Scope 1 Emissions
2022 Communication on Progress
groupe ORPEA
Published date
July 29, 2022
No. of questions
59
Supplemental files
ORPEA Group_Responsible_Procurement_Charter_GB.pdfAccord ORPEA - UNI Global UnionORPEA Ethics and CSR Code of ConductURD_2021.pdf02404_DOCS CORPO_RSE-Code-de-conduite-V16_FR_GB-PREEXE.pdfFR-Accord-Mondial-ORPEA.pdfPolitique de 'bien-être au travail'_BELGIUM.pdfPolitica H&S_SPAIN.pdfURD_2021.pdf02404_DOCS CORPO_RSE-Code-de-conduite-V16_FR_GB-PREEXE.pdfURD_2021.pdfCEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentThrough the Non financial Statement within its Universal Registration Document, ORPEA communicates and addresses issues related to Sustainable Development. In addition, the CSR Committee of the Board meets regularly and monitors the progress of the CSR strategy and its targets. At the end of 2021, the Group launched its revised Code of conduct - Ethics and Corporate Social Responsibility with the aim of setting out the main principles to be respected and outline ethical and responsible behaviors. Furthermore a company risk analysis, including ESG issues, is conducted regularly as outlined in our Universal Registration Document.2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional comment- In 2021, the Group launched its revised Code of conduct - Ethics and Corporate Social Responsibility with the aim of setting out the main principles to be respected and outline ethical and responsible behavior. The code is structured around four main parts: (1)ethics, as a people-centered company (principles 1 to 4); (2) responsibility, as an employer (principles 5 to 7); (3) citizenship, as a committed player in the local communities and society (principles 8 and 9), i.e.; (4) integrity, in the conduct of business (principles 10 to 16), including the Group’s commitments to anti-corruption, respect for business partners and the Group’s commitments as a listed company. - ORPEA's Responsible Procurement Charter is aligned with the Group's Code of Conduct. Its purpose is to create a reference framework shared by all actors, ORPEA purchasing teams, suppliers and subcontractors. Thus, ORPEA Group aims to have the Responsible Purchasing Charter signed by all its suppliers, regardless of their country of location. This charter is a prerequisite for any business partnership and by adhering to this Charter, suppliers commit to respecting and implementing all the principles set out therein, such as the principles of the United Nations Global Compact, the International Bill of Human Rights and the fundamental Conventions of the International Labour Organization (ILO), in compliance with contractual provisions and applicable national laws.3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentIn 2021, the Group launched its revised Code of conduct - Ethics and Corporate Social Responsibility with the aim of setting out the main principles to be respected and outline ethical and responsible behavior. The principles are as follows: 1. Respecting the rights and dignity of people 2. Ensuring health, safety and well-being in our facilities 3. Respecting the privacy of individuals and their personal data 4. Maintaining trust based relationships with the families and loved-ones 5. Promoting social dialogue 6. Providing training and support, encouraging career development 7. Promoting and respecting Equality, Diversity and Inclusion 8. Acting locally and contributing to the development of territories and the community 9. Limiting our ecological footprint Regarding suppliers, human rights, environment and corruption is also addressed in our Responsible Procurement Charter that sets out ORPEA’s reciprocal commitments in terms of health and safety, environmental protection, ethical business practices and fighting conflicts of interest and corruption. By adhering to this Charter, suppliers commit to respecting and implementing all the principles set out therein, such as the principles of the United Nations Global Compact, the International Bill of Human Rights and the fundamental Conventions of the International Labour Organization (ILO), in compliance with contractual provisions and applicable national laws. https://orpea-corp-events.com/rse/en/publications4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional comment- For Anti-corruption and Human Rights: Risk and Compliance Director that has direct influence to the CEO and dual reporting to the Board Audit Committee - For Environment: Weel Being Executive Vice President in charge of CSR and Construction Executive Vice President (both Part of the Executive Committee) - Labour: Human Ressources Executive Vice President (Part of the Executive Committee) Furthermore the CSR and Innovation Committee of the Board of Directors, is responsible for overviewing topics such as safety and quality of life and care of people in the facilities, the health, safety and well-being of employees, the Group’s environmental footprint, social issues, the implementation of innovative solutions and the actions of the ORPEA Foundation.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional comment1. International Ethics Committee presided by an independent person and composed of diverse professionals. In 2022 the Group will progressively deploy peripheral local committees in each of our geographical zones. 2. CSR and Innovation Committee of the Board of Directors that is responsible for validating and supervising Orpea's CSR strategy (including human rights, labour rights, decent work and the environment ) 3. Corporate department Community Meetings. Those meetings gather corporate teams and local teams (CSR, purchasing, quality, communication...) to address proper deployment and implementation of the CSR strategy at every level of the Group 4. The Group's anti-corruption program is deployed by the Audit, Risks, Compliance and Internal Control Department (DARCI) and supervised by the board Audit Committee. It is based on the following pillars : - Commitment of top management (in particular through formal and public statements, but also through the Code of Conduct on Ethics and CSR and the Code on the fight against corruption and influence peddling) - Adoption of a zero tolerance policy towards corruption - Preparation of 20 corruption and influence peddling risk maps (countries and Group) validated by the Group Executive Committee, - Drafting, deployment and facilitation of policies and processes (Policy on gifts and entertainment, Rule on facilitation payments, Guide to the prevention and management of conflicts of interest and declaration form and Rules on the prevention and management of conflicts of interest) - Generic and specific training depending on the level of exposure of employees to the risk of corruption, - Implementation of a third-party evaluation system, notably through compliance audits, - Deployment of a Group whistleblowing system: orpea.signalement.net, - 18 internal control processes, including Group Standard Compliance. All the above is being enhanced and reviewed in 2022 in light of recent events. Amongst others, a new campaign on conflict of interest was launched in March 2022 with a more in depth questionnaire. The Group has also launched a extensive training on its reviewed code of conduct that started in May 2022 and will be rolled out for the next two years to reach 100% of our employees trained. The Group's General Management is considering optimizing its comitology to compliance and internal control at Group level. During the second half of 2022 a benchmark will be carried out against the best standards of listed groups to enhance our practicies.Prevention
6. Does the company have a process or processes to assess risk?
Optional commentInternally Orpea has an assessment risk process which maps process is based on the following steps : - an analysis and categorization of risks by theme, based on interviews with the Group's principal managers - a benchmark of risks with those applicable to companies of comparable or related size and sectors - a rating of each risk according to criteria of impact, probability of occurrence and level of control - steering of action plans to mitigate risks that represent key issues for the Group. This analysis includes human rights risk (such as well-treatment), labor rights, environmental issues and corruption related risks. - Internal processes are also in place for our own operations regarding corruption through gifts and entertainment policy (lastly updated in 2021, mostly in France, to take into account the new anti-gift law applicable to health professionals), Conflict of Interest Policy and Whistleblowing Platform. An Audit Investigation Charter has also been drafted in 2021 to guide the audit missions and is regularly applied to the course of investigations launched following a whistleblower’s report. This charter will be updated in 2022 to incorporate regulatory changes related to the strengthening of whistleblower protection. As of March 2022, a new campaign to identify conflicts of interest has been launched for at risk persons and on the basis of a more thorough questionnaire. - We assess corruption risks, a new corruption and influence peddling risk mapping exercise was conducted in 2021 took place in 19 countries and involved interviews with some 100 people. The identified risks were shared with the management of the regions and with the Group Executive Committee. Action plans have been identified and will be monitored regularly. In light of recent events in 2022, the Group plans to significantly strengthen its compliance process and associated key controls. Regarding environmental risks even though the company considers it in its regular risk analysis process, the company plans to engage in the coming years in a specific risk analysis in agreement with TCFD reporting recommendations. Externally Orpea assesses risk in the following way: - Global and National suppliers are evaluated through the EcoVadis platform among four different categories: Environment, Social and Human Rights, Ethics and Sustainable procurement. The results of this CSR evaluation is gradually being incorporated in purchasing decisions. Complete EcoVadis roll out is scheduled in 2022 and 2023. Regarding new partnerships, a particular focus is given to internal controls and strict approval procedures before each region enters into a relationship with the new partner. Accordingly, an integrity verification process of the new partner is conducted using dedicated tools such as Lexis Nexis and Dow Jones to avoid risk of corruption and/or influence peddling. This is supplemented, if necessary, by in-depth investigations (depending on the nature of the third party, the nature of the services provided, potential interactions with public officials and the risks identified). This process is currently in place in countries that are equipped with an e-purchasing platform. The Group will continue to roll out this platform to reach 70% of its operations by end of 2022 and widen the control process.6.1. During the assessment of risk, which business relationships are reviewed?
Optional comment- Ongoing roll-out with main suppliers through Ecovadis rating wich includes Environment, Social and Human Rights, Ethics, Sustainable procurement assessments. In 2021 global suppliers were in the process of being evaluated. In 2022 ORPEA will finish evaluating its global suppliers and start with national suppliers. In adittion, suppliers are pre-classified on the basis of their business volumes or their strategic importance. Depending on the results of the evaluation, the Compliance department conduct Know Your Third-Party procedures based on in-depth duty of care compliance questionnaires. Action plans are then implemented based on the responses provided. Due diligence processes are carried out with the support of local compliance officers and cover the verification of the integrity of strategic third parties (such as first-tier suppliers and general contractors) and of almost all third parties related to acquisitions (intermediaries, vendors). In line with the findings of external and internal investigations following the publication of a book containing allegations of malpractice, the third party compliance process will be strengthened.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?
Optional commentIn 2019, the Company carried out a complete overhaul of its risk mapping process to identify the main risks throughout the Group. All subsidiaries and activities were included in the exercise to take into account changes within the company and its operating environment. The action plans relating to risks identified as significant were refined as part of a process of continuous improvement. Dedicated risk maps for information systems, corruption and influence peddling were updated in 2021 and were included in the risks monitored at Group level. In 2022, the Group will carry out a new assessment of its main risks and update its risk map accordingly, particularly due to the consequences of the events faced by the Group and its stakeholders since January 2022. - In light of recent events the Group has also launched in May 2022 a double materiality analysis with extensive participation of it stakeholders. This analysis will help identify material sustainability topics on which the Group has an impact as well as identifying the impacts that those issues have on the Group business model. - The Group’s environmental risks are assessed according to the principle of double materiality and are based on two priority areas: (i) the Group’s impact on natural ecosystems: carbon emissions related to the operation of buildings (heating, electricity, etc.) and their construction (building materials, soil artificialisation, etc.), pollution related to the waste generated by the Group’s activities, use of natural resources (water, food, etc.); (ii) risks incurred by the Group, particularly due to climate change. In 2021, ORPEA carried out a first review exercise of its business model according to TCFD recommendations. This approach will be continued and strengthened in 2022.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- ORPEA has a whistleblowing platform in place. In order to reinforce knowledge of this tool, the procedures for reporting through the dedicated platform will be presented in greater detail as part of the new training on the revised Code of Conduct Ethical and CSR being deployed in 2022. In addition, an e-learning module dedicated to the whistleblowing platform was rolled out in 2021 in France and at global corporate level in order to raise awareness of this platform among employees. Other awareness-raising actions are planned for 2022 throughout the Group, in particular through posters displayed in staff rooms and the roll-out of a QR code facilitating access to the whistleblowing platform. - An Audit Investigation Charter has also been drafted to guide the audit missions and is regularly applied to the course of investigations launched following a whistleblower’s report. This charter will be updated in 2022 to incorporate regulatory changes related to the strengthening of whistleblower protections.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.
Optional commentIn accordance with the Sapin 2 law, a global ethics alert system is available to all stakeholders in order to alert them to breaches of the principles of the Code of Conduct, especially those concerning: - conflicts of interest - discrimination and harassment - fraud, embezzlement and theft; - non-compliance with laws, regulations or the public interest; - anti-competitive practices; - occupational health and safety. Confidentiality of information is guaranteed at all stages of the whistleblowing process, including the identity of the whistleblower (https://orpea.signalement.net/). The Group has also established a procedure for compiling reports accessible on the whistleblowing site. The procedure sets out the rights and obligations of whistleblowers and those referred to in a whistleblowing report. It also stipulates the scope of the protection provided to the whistleblower making a report in good faith.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?
Optional comment1. Human Rights : A specific complaint process is in place within the company and opened to all stakeholders. Any complaint regarding human rights (such as well-treatment matters) is immediately escalated within the company. A root analysis is then made with the whole team and proper action plans are set in motion. As part of the process a specific meeting is set with the affected stakeholders to discuss the complaint and actions put in place. Other feedback mechanism are in place in some countries and will be straightened and deployed in 2022 in light of recent events. For example, the Group will set up an independent mediation program in France as it is already the case in Austria. Furthermore the Group will put in place a mistreatment observatory following the suicide observatory which has proven very effective in preventing and analyzing causes of such events. Finally a hotline has been put in place in France in early 2022 in order to give stakeholders and particularly residents, patients and families multiple ways to express their concerns. 2. Labor Rights and Decent Work : The employee representative bodies (Instances Représentatives du Personnel) are a communication channel to address the employees' issues at all levels of the company. 85% of employees are covered by a collective agreement or a sector agreement (like Quality of Work Life). In light of recent events Orpea has redoubled its efforts to negotiate new agreements and continue to improves the dialogue. In 2022, agreements were signed, such as the global agreement with UNI Global Union for union representation and, locally in France, the profit-sharing agreement based on ESG criteria and no longer solely on financial criteria. 3. Environment, Corruption and any other topics: An internal process to audit and investigate potential incidents applies. At a first «checking» stage, the referent proceeds to a preliminary assessment to determine whether or not the incident fall within the scope of the procedure. Once the alert is admitted a referent informs the whistleblower. If necessary an investigation could be run either by a small internal team or, by external third parties according on the gravity of the alert. The investigation progress, its contents, its outcome, and the subsequent report are strictly confidential. For all type of complaints or alerts reported through the Whistlebowing Platform, if it is proven to be true, ORPEA takes the appropriate disciplinary measures in accordance to labour local regulations. If, after the reported event, there are injured parties other than ORPEA, appropriate measures will be taken to repair any damage that may have been caused as soon as possible. If the events are of criminal legal significance, the necessary measures shall be taken so that, as soon as possible, the authorities are informed of the events and all the evidence that proves them, showing full willingness to cooperate. Finally An "Audit Charter" has been drafted to provide a framework for audit assignments and also applies to the conduct of investigations initiated following a whistleblower report. This charter will be updated in 2022 to take into account the regulatory changes relating to the reinforcement of whistleblower protection.Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional comment- For adverse events relating to Human rights, the Group conducts root cause analysis, put in place local action plans and if applicable re-evaluates and change internal protocols through it quality department network. In light of recent event the Group will work in 2022 on the reporting of new indicators for enhanced transparency on this topic, to assess, among other things, the exhaustivity of reports of such events to the authorities and the quality of the information and the timeframe in which they were reported. - Some committees are in place with the participation of Instance Representative du Personnel (The employee representative bodies) and the Group's teams amongst other on safety issues. It is the case for example for the work accident committee, in which those accidents are discussed on a regular basis and give rise to common action plan in order to avoid similar incidents in the future. This process is however not in place in all countries and is subject to local regulations. - Environmental issues do not have specific channel and are to date raised through the whislelblowing platform and are subjet to process of any reported incident. - The Group's Audit, Risks and Compliance Department, which reports to the General Secretary and to the Board Audit Committee, is organized around two units: Permanent Control and Periodic Control. On one side, The Permanent Control unit works to identify and prevent risks and to develop an internal control system. It has four main areas of expertise, including Compliance, which ensures that the Group complies with its obligations, in particular in the fight against corruption and influence peddling. On the other side, the Periodic Control unit, composed exclusively of the Internal Audit department, is responsible for ensuring that the internal control system is operating effectively and that risks are covered in all Group entities. It is also responsible for making proposals for improvement to limit exposure to risk. In light of recent events, the Group initiated a process to strengthen its internal control system. Initial measures have already been implemented in last months, including: strengthening the prevention and management of conflicts of interest; active promotion of its Whistleblowing platform and the deployment of its new Code of Conduct, through an extensive action plan to ensure training of 100% of its employees by 2023.Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentCSR objectives are part of the criterion on senior executives bonuses. Given the arrival of a new Group CEO, the compensation rules have been revised and are as follow: 1. In 2022, quantifiable CSR objectives, represent a proportion of 40% of total CEO's variable compensation (Vs. 15% in 2021). It now includes the following criterion: - decrease in the frequency rate of lost-time accidents, - percentage of facilities certified by an external body, - percentage of facilities/countries that have set up a system of enhanced dialogue with family and friends, - decrease in the turnover rate, - percentage of significant and regular suppliers that have signed the responsible procurement charter and percentage of new construction projects with the HQE (or equivalent) 2. The same logic applies to the senior managers of each region, including the CEOs and COOs, whose variable remuneration is conditional, up to 20%, on the implementation of the CSR strategy in their region, of which 15% is based on the achievement of the 2023 CSR roadmap objectives and 5% on a priority CSR criterion depending on the local characteristics of each region. Up to 15% of the variable remuneration of CFOs is correlated with achieving 2023 CSR roadmap objectives. 3. Employees' profit-sharing plan (France) In July 2022, ORPEA signed an employees' profit-sharing plan amendment with two of the three representative trade unions (Arc-en-Ciel and UNSA - SAMS) and will be paid, for fiscal year 2022, no later than May 31, 2023 Until now, the profit-sharing bonus paid to employees was based solely on the achievement of financial targets. This amendment, which covers the period 2022, introduces two non-financial indicators: one relating to the health and safety of employees (with the frequency rate of workplace accidents) and the other relating to the well-being of residents (with the annual satisfaction rate). Non-financial indicators now account for the majority of the bonus calculation and represent 60% of the criteria. As a reminder the CSR 2023 roadmap addresses the following : 1. Well-being - Increase in the employee engagement rate - Reduction in work-related accidents - Facilities certified by an external ISO 9001 - Facilities trained ethics/positive treatment officer - Implementation of the Catering Charter and have achieved the objectives related to nutrition, food safety and the environmental footprint 2. Career development - Internal promotion - Employees with a diploma or certificate 3. Inclusion and Diversity - Women in Top Management - Mechanisms to improve dialogue with loved ones 4. Environmental impact - New construction projects with LEED or BREEAM certification - Reduction in energy consumption -Reduction in Scope 1 & 2 Carbon Emissions - Suppliers having signed our Responsible Procurement Charter - Supplier calls for tender including a CSR assessment 5. Building a Better World - Innovative programmes at Group level aimed at enhancing the wellbeing of residents and patients - Research partnerships with a renowned university - Roll-out of the new Code of Conduct Ethics and CSR as well as training for all employeesBoard Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
Optional commentFollowing the 2022 events the Group has taken extensive measures to renew its governance: New Group CEO was appointed July 1st - Laurent Guillot 5 New board members (4 independent) were appointed to the board. Find the press release from 28/07/2022 : https://www.orpea-corp.com/images/orpeafinance/pdf/Communiques/FR/2022/CP_POST_AG_VDEFCLEAN_40351.pdf13. Do you produce sustainability reporting according to:
Optional commentIn 2021 ORPEA declared for the first year, its non-financial information for the period between January 1, 2021 to December 31, 2021 with reference to the GRI standards (not yet in accordance) and in accordance with SASB Standard for Health Care Delivery Industry (Chapter 4.10 of 2021 URD).Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentSee Chapter 4.12 of 2021 Universal Registration Document (ORPEA_DEU_2021_FR)Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Response
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
1. The Orpea Group and UNI Global Union signed on April 8 2022 an agreement that makes strong commitments to upholding the rights of ORPEA's 70,000 employees, to the fundamental freedoms of trade unions, as well as to the ability to create the conditions for productive social dialogue and collective bargaining. This "Global Partnership Agreement on Ethical Employment, Social Dialogue, Collective Bargaining and Trade Union Rights" is the first global agreement of its kind in the healthcare and private retirement facilities sector. It is based on the mutual recognition that decent working conditions, good training, good wages and respect for workers' rights have a direct impact on the quality of care offered to residents and patients in the Group's facilities. 2. Facing the evolution of the organizations and the relationship to work, the company wishes to formalize the use of telecommuting for the employees who usually carry out their functions within the premises of the head quarters in PUTEAUX (92), ORPEA signed on 09-30-2021 an Agreement on remote working: -To limit the travel constraints of the employees -To limit the environmental impact of these trips - Increase the attractiveness of the company and the loyalty of the employees -To improve the balance of life - Expressing confidence in employees by giving them more autonomy 3. Regarding the Quality of Life at Work, in Spain, ORPEA has implemented shift work (7 hours per day plus weekly rest) which allows for a better reconciliation with family time. 4. ORPEA participated in the first Worldwide DEI (Disability equality Index) questionnaire in 2021 on a test sample of three countries (Italy, Spain and France) in order to further formalize its disability policy. The results of this survey will enable the Group to deploy certain best practices in all the countries where it operates. 5. Launch of the "Réussir au féminin" (Being successful as a women) program focused on supporting and training women in order to increase their access to top management. In a perspective of constant improvement on the subject of parity, ORPEA signed in 2021 the United Nations' Women Empowerment Principles (WEPs). 6. In France, initiatives have been set up with Pôle Emploi, as well as "Forces Femmes", which helps women over the age of 45 return to work, and "Nos Quartiers ont du Talent", which helps young people find their first job or build a professional project. 7. Partnership with the association "La Cravate Solidaire" has enabled to collect 326 kg of professional clothing for men and women from employees at the head office or in the sites to support and promote access to employment for people who are excluded from employment.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional comment1. A new Code of Conduct Ethics and Social Responsibility was launched in 2021 as a broader policy for Forced Labour, Child Labour, Non-discrimination in respect of employment and occupation and wich is based on the principles of the following international and national conventions: - The 1948 Universal Declaration of Human Rights; - The International Labour Organization’s fundamental Conventions; - The OECD Guidelines for Multinational Enterprises; - The United Nations Global Compact, which ORPEA joined in 2020; - The United Nations Convention against Corruption; - WHO Principles; - The HAS (French health authority) reference framework; - The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. 2. In light of recent events the Group is working on a revised Global HR policy which will include topics such as working conditions and freedom of association.1.1. For each labour rights policy, is it:
Optional commentHuman Resources departments in each country have carried out an analysis of their occupational health and safety activities and drawn up specific national action plans in coordination with the business lines concerned. All of the Group's countries are mobilized around this key issue, while scrupulously complying with national regulations. In 2022, the Group will embark on an even more ambitious policy to reduce workplace accidents, driven and embodied by Group General Management.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?
Optional commentOperating in 23 countries, the Group aims to promote that all its employees are covered by collective bargaining agreements, particularly with regard to key issues such as wages, working hours and working conditions. - In May 2021, Spain signed a wide-ranging three-year agreement for all its employees covering diversity and inclusion, recruitment, career development and training, work/life balance, prevention of all forms of harassment and discrimination, and health and safety in the workplace. - France has also signed a major collective agreement in June 2021 to renew and improve its commitments to quality of life at work and professional equality. In order to promote well-being at work effectively, various measures such as more flexible working hours (including remote working) to ensure a better work-life balance or measures related to parenthood are included. - In April 2022, the Group and UNI Global Union signed at the OECD headquarters in Paris a landmark agreement that makes strong commitments to upholding the rights of ORPEA's 70,000 employees, to the fundamental freedoms of trade unions, as well as to the ability to create the conditions for productive social dialogue and collective bargaining. This "Global Partnership Agreement on Ethical Employment, Social Dialogue, Collective Bargaining and Trade Union Rights" is the first global agreement of its kind in the healthcare and private retirement facilities sector.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?
Optional commentOperating in 23 countries, the Group aims to ensure that all its employees are covered by collective bargaining agreements, particularly with regard to key issues such as wages, working hours and working conditions. - In May 2021, Spain signed a wide-ranging three-year agreement for all its employees covering diversity and inclusion, recruitment, career development and training, work/life balance, prevention of all forms of harassment and discrimination, and health and safety in the workplace. - France has also signed a major collective agreement in June 2021 to renew and improve its commitments to quality of life at work and professional equality. In order to promote well-being at work effectively, various measures such as more flexible working hours (including remote working) to ensure a better work-life balance or measures related to parenthood are included.4. Who receives training for the following labour rights issues?
Optional comment1. For example, in Spain the HSE (Health, Safety and Environment) Committee which comprises staff representatives meets at least four times a year and its members receive at least 30 hours of specific training per year. Besides, Managers and team leaders are trained on how to prevent psychosocial risks (in particular as part of their onboarding), how to deal with workplace events that may lead to them, and how to raise teams’ awareness. A special training course on psychosocial risks during the Covid-19 crisis was also provided in 2021. 2. The Group has taken the goal of training 100% of its employees on it Code of Conduct ethics and CSR by end of 2023. This new Code of Conduct is structured around four main parts : - ethics, as a people-centred company (principles 1 to 4); - responsibility, as an employer (principles 5 to 7); - citizenship, as a committed player in the regions and society (principles 8 and 9), i.e., the Group’s impact on society and the environment as a committed player; - integrity, in the conduct of business (principles 10 to 16), including the Group’s commitments to anti corruption, respect for business partners and the Group’s commitments as a listed company.5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional comment- Occupational safety and health is subject to a specific monitoring and protocols. As part of our CSR 2023 Roadmap, ORPEA will strengthen its commitment to Health and Safety by setting objectives to reduce the frequency of workplace accidents by 15%. All of the host countries are mobilised on this key issue while strictly complying with national regulations. In 2022, the Group will adopt an even more ambitious policy to reduce workplace accidents, which will be driven and embodied by its Executive Management. A comprehensive risk mapping and analysis is carried in most countries to identify the risks an employee may face at work. Workplace risk categories are assessed based on work units and characterized in terms of the hazards identified, the situations that can lead to them and the control measures in place. The major risks identified are musculoskeletal disorders, falls, and psychosocial risks, which are cross-cutting and common to all work environments. - Collective agreements are signed regularly (every three years), with varying scopes, in line with employee consultation and the local regulations in force, particularly in the following areas: quality of life at work (including the promotion of a work-life balance), remuneration, management of working hours and rest periods, reducing difficult working conditions, incentives, bonuses and profit-sharing, health, life and disability insurance, promoting the inclusion of target groups such as people with disabilities and older workers. - All guidelines related to inclusion, diversity and non-discrimination are set out in detail in the Group’s Code of Conduct Ethics and CSR, on which training will be provided to all employees by 2023. Furthermore the Group has set the objective to reach 50% of women in its top management by 2023.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentAround 85% of employees are covered by an industry, company or local collective bargaining agreement, at country or Group level. The Group operates in 23 countries and aims to ensure that all employees are covered by collective bargaining agreements, particularly regarding to key issues such as wages, working hours and working conditions. To date, national laws vary and do not always provide for an agreement in the healthcare and nursing sector. France, Belgium, Spain, Italy, Austria and other countries have such agreements. There is, however, no such agreement in Ireland. A collective agreement is in force for hospitals in Portugal, but is still being negotiated for nursing homes there. In Germany, collective agreements may be negotiated at facilities with a Works Committee in place, which means at approximately half of them.7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentThe Group currently works with more than 20 trade unions in different countries. Trade union representation may vary depending on electoral cycles. The Group’s trade union landscape is diverse, and among all the trade union players that exist in the healthcare and nursing sector, many partner organizations are offshoots from conventional national federations or independent trade unions. However we do not track the percentage of employee that are in a trade union.8. In the course of the reporting period, what was the percentage of women in:
Optional commentIn its Improving Tomorrow roadmap (2023 CSR Programme), the Group has made a commitment to continue its efforts to achieve gender balance at all levels of the organisation, in particular by further increasing the number of women in its top management (50% women in top management positions by 2023).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?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentIn 2021, the workplace accident frequency rate was 31.77, which is lower than both 2020 (37.91) and 2019 (33.9). Frequency rates were particularly high in 2020 due to the health crisis. All of the Group’s countries are mobilized on this key issue while strictly complying with national regulations. In 2022, the Group will adopt a more ambitious policy to reduce workplace accidents, which will be driven and embodied by its Executive Management. ORPEA is stepping up its commitment by targeting a 15% reduction in workplace accidents by 2023 compared to 2020.11. In the course of the reporting period, what was the company’s 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?
Optional commentIn the course of 2022 some allegations were made on company's respect of freedom of association. All press releases are publicly available : https://www.orpea-corp.com/en/press-releases/202213. 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.
1. ORPEA Group and UNI Global Union signed on April 8 2022 an agreement that makes strong commitments to upholding the rights of ORPEA’s 70,000 employees, to the fundamental freedoms of trade unions, as well as to the ability to create the conditions for productive social dialogue and collective bargaining. - The agreement, which covers 70,000 employees in 23 countries, aims to improve the working conditions of employees and the quality of care provided to residents and patients at ORPEA through enhanced social dialogue and union rights – It includes strong commitments on employees’ rights, the conditions for productive social dialogue, the fundamental freedoms of trade unions and collective bargaining. 2. The Group has also set up training and awareness-raising initiatives on the Code of Conduct for all teams, as well as a whistle-blowing system for employees and external stakeholders to report any suspicion of abuse or, more generally, any breach of its ethical principles. The procedure for managing conflicts of interest was strengthened in March 2022.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentIn addition to the Group-wide carbon footprint for scopes 1, 2 & 3, which confirms that energy consumption is the main source of carbon emissions, ORPEA has made strong commitments by developing an ambitious strategy for sustainable buildings called Green Building Strategy (GBS). This GBS applies to new projects as well as to existing buildings to be renovated. It is structured around four areas: - Reducing carbon emissions to combat climate change - Placing biodiversity and biophilia at the heart of our institutions and adapt to nature - Preserving resources and developing the circular economy; - Communicating the Green Building approach to all stakeholders and involving them in its implementation. * See more on Chapter 4.5 of the 2021 Universal Registration Document (https://www.orpea-corp.com/images/orpeafinance/pdf/Documentation/FR/2022/ORPEA_DEU_2021_FR_a6a44.pdf)1.1. For each environmental policy, is it:
Optional commentSee Chapter 4.5 of the 2021 Universal Registration Document (https://www.orpea-corp.com/images/orpeafinance/pdf/Documentation/FR/2022/ORPEA_DEU_2021_FR_a6a44.pdf)Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
Optional comment1. With the launch of the Group’s environmental strategy ORPEA has undertaken practical measures to protect natural resources through optimised water and waste management. In addition, in view of the first carbon footprint carried out at Group level on Scope 1, 2 & 3 emissions, which confirms that energy consumption is the main source of carbon emissions, ORPEA has demonstrated its strong commitment by developing an ambitious strategy for sustainable buildings, the Green Building Strategy (GBS). The top three sources of emissions at ORPEA are energy (in particular for heating) which accounts for 31% of emissions, purchases (mainly for catering) for 28% of emissions and visitor or employee transportation, making up 18% of total emissions. For the first time, a complete carbon footprint was measured in 2021 using the GHG Protocol method, the results were as follows: Scope 1: 94.167 tonnes of CO2 eq Scope 2: 56.181 tonnes of CO2 eq Scope 3: 391.687 tonnes of CO2 eq - The Group’s energy trajectory was defined by categorising the existing real estate portfolio according to various criteria (year of construction, type of assets, etc.) and then prioritising the actions to be implemented according to the impact on energy consumption by 2050 Vs 2019: 16% reduction by 2025 29% reduction by 2030 48% reduction by 2040 67% reduction by 2050 2. In order to support the Group in its ambitions, ORPEA has been working with a specialised company to measure its waste in France since 2019. In view of the success of this assignment, the Group has extended the analysis to all its regions in order to: - obtain a global view and measurement of its waste; - establish a common measurement methodology for all host countries; - set targets to improve the management of the waste generated. See Chapter 4.5 of the 2021 Universal Registration Document (https://www.orpea-corp.com/images/orpeafinance/pdf/Documentation/FR/2022/ORPEA_DEU_2021_FR_a6a44.pdf)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?
Optional comment1. As part of its Green Building Strategy, the ORPEA Group wants to go even further by setting targets to reduce carbon emissions indirectly associated with the construction of its buildings by: - systematically using Life Cycle Assessments (LCA) to make low-carbon design choices; - integrating at least two design choices that favour low-carbon mobility for all new sustainable buildings and major renovations (bicycle parking lots, charging stations for electric vehicles, etc.). The Group’s energy trajectory was defined by categorising the existing real estate portfolio according to various criteria (year of construction, type of assets, etc.) and then prioritising the actions to be implemented according to the impact on energy consumption by 2050 Vs 2019: 16% reduction by 2025 29% reduction by 2030 48% reduction by 2040 67% reduction by 2050 2. In 2021, ORPEA had already started to take certain weather and climate risks into account when designing its buildings. With regard to the risk of flooding, the Group commissioned specific studies for plots in sensitive areas. And in response to the risk of heat waves, ORPEA has undertaken actions to increase the plant cover of its buildings in order to limit, among other things, the effects of urban heat islands, as well as to optimise the use of shaded areas in order to passively preserve coolness. In accordance with the recommendations of the TCFD (Task Force on Climate Related Financial Disclosures), ORPEA has begun to identify the risks and opportunities related to climate change that could have a direct impact on its daily work in the service of vulnerable people. In order to follow the TCFD recommendations, the Group will progressively integrated climate change indicators and targets into its environmental strategy. Details are presented in chapter 4.5.2.3 and 4.5.2.5 of the 2021 URD (https://www.orpea-corp.com/images/orpeafinance/pdf/Documentation/FR/2022/ORPEA_DEU_2021_FR_a6a44.pdf)4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional comment1. In 2021, with the help of an external advisor, ORPEA set trajectories for reducing its energy consumption and energy-related carbon emissions (Scopes 1 & 2) by 2050. These trajectories set the energy and carbon performance objectives to be achieved by ORPEA’s real estate assets, in order to comply with the Paris Agreements. Based on this analysis, ORPEA set the following carbon reduction trajectory compared with 2019: - 11% reduction in GHG emissions by 2023 - 17% reduction in GHG emissions by 2025 - 31% reduction in GHG emissions by 2030 - 59% reduction in GHG emissions by 2040 - 87% reduction in GHG emissions by 2050 2. The Group’s energy trajectory was defined by categorizing the existing real estate portfolio according to various criteria (year of construction, type of assets, etc.) and then prioritizing the actions to be implemented according to the impact on energy consumption. As a result of this analysis, ORPEA has set the following trajectory to reduce its energy consumption compared with 2019: - 16% reduction by 2025 - 29% reduction by 2030 - 48% reduction by 2040 - 67% reduction by 20505. 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)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentFor the first time, in 2021 ORPEA did a complete global Carbon Footprint among all its countries on Scopes 1, 2 and 3, in partnership with an expert consulting firm.7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
8. Has the organization acted to support climate change adaptation and resilience?
Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Optional commentORPEA has started to purchase green energy from the grid. In 2021, the Group renegotiated its energy contracts to increase the share of green energy in the overall mix and reduce related carbon emissions. As for end 2021, 8 countries used green electricity (in part): - Germany: hydropower, wind, solar energy - Spain: wind, solar, high efficiency cogeneration - Portugal: wind, renewable cogeneration - Switzerland: hydropower - Austria: hydropower, wind, biomass, solar energy - Italy: photovoltaic system - Poland - Czech In 2022, 10 countries use now renewable energy (same countries than 2021 plus France and Brazil).Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Optional commentORPEA main activity is to provide health care services (clinics and retirement homes or homecare).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):
Water consumption (volume of water in megaliters):
13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
Optional commentBeware, in 2021 the Groupe accounted for waste in 60% of its perimeter (8 countries : France, Belgium, Ireland, China, Latvia, Poland, Slovenia and Austria). Details provided in chapter 4.5.4.1 of 2021 URD (pages 140 - 143)19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
Optional commentBeware this ratio was calculated upon a 60% perimeter denominator. Also the concept of hazardous waste vary considerably from one country to the other and some countries do not produce hazardous waste.20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
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.
In 2021, ORPEA had already started to reflect on the impact of climate change on its buildings and take action. With regard to the risk of flooding for example, the Group commissioned specific studies for plots in sensitive areas. And in response to the risk of heat waves, ORPEA has undertaken actions to increase the plant cover of its buildings in order to limit, among other things, the effects of urban heat islands, as well as to optimize the use of shaded areas in order to passively preserve coolness. With the arrival of new EU green taxonomy regulation, the Group will start a resilience analysis of a portion of its existing real estate park in 2022 as well as extend its assessment of exposure to physical climate risks (floods, heat waves, etc.) to all its new buildings. This analysis will make it possible to incorporate solutions for adapting to climate risks into all new buildings right from the design stage.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commenthttps://www.orpea-group.com/sites/default/files/cp_compliance_certification_def.docx_.pdf2. 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- Gifts and entertainment policy, which has been harmonized and adapted in line with applicable local regulations, as well as a guide to preventing and managing conflicts of of conflicts of interest (Page 94, URD) - A guide to preventing and managing conflicts of interest, which is part of the Group's ethical approach. It presents the notion of conflict of interest in an educational manner and illustrates it with practical cases. The guide is accompanied by a conflict of interest declaration form (Page 96, URD) - In accordance with the Sapin 2 law, a global ethics alert system is available to all stakeholders in order to alert them to breaches of the principles of the Code of Conduct (Whistleblowing platform: www.orpea.signalement.net). In order to raise the level of awareness of this tool, reporting procedures through the dedicated platform are presented in greater detail as part of the training courses on the new Code of Conduct Ethics and CSR to be rolled out in 2022. Besides an e-learning module dedicated to the whistleblowing platform was rolled out in 2021 in France and at Group level in order to raise awareness of this platform among employees. Other awareness-raising actions are planned for 2022 throughout the Group, in particular through posters displayed in staff rooms and the roll-out of a QR code facilitating access to the whistleblowing platform.Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentThere are two different trainings : 1. For all employees: Code of Conduct Ethics and CSR training, (business ethics module), Deployed in 2022. 2. For targeted employees: 1.5 hour training to exposed employees (purchasing, construction, finance, etc.) and a e-learning module proposed France and corporate offices (gift and invitation policy) targeted population3.1. How often is such training provided?
Optional commentThere are two different trainings : 1. For all employees: Code of Conduct Ethics and CSR training, (business ethics module), Deployed in 2022. Trainings are delivered every year but not all employees will attend every year. training for new employees are organized regularly. 2. For targeted employees: 1.5 hour training to exposed employees (purchasing, construction, finance, etc.) and a e-learning module proposed France and corporate offices (gift and invitation policy) targeted population4. Does the company monitor its anti-corruption compliance programme?
Optional comment1. A guide to preventing and managing conflicts of interest presents the concept of conflicts of interest in an educational way and provides practical examples. The guide comes with a conflict of interest declaration form. This declaration is annual and optional for some functions considered less exposed but mandatory for other functions, even if there is no conflict of interest, such as: - Members of the Group's Executive Management, the CEOs of the regions and all those working in the Audit, Risk and Compliance department; - All department heads at both the Group and regional level, plus employees in the following functions: expansion and development, real estate and construction and maintenance, procurement and catering; - Regional Directors and Facility Directors. Where a conflict of interest is declared, Compliance verifies whether or not it is material and implements the necessary corrective measures. As of March 2022, a new campaign to identify conflicts of interest has been launched for the above-mentioned people and on the basis of a more thorough questionnaire. 2. A global ethics alert system is available to all stakeholders in order to alert them to breaches of the principles of the Code of Conduct Ethics and CSR (Whistleblowing platform: www.orpea.signalement.net). 3. Monitoring process: starting 2022, monthly training sessions proposed to risk-exposed employees which have to sign an attendance sheetResponse and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional commentIn light of recent events, we have chosen to report according to the 2022 situation even though is is not within the reporting period. In light of the accusations made against the Group in early 2022, the board created a specific crisis committee which mandated an independent audit of the Group by Alvarez & Marsal and Grant Thornton. Results of those audit as well as press release are now available publicly on our website: - https://www.orpea-corp.com/images/orpeafinance/pdf/Communiques/ENG/2022/PR_ORPEA-conclusions_GTAM_ENG_50cf5.pdf - https://www.orpea-corp.com/images/orpeafinance/pdf/Communiques/ENG/2022/ORPEA-conclusions_GTAM_II_VF_200bd.pdf (in french)7. Does your company engage in Collective Action against corruption?
8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
Diverse actions are planned to be deployed in and have already been: 1. Commitment of top management regarding the anti-corruption principle 2. Preparation of 20 corruption and influence peddling risk maps (country and Group) validated by the Group Executive Committee, 3. Generic and specific training according to the level of exposure of employees to corruption risks 4. Self-assessment within the clusters of the level of internal control over the Major Rules.