified a best practice formal provision. Any environmental issue would likely be considered differently and so we have indicated that there is currently no process in this case at the current time.

Lessons

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

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

Optional comment

We have thankfully not had to deal with any human rights, labour rights or anti-corruption issues and so have not been able to capture any lessons to date. We would, at a minimum, capture root cause information thought we have not indicated this in these questions because we have no existing process. We are investigating the root causes of environmental issues in print media and seeking out best practice and so have indicated this above.

Executive Pay

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

Optional comment

We cannot see a way to effectively link pay and these issues without compromising our belief that they are fundamental pillars that everyone in the business must work to upholding.

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 (#)	2
Male (%)	7.4
Female (%)	33.33
Non-binary (%)	0
Under 30 years old (%)	37
30-50 years old (%)	100
Above 50 years old (%)	29.63
From minority or vulnerable groups (%)	7.41
Executive (%)	92.59
Independent (%)	7.41

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

Other (Please provide additional information)

Optional comment

To date we have been overwhelmed by the volume of sustainability assurance programmes that exist. We are currently compiling a Sustainability Report for one of the markets that we serve and there are an estimated 400+ certificates available for companies that operate in this industry. There are fewer than this in media but it is daunting nevertheless. If/when we find an appropriate third-party we will seriously consider seeking more formal assurance.

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
2018
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Optional comment

Our ICT Policy is currently being updated and our Company Handbook is up to date.

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
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

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

Optional comment

We issue regular ICT updates and have a help desk function for any related queries. We have not issued any specific messaging about the rights of women and/or girls but will review this in the current reporting year.

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

Optional comment

We are conscious that an absence of any issues can lead to complacency. We have never encountered any human rights issues in the work place or with our wider stakeholder community. But this does not mean that we don't need to do anything.

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

Optional comment

Our induction training covers digital security/privacy and the the rights of women and/or girls, covered in our Company Handbook. Additional in role training may also cover these topics from time to time but not in a structured programme. We don't currently have any plans to extend this to our supplier community.

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

Optional comment

We have not had any issues in either of these cases and so can only continue to commit to dealing with them immediately, sensitively and effectively if an issue arises in the future.

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

Optional comment

We have not identified any adverse impacts through our operations in relation to human rights and so have not had the opportunity to provide a remedy.

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.

Human rights principles sit at the heart of everything we do, our people are our most treasured asset. Employee support, encouragement and care form the foundation of our values and we apply them every day. We recognise that human rights are universal, inalienable, indivisible, interdependent and interrelated. Participation and inclusion are fundamental rights at Tudor Rose and we recognise the we are accountable for our actions. To date we have not experienced a breach of our most important principles and yet we will remain vigilant and seek to address any possible flaws in our actions, processes, policies and procedures to ensure the continuation of our current performance standards.

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
2021
Occupational safety and health
2021
Working conditions (wages, working hours)

Optional comment

In the UK media industry we are very fortunate to not have any issues relating to freedom of association, forced labour, child labour or working conditions and so see no immediate need to write an internal policy commitment to address these challenges. To the best of our knowledge our limited supplier community is in the same position. However, we are now reviewing our need for a supplier policy that incorporates a requirement for our suppliers to be similarly committed to human rights principles.

1.1. For each labour rights policy, is it:

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

Prevention

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

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

Optional comment

We follow our industry news and updates regularly and have not observed any potential for issues in relation to labour rights within our industry. However, we freely acknowledge that it's easy to become complacent and so we are currently reviewing the need to engage with our suppliers on these topics, formulate a supplier policy that sets our expectations of our suppliers and to envisage how we might contribute to preventing or mitigating any risk, no matter how small.

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)

Optional comment

Our workforce is well-informed but to date we have not engaged our supplier community or wider business relationships with a view to preventing the risks/impacts associated with labour rights issues. We hope that a future Supplier Policy will address our concerns and contribute to informing all stakeholders about the fundamental human rights pillars that for us non-negotiable.

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

As a result of this CoP we will review our internal induction programme and training to ensure that human rights issues are fully covered in the current reporting year.

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)

Optional comment

We had noted that we will review issues on an ad-hoc basis because we are committed to doing so, though we have not yet identified an issue in our operations in the 25 years that we have been in business. We are committed to maintaining this record but still have work to do in this area to ensure our continued standard of performance.

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

Optional comment

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

	Percent of women (%)	Unknown
Senior leadership level position	50
Non-executive board	0

Optional comment

The company has only two board directors - brothers - and no non-executive board. Of the remaining six management positions (with staff), 33.33% are women.

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

We have comparable roles in our sales and editorial departments where there are employees with comparable jobs. In these cases the basic salary and remuneration is exactly the same.

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

Optional comment

We are an office-based business and injuries have always been infrequent and minor. Zero were recorded in the current reporting period though for much of this time we have been working at home or with limited time in the office due to the pandemic.

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

Optional comment

See comment associated with previous question

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

We have not had any human rights cases to remedy, either directly or indirectly, in the reporting period

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.

See previous responses - human rights principles, including labour rights, are fundamental to the values of our company and our entire workforce. We hold regular meetings with individuals, in teams and as a company. We operate an very wide open door policy, encouraging members of the team to speak to directors and other business leaders in an open and mutually respectful way. We have not experienced any human rights issues through this approach - while it works for us as an SME, we are still interested in exploring best practice approaches from other UNGC participants.

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2021
Water
Oceans
Forests / Biodiversity / Land Use
2021
Air Pollution
2021
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2021
Energy & Resource Use

Optional comment

Three of these topics are covered in either our Company Handbook or our Environmental Report. However, none are sufficiently thoroughly addressed - largely because we are effectively a service company and have little opportunity to influence positive environmental action and activity. However, we have recently taken a somewhat more proactive stance and the formation of our Sustainability Project team will focus on seeking new opportunities to reduce our corporate environmental impact.

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

The basics of our environmental policy is contained within our Company Handbook and further detail is shared in our Environmental Report. There are a number of improvements that we are hoping to make in the year ahead to add more formality to our actions and aspirations as well as sharing our status and ambitions with a wider external audience and recruiting support from our supplier community.

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

Until recently we have not been able to develop a structure to engage stakeholders beyond informal questions. However, in December 2021 we commenced work on a Sustainable Maritime Interiors report for the passenger shipping industry. At the time of completing this CoP we have recruited over 100 contributors and this experience has given us the confidence to engage our own internal business relationships to develop a more thorough understanding of the environmental threats and opportunities that we can contribute to.

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 have a skeleton framework but we are behind in our efforts to develop a Sustainability Report which will address these topics and actions through our new Sustainability Project team.

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

We are in the midst of a project that will ideally see us from reviewing issues on an ad-hoc basis to setting annual targets and tracking progress.

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)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

We have not yet been able to calculate our scope 1, 2 and 3 emissions. We are primarily a services company and our emissions relate primarily to our office premises, business travel and magazines. We need to find a satisfactory source to use to model our current emissions and explore pathways to reduce them without compromising our ability to function as a successful business.

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)

Optional comment

We do not have an R&D budget but a significant number of people within the business are working on developing and executing an audience vision for the future that will enable us to reduce our reliance on print media in favour of emedia. While we have made some significant strides in 2021 (reducing the printed distribution of one magazine from 25,000 to 15,000 while increasing the readership of our digital edition by 10,000), we anticipate that this vision will continue to evolve through the life of the business.

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

Optional comment

Our audience vision will increase our resilience to climate change and our forthcoming Sustainable Maritime Interiors report is a project that we are co-funding to contribute to help cruise and ferry companies to adapt to the new business imperative to become more environmentally sustainable.

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

This is a calculation that we are waiting to receive from suppliers and we hope to be able to submit an answer during this reporting period.

Technology

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

Percent of total revenue (%)

12.41

Marketing services + emedia revenue / total revenue as a percentage. Our marketing services and emedia work has a digital rather than physical output and so consumes no raw material and has no manufacturing cost.

Unknown

Not applicable (Please provide additional information)

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.

We are working on developing an audience vision that will reduce our reliance on print media, we are writing a Sustainable Maritime Interiors report to guide one of the industries that we serve, we are seeking to increase the revenue that we generate (as a percentage of total revenue) from environmentally friendly products and services, we continue to seek best practice solutions to environmental concerns about printed media (biodegradable polybags, prioritising natural inks, FSC certified paper, efficient delivery service), we have started a Sustainability Project team, we are in the midst of compiling our first ever Sustainability Report, we are reviewing our energy supplier choices and we have numerous other small initiatives and activities to improve our environmental performance.

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

Optional comment

We make our policies very clear in our Company Handbook and everyone in the business knows that we have a zero tolerance for corruption. As it has never been an issue we are currently reluctant to make it one by introducing a compliance programme. However, we are happy to listen to reasoning that might prove the value of such a programme.

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

Our policies and recommendations, including employee conduct, are included in our Company Handbook

Prevention

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

Optional comment

Training is probably an exaggeration but this topic is covered in our standard induction - all new employees are asked to sign the Company Handbook to confirm that they will abide by the policies and recommendations within it. We are only a small business (27 staff) and so have limited resources to be able to action each task in this CoP - prioritisation has been key to make small improvements every year.

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

See answer to question 3.

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

Optional comment

While we have indicated that we review issues on an ad-hoc basis, we have not actually had a corruption issue and so this is aspirational rather than actual.

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
n/a
Confirmed during the current year, and related to this year	0
n/a

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)

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 submitted a letter of support for Anti-Corruption and the Global Development Agenda.

Optional comment

While we support Collective Action against corruption and submitted a letter of support for Anti-Corruption and the Global Development Agenda we have not taken any additional action and are not active partners. This is primarily due to our small size, requiring us to engage more deeply in initiatives that we are better equipped to make a meaningful contribution to.

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.

No actions taken in this reporting period as we continue to be free from any issues relating to corruption and we have not received or identified any potential issues.