Report - COP Prototype

2022 Communication on Progress

NaturAceites, S.A

Published date

July 15, 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

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

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

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

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)

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 (%)	100
Female (%)	0
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	60
Above 50 years old (%)	40
From minority or vulnerable groups (%)	0
Executive (%)	100
Independent (%)	0

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)

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
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

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

Optional comment

A través de auditorias internas y externas

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
A través de auditorias internas y externas de entes de certificación y clientes
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
A través de auditorias internas y externas de entes de certificación y clientes
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.

Durante el 2021 se implementaron procesos de Debida Diligencia en Derechos Humanos en las 3 regiones operativas ( Escuintla, Fray Bartolomé y Polochic). Este proceso tuvo como objetivo: a) Evaluar el contexto y los riesgos asociados a DDHH en cada region; b) identificar riesgos y posibles impactos de las operaciones de la empresa en las regiones; c) validar con partes interesadas locales los principales elementos o percepciones de los posibles riesgos e impactos en DDHH d) identificar programas actuales relacionados a los temas relevantes identificados. Durante el presente período ( 2022), se tiene contemplado realizar el estudio de impacto en derechos humanos a nivel corporativo.

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

Optional comment

Actualización de políticas se llevará a cabo en el Q4 2022

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)

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

Por medio de los programas de auditoría interna y las auditorías externas de certificación se verifica el cumplimiento de los requerimientos asociados a estos temas materiales

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
La evaluación es por medio de auditorías internas/externas de tipo laboral
Forced labour
La evaluación es por medio de auditorías internas/externas de tipo laboral
Child labour
La evaluación es por medio de auditorías internas/externas de tipo laboral
Non-discrimination in respect of employment and occupation
La evaluación es por medio de auditorías internas/externas de tipo laboral
Occupational safety and health
La evaluación es por medio de auditorías internas/externas de tipo laboral
Working conditions (wages, working hours)
La evaluación es por medio de auditorías internas/externas de tipo laboral

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	0
Non-executive board	4

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

Optional comment

Se paga exactamente igual a hombre y mujer en una misma posición

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	4.5

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

	Incident rate	Unknown	Choose to not disclose
Incident rate

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.

Se siguen fortaleciendo los canales internos de comunicación y participación con los colaboradores tales como los Comités de Mejora laboral ( en plantas de beneficio) y los comités de convivencia ( en las áreas agrícolas). Adicionalmente, se han conformado los comités de genero en las regiones incluyendo oficinas administrativas y se ha nombrado una Embajadora del Comité de Género.

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
Water
Oceans
Forests / Biodiversity / Land Use
2020
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

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

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

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

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

El Alcance 3 se puede iniciar a trabajar en el 2o semestre, para incluir infor-mación GEI de Productores (combustibles, fertilizantes y áreas plantadas) y transporte de tercera parte (CPO / PKO y refinados)

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 (%)

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

Optional comment

Si bien no hemos tomado medidas para aumentar la resiliencia de toda la organización al cambio climático; en ESC y en 2021 inició el proyecto para aumentar consumo de biomasa. Pendiente revisar los resultados de eficiencia energética 2021 de Agrícola (implemento varios proyectos) y ESC (ha habido una tendencia a ser energéticamente más eficientes).

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 (%)

No se han lanzado proyectos para que nuestros productos sean más amigables con el ambiente. Una opción puede ser promover / involucrarse en el reciclado de cajas de cartón de mantecas / margarinas y que el cartón reciclado pueda ser usado en cajas de producto.

Unknown

Not applicable (Please provide additional information)

Sector-specific: Water

12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

Water withdrawal (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	975773
Groundwater:	889273
Surface water:	17035
Rainwater:	9464
Wastewater:	0
Percentage of water withdrawn in regions with high or extremely high water stress (%)	13

Water consumption (volume of water in megaliters):

	Mega-liters	Unknown	Not applicable (Please provide additional information)
Total	915773
Groundwater:	889273
Surface water:	17035
Rainwater:	9464
Wastewater:	0
Percentage of water consumed in regions with high or extremely high water stress (%)	13

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

Water intensity of products (cubic meter/$):

Unknown

Not applicable (Please provide additional information)

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	5
Hectares	5703

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)

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)

Optional comment

Regeneración natural: remediación de zonas riparias. Set-aside land: proyecto Probosque. Biodiversity offsetting: proyecto de compensación con WCS.

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.

Plan de Gestión Ambiental: Como parte de la implementación de un Sistema de Gestión Ambiental, se ha elaborado una Plan de Gestión Ambiental en cada una de las regiones operativas de la compañia. Este Plan incluye TODOS los compromisos ambientales derivados de los instrumentos y resoluciones administrativas ambientales, así como los objetivos y metas derivados de la estrategia de sostenibilidad. Definidos los programas y los indicadores, se llevan a cabo revisiones trimestrales con las gerencias para verificar el cumplimiento y logro de objetivos, derivando además planes de acción y ajuste en cuanto a las brechas identificadas. Centro de Producción más Limpia. (Programa de Desempeño Ambiental): NaturAceites se afilió al Centro de Producción más Limpia de Guatemala CPL por medio del Programa de Desempeño Ambiental. Este programa tiene como objetivo hacer una evaluación del desempeño ambiental por medio de un autodiagnóstico y posterior auditoría por el CPL, con el objetivo de identificar brechas y oportunidades de mejora en la implementación de un sistema de gestión ambiental tomando como referencia ISO 14001. Actualmente, las 3 Plantas de Beneficio forman parte de esta iniciativa.

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

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

Prevention

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

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

El programa anticorrupción (basado en UNGC y Transparencia Internacional) está en proceso de ser implementado durante 2022. Para la evaluación del sistema anticorrupción, ya se cuenta con una lista de verificación (elaborada externamente) basada en ISO 37001:2016, Transparencia Internacional, SMETA 6.1, UNGC y GRI 205.

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

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
Ninguno
Confirmed during the current year, and related to this year	0
Ninguno

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)

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.

Se tiene contemplado para este 2do Semestre 2022, llevar a cabo la elaboración de la política anticorrupción corporativa y realizar un diagnostico de brechas para identificar, procesos, áreas o temas con posibles riesgos y generar planes de acción que minimicen los mismos.