2022 Communication on Progress

KYIP Capital SGR S.P.A

Published date

July 21, 2022

No. of questions

53

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

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

    No, this is not a current priority

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

    Yes, and the commitment is focused on our own operations

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Please refer to the ESG Policy. https://www.kymapartners.com/sostenibilita/

    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
    So far the Code of Ethics does not include any reference to environmental protection. We refer to the ESG Policy.

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

    No one is specifically responsible for this topic

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

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

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No formal structure

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

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

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    As per the specificity and dimension of the company the creation of a formal structure is not efficient or not applicable. However, the company has identified responsibilities to address the sustainability topics and with direct influence at the highest level of the organization. Indeed, sustainability topics are discussed regularly at Board level.

    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
    yma has developed an ESG Checklist assessing country and sector risks and if the company has been involved in any incidents, controversy related to UNGC Principles

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

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Kyma performs risk assessment to all its investments

    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

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

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

    Optional comment
    Kyma plans to implement within two years the process 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.

    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
    Suppliers include Kyma investments (i.e. Portfolio Companies)

    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?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

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

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    5

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    40

    Above 50 years old (%)

    60

    From minority or vulnerable groups (%)

    0

    Executive (%)

    80

    Independent (%)

    20

    13. Do you produce sustainability reporting according to:

    UN PRI and UNGC

    Data Assurance

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

  • Human Rights

    Materiality / Saliency

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

    Optional comment
    Please refer to Kyma ESG Policy and Responsible Investment Policy. https://www.kymapartners.com/en/sustainability/

    Response

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

    Kyma has performed an ESG DD to all its investments and has developed an action plan to improve human rights related matters management within its Portfolio Company (PC). PC for instance has to include a specific reference to the protection of Human Rights international recognized standards within the Code of Ethics.

  • 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

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    2021
    Optional comment
    Please refer to Kyma ESG Policy and Responsible Investment Policy. https://www.kymapartners.com/en/sustainability/

    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

    Not applicable

    Forced labour

    Not applicable

    Child labour

    Not applicable

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    As it concerns Kyma, freedom of association, forced labour and child labor aspects are not material. The company has implemented policies and processes to guarantee a non discriminatory and safe working environment. As it concerns Kyma's investment, an assessment has been performed to evaluate the company's impact and risks on all social and labor right issues, including a gender pay gap assessment. While no material items were identified, based on the results of the assessment some further improvement actions were included in the portfolio company action plan.

    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)

    Optional comment
    Training related to sustainability aspects including in the ESG and Responsible Investment Policies have been provided to all employees at the beginning of 2022. Occupational Health and safety training is regularly provided to all employees as required also by law.

    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

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Forced labour

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Child labour

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Non-discrimination in respect of employment and occupation

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Occupational safety and health

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Working conditions (wages, working hours)

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected labour rights related topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected labor rights related topics.

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    100

    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
    As per the dimension and country in which Kyma Investment Partners operates, having employees in a trade union organization is not a common practice. Moreover, in 2021 there only 2 employees and 5 members of the Board of Director, including 4 partners.

    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

    0
    Optional comment
    Kyma has been funded in 2020 by its partners. In the coming years, Kyma is committed to working in improving women within senior leadership level position. In 2022, the company has already hired a women at senior leadership position.

    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 (%)

    There were only two employees in 2021, one male manager and one female white collars, so it is not possible to compare basic salary and remuneration of women to men considering jobs of equal value.

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

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0

    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

    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.

    Kyma has performed an ESG DD to all its investments and has developed an action plan to improve labour rights related matters management within its Portfolio Company (PC). PC for instance has to improve diversity in the management, extended the career development process to all employees and implement a welfare program.

  • 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

    2021

    Oceans

    As per the activities and geography on which Kyma and its portfolio company are located and operate, the ocean topic has not been resulted as material, so far.

    Forests / Biodiversity / Land Use

    As per the activities and geography on which Kyma and its portfolio company are located and operate, are not having significant impact on stakeholders, therefore the topics are not applicable to them.

    Air Pollution

    As per the activities and geography on which Kyma and its portfolio company are located and operate, are not having significant impact on stakeholders, therefore the topics are not applicable to them.

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

    2021

    Energy & Resource Use

    2021
    Optional comment
    Please refer to Kyma ESG Policy and Responsible Investment Policy. https://www.kymapartners.com/en/sustainability/

    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

    As per the activities and geography on which Kyma and its portfolio company are located and operate, are not having significant impact on stakeholders, therefore the topics are not applicable to them.

    Forests / Biodiversity / Land Use

    As per the activities and geography on which Kyma and its portfolio company are located and operate, are not having significant impact on stakeholders, therefore the topics are not applicable to them.

    Air Pollution

    As per the activities and geography on which Kyma and its portfolio company are located and operate, are not having significant impact on stakeholders, therefore the topics are not applicable to them.

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

    Energy & Resource Use

    Optional comment
    As it concerns Kyma, environmental related aspects are not material. The company has implemented policies and processes to guarantee environmental protection and efficient use of resources, including GHG emissions reduction. As it concerns Kyma's investment, an assessment has been performed to evaluate the company's impact and risks on all material environmental issues. While no material items were identified, based on the results of the assessment some further improvement actions were included in the portfolio company action plan.

    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
    Training related to sustainability aspects including in the ESG and Responsible Investment Policies have been provided to all employees at the beginning of 2022.

    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

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

    Water

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

    Oceans

    Not applicable

    Forests / Biodiversity / Land Use

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

    Air Pollution

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

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

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

    Energy & Resource Use

    Kyma assess progress in preventing/mitigating the risks/impacts associated with the selected environmental topics through an annual ESG questionnaire submitted to the portfolio company which enables to review their performance, define gaps and identify improvement actions to be included within a Sustainability Action plan. Moreover, Kyma annually monitor its performance including the above selected environmental related topic.

    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

    Emissions (tCO2e)

    0

    Scope 2 Emissions

    Emissions (tCO2e)

    Scope 3 Emissions

    Kyma has started its operations in June 2021, scope 3 Emissions will be monitored in the coming years

    Emissions (tCO2e)

    Optional comment
    The company supply 100% electricity from certified renewable energy. No energy sources contributing to scope 1 GHG emissions have been consumed by the company.

    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 (%)

    In 2021, Kyma had only one investment and the percentage of company's revenue invested in R&D of low-carbon products/services wasn't monitored.

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

    Optional comment
    Kyma performs for each potential investment a Climate Change Business Impact check list to identify climate related physical risks and the resilience of the business to climate change

    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

    100

    Technology

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

    Percent of total revenue (%)

    In 2021, Kyma had only one investment and the percentage of company's revenue which came from environmentally friendly products/services wasn't monitored.

    Sector-specific Questions

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

    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.

    Kyma has performed an ESG DD to all its investments and has developed an action plan to improve environmental related matters management within its Portfolio Company (PC). PC for instance has to improve the monitoring of GHG emissions and consider purchasing electricity from certified renewable sources (Green certificates, Guarantee of Origins).

  • Anti-corruption

    Commitment

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

    Optional comment
    Kyma Investment Partners is going to implement in the next two years an anti-corruption compliance programme in line with Italian legislation (Modello di Organizzazione e Gestione D.lgs. 231).

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

    Optional comment
    eneral recommendations included in the Code of Ethics. Kyma Investment Partners is going to implement in the next two years an anti-corruption compliance programme in line with Italian legislation (Modello di Organizzazione e Gestione D.lgs. 231).

    Prevention

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

    Optional comment
    Kyma Investment Partners is going to implement in the next two years an anti-corruption compliance programme in line with Italian legislation (Modello di Organizzazione e Gestione D.lgs. 231). Once implemented all employees and other partners, such as the portfolio companies, will receive regular training on anti-corruption and integrity.

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

    Kyma Investment Partners is going to implement in the next two years an anti-corruption compliance programme in line with Italian legislation (Modello di Organizzazione e Gestione D.lgs. 231). Once implemented the anti-corruption compliance programme will be monitored trough external independent monitoring. So far, Kyma review issues on ad-hoc basis and in case of incidents related to corruption. No incidents of corruption have occurred so far.

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    no incidents

    Confirmed during the current year, and related to this year

    0
    no incidents

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    Optional comment
    Kyma plans to engage in Collective Action against corruption in the next two years at portfolio company level.

    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.

    Kyma is implementing the anti-corruption compliance programme in line with Italian legislation. Moreover, it has performed an ESG DD to all its investments and an ESG checklist assessing the risk of anti-corruption related to the countries in which the Target company is operating has been performed. No risks of anti-corruption has been identified.