Scope 1 Emissions
2022 Communication on Progress
NTT DATA EUROPE & LATAM SL
Published date
August 5, 2022
No. of questions
67
Supplemental files
Sustainability Report NTT DATA EMEAL 21-22.pdfNTT DATA EUROPE LATAM DECLARACIÓN PROVISIONAL VERIFICACION EINF 2021.pdfEnvironmental and Energy PolicyCEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentThe Board of Directors, NTT DATA Europe & Latam's highest governance body, issues an annual statement on the importance of sustainable development for the company, addressing impacts in the three dimensions of development (Economic and Governance, Social and Environmental). At the same time, at regular meetings, it is responsible for approving the organisation's sustainability objectives detailed in the global Sustainability & ESG strategy, as well as overseeing the Non-Financial Reporting (ESG) and reviewing the Potential Risks Report (in this regard, it specifically delegates to the Audit & Compliance Committee the relevant tasks of oversight and direct control of global risk management, which is led by the Chief Risk Officer (CRO).2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentThe holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., has a Compliance & Risk Management Department which is encharged of promoting the implementation of adequate Compliance & Risk Management Programs across the organization. Within these programs, that are currently being updated, one of the key aspects is to promote a zero tolerance for any conduct or behaviour that may be possible linked to corruption or bribery of any kind. Considering this update, now it is applicable the Code of Ethics and Professional Conduct of the NTT DATA Spain Group (group of companies that are part of the NTT DATA EMEAL Group) and that we attach herein. This Code forbids all kind of corruption or bribery acts, within the public and the private sector and promotes the Group to comply with all applicable laws on Anti-Corruption and on Anti-Bribery. In addition, the latter Group has a global Anti-corruption Policy which develops the referred Code (this is an internal Policy and confidential information of the Company so its content cannot be shared with third parties). Link: https://pt.nttdata.com/documents/code-ethics-eng.pdf3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commenthttps://mar.nttdata.com/documents/code-ethics-eng.pdf4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentThe ESG area reports to the Nominating and Sustainability Committee of the Board of Directors.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentThe holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., has a Group Chief Compliance Officer who supervises the Compliance Program implemented and that is being updated. This role directly reports on Compliance related mattres (including on Anti-Corruption) to the top management, in particular, to the holding parent company Audit & Compliance Comittee (body in which the Board of Directors delegates the Compliance function).Prevention
6. Does the company have a process or processes to assess risk?
Optional commentEvery Fiscal Year (FY), the Chief Risk Officer (CRO) reports to the Audit & Compliance Committee its global risk assessment (Annual Risk Assessment), in coordination with the rest of the areas involved in the Company. The risks are reported three times a year, at the beginning, in the middle and at the end of the financial year. The reports comprise, by way of summary, the following information: 1. Report at the beginning of the FY: The global risk matrix identifies the material or most critical risks in the organisation, anticipating some of the measures deemed appropriate for their prevention and/or reduction in that FY. Mid-FY report: The specific measures adopted by the Group for each of the material risks identified for their prevention and/or reduction are reported, as well as the number of incidents that may have occurred, the status of such measures (planned or not) and their evaluation, together with the assumptions that may have been detected by the Internal Audit area. FY-end report: A final assessment of the identified material risks is reported, including the total number of incidents, the degree of implementation of the measures taken for their prevention and/or mitigation, as well as the measures that are expected to continue or be taken, as appropriate, in the following financial year.6.1. During the assessment of risk, which business relationships are reviewed?
Optional commentThe Chief Risk Officer of the holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., coordinates and manages the risk assessment and evaluation of all corporate risks, also the ones linked to the Group business activity.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 commentThe ESG area reports to the Nominating and Sustainability Committee of the Board of Directors.7.1. During the due diligence process, which business relationships are reviewed?
Optional commentDue to the type of services we offer, we do not have a large number of suppliers, so the most relevant ones are analysed.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 commentWhistleblowing: The company has whistleblowing channels to ensure that anyone can anonymously report possible conduct related to corruption, bribery or any other irregularity. These channels allow any employee or professional of the Group, and any third party who has dealings with the Group, to make reports securely and anonymously, confidentially and anonymously. The information communicated is kept encrypted and adjusted to adequate security parameters.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 commentThe Whistleblowing System may be used by all professionals within the NTT DATA EMEAL Group and the NTT DATA EMEAL Foundation, as well as by any third parties who may have an interest or relationship with our Group or the NTT DATA EMEAL Foundation, or who act on our behalf or collaborate with us (clients, suppliers, agents, other related third parties, etc.). Access to the Whistleblowing System can be found at the bottom of the corporate website.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 commentThere is no process in place as the access to effective legal protection is a fundamental right which is available for any citizen by the applicable laws.Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentThe holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., has not face any case related to corruption or bribery. In the alleged scenario in which a case on this topic would occur, the Company would proceed in conformity with the steps provided in the reply to this question.Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentThe specific executive roles assigned to Compliance matters or the fight against corruption or bribery contemplates this aspect in their corresponding remuneration.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
13. Do you produce sustainability reporting according to:
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 commentThe results of the Materiality Matrix can be found in chapter 1.3 'Materiality Analysis' in the NTT DATA EMEAL Sustainability Report 21/22.Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
2.1. For each human rights policy, is it:
Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
Optional commentWe maintain constant communication with affected stakeholders to collaborate in the prevention/mitigation of the risks/impacts in question.4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
5. Who receives training for the following human rights issues?
Optional commentNTT DATA EMEAL Sustainability Report 21/226. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
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.
Within our ESG strategy and aligned with the corporate strategy, we closely monitor these aspects that are material for both the company and our stakeholders. These and other indicators are regularly reported to the Appointments and Sustainability Committee of the Board of Directors.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentFreedom of association and the effective recognition of the right to collective negotiation are regulated in the applicable collective bargaining agreement (Consultancy Collective Bargaining Agreement) as this is the normative source that has to regulate these types of rights. In the same sense, working conditions are regulated in the collective agreement as well as in the company's working time policy. On the other hand, forced labour and child labour are covered by our Code of Ethics as a practice that is totally prohibited by current legislation. Finally, occupational health and safety standards are adequately covered by existing policies on Health and Safety.1.1. For each labour rights policy, is it:
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?
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?
4. Who receives training for the following labour rights issues?
Optional commentTraining is only provided to employees and third parties in the case of Health and Safety. In all other cases, as these are labour law requirements, the company must comply with the applicable collective bargaining agreement, labour regulations and the prohibition of forced labour, child labour and non-discrimination in employment.5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentRegarding forced labour and child labour, there are no periodic reviews as these practices are totally prohibited. Health and safety policies are reviewed periodically. As far as working conditions are concerned, reviews are carried out in the event of changes to current labour legislation in order to adapt it to the same.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentThe percentage of employees covered by the agreement, broken down by country (Germany, Austria, Belgium, Spain, Italy, Portugal, Switzerland, Brazil and Chile) in accordance with the applicable regulations is 100%. The remaining countries do not have a sectorial collective bargaining agreement.7. What is the percentage of employees in a trade union or other workers' organization?
Optional commentThe only countries with trade unions are Mexico, called Sindicato blanco or Sindicato de protección (Federación Obrera Sindical -FOS-), the United Kingdom -Union and prospect-, Romania and Italy.8. In the course of the reporting period, what was the percentage of women in:
Optional commentSection 1.4 ESG INDICATORS of the Sustainability Report 21/229. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Optional comment83,3% = (26.704€/year/32.033€/year) x100 The remuneration policy at NTT DATA EMEAL guarantees equity without making any distinction regarding gender or any other diversity variable. For the same professional category, remuneration is the same for both men and women. However, there is a gender imbalance in the pyramid due to the shortage of women in STEAM disciplines and in the consulting sector. The effectiveness of the measures implemented to reduce this gap is being monitored.10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Optional commentA total of 19 occupational accidents occurred during the year, a figure that has increased compared to previous years due to the increase in the number of countries as a result of the integration process of NTT DATA EMEAL. An accident at work is considered to be any event that causes an injury to a person while performing work activities during working time. That is to say, that causes harm to the employee, occurs during the exercise of their work activity and generates sick leave, such as falls, slips, cuts, etc. Accidents in itinere, common illnesses (flu, COVID-19, operations, etc.), maternity, paternity and breastfeeding leave, as well as incidents that do not result in sick leave (minor cuts, minor falls, etc.) have not been included. According to the applicable law, there is no obligation to register de number of accidents per hour.11. In the course of the reporting period, what was the company’s incident rate?
Optional commentIn accordance with applicable labour legislation, only occupational accidentes are recorded and not any incidents that may exist that are not defined in the applicable labour/Health and Safety legislation.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 commentRemedies in case of breaches of the right of association, health and safety and work conditions are provided for in the relevant employment legislation and the applicable collective agreement, which regulates the possible consequences of breaches by the company.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.
In headquarters, a digital disconnection policy has been approved, which contributes to promote an appropriate working environment. Likewise, the use of digital devices by employees has been expressly regulated in a policy to encourage their appropriate use and to regulate possible interventions by the company on these devices to safeguard the employee's right to privacy. A teleworking policy has also been approved with the aim of providing employees with flexibility on employment.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentWe currently have an Environmental and Energy Policy applicable at all levels of the group.1.1. For each environmental policy, is it:
Optional commentOur Environmental and Energy Policy is based on the ISO 14001 and ISO 50001 standards, and is published for public consultation by anyone inside or outside the organization.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?
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 commentClimate Action: we currently calculate our carbon footprint in accordance with ISO 14064:2018, which is audited and verified by an independent third party. The people involved in the data collection and calculation are trained during the process. This information is then shared in our annual sustainability report. Water: we gather information on the company's water consumption and calculate the emissions associated with water consumption and treatment in each of our countries. This data is then audited both in the carbon footprint audit and in the audit of our sustainability report by an independent third party. This data is reported publicly in our sustainability report. Oceans, Forests, Biodiversity, and Land Use: Due to our IT consulting business model, we do not consider these types of issues to be material. In the case of water, although we also consider it non-material, since our FY20 we have been collecting information on water consumption, 100% of which comes from the water supply network. Air Pollution: As with the Climate Action response, we calculate our carbon footprint emissions according to ISO 14064, where we report CO2, CH4, N2O and HFCs, where boiler and air conditioning maintenance reports are audited, as well as calculating emissions from company business travel. This data is also double audited in those offices that have ISO 14001 and ISO 50001. Waste: we gather the company's hazardous and non-hazardous waste data and calculate the emissions associated with the management of waste treatment in each of our countries. This data is then audited both in the carbon footprint audit and in the audit of our sustainability report by an independent third party. This data is reported publicly in our sustainability report. These data are also audited by an independent third party in those offices where we have ISO 14001, by an independent third party. Energy & Resource use: Within our carbon footprint we study and analyse data on electricity and natural gas consumption, as well as paper consumption and laptop purchases. These issues are audited in the carbon footprint and sustainability reporting process by an independent third party. We currently have 72% renewable energy in the company, which we have a commitment to be 100% renewable by 2030, with parent group NTT DATA. This data is published in our sustainability report.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentIn the case of Climate Action and Energy, we have KPIs, which we approve annually and which are published in our sustainability report. For water, waste and air pollution, these are reviewed ad-hoc by country and communicated internally, so that countries (especially those with ISO 14001 and ISO 50001) are aware of the status of these issues, where a series of recommendations are made to reduce the associated impact.4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?
4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?
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)?
Optional commentBoth for Climate Action, Air Pollution, Waste, Energy and Resources. Annually, reports are made on the environmental status of each of our countries, where their situation is analyzed with respect to the rest of the countries and the Global Index, where subsequently strategic lines of recommendations are available to each country, to reduce the impact on these matters. Currently the analysis of water consumption is also being included, although for us it is not a material issue.Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
Optional commentWe currently calculate our carbon footprint based on the ISO 14064:2018 standard, which is externally verified. Within our Scope 1, we calculate direct emissions from our natural gas boilers and fugitive emissions of refrigerant gases. In our Scope 2, we calculate indirect emissions from electricity consumption. For what would be our Scope 3, we calculated emissions from business travel, purchased goods from laptop and paper purchases, business travel, telecommuting, water consumption and treatment, and waste management and treatment.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?
Optional commentBased on the TCFD, we have conducted an identification, assessment and analysis of our climate change risks and opportunities. We have also developed a system of recommendations to our countries to reduce their emissions, mainly through the procurement of renewable energy with a guarantee of origin certificate and the reduction of emissions from travel, by promoting teleworking, videoconferencing and contracts with more sustainable travel service providers (electric/hybrid fleets), as well as promoting, whenever possible in time and form, the alternative use of trains instead of airplanes.Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Optional commentWe have a commitment to be 100% renewable by 2030. By FY21 we had a commitment to have 63% renewable energy, reaching 72% during this period.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 commentOur business model is based on strategic IT consultingSector-specific: Forest, biodiversity, and land use
14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
Optional commentWe do not own or rent property in protected or key areas.15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
Optional commentWe do not have this type of property16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Optional commentAs part of our Net Zero by 2030 strategy, we are entering into agreements with organisations that create corporate forests, offset our emissions, and have corporate volunteering. During FY21 we have offset the emissions of some of our events, as well as the emissions of some countries, such as Portugal.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.
Our main strategy is to reach Net Zero by 2030. To do this, we will initially reduce our direct and indirect emissions, mainly through the contracting of 100% renewable energy by 2030, and the promotion of teleworking and videoconferencing policies, and sustainable transport, to reduce our commuting emissions. In adittion, we are immersed in reforestation projects, with corporate volunteering, to offset our remaining emissions. We are currently beginning to offset the emissions from our events, and we are initiating global offset projects for each of our countries, the first being Portugal.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentThe Global Anti-Corruption Policy promotes zero tolerance of corruption in any form and provides guidelines to be followed in this area, with special reference to compliance with the anti-corruption regulations of the United States -Foreign Corrupt Practices Act ("FCPA") - and the United Kingdom -UK Bribery Act ("UKBA"). Also in Anti-Bribery and Money Laundering matters that may be applicable from time to time, whether international, European or national. Likewise, the NTT DATA Spain Group promotes the use of the Anti-Bribery Clauses drawn up by the TRACE International Association (Anti-Bribery Compliance Solutions) in all international contracts that the company enters into with third parties in these areas. All areas of the organisation, especially the Business areas, must be very aware of this Policy, and must apply and comply with it in full.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 commentThe holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., has the intention (estimated) to draft a new global Policy on Conflict of Interest which will be applicable to all entities under the NTT DATA EMEAL Group perimeter. At the current moment, for the NTT DATA Spain Group (group of companies within the NTT DATA EMEAL Group) this topic is expressly adressed in the Code of Ethics and Porfessional Conduct of mentioned Group, within its section 3 "Objectivity".Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentIn addition to the reply, the holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., includes specific Anti-Corruption clauses or commitments in all Company contracts to be signed with third parties, as clients, suppliers, subcontractors, distributors, agents, intermediaries, etc.3.1. How often is such training provided?
4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
Optional commentThrough the global whistleblowing channels (Whistleblowing Systems), which operate in the two Operating Companies being integrated, no complaint or communication related to possible conduct associated with corruption or bribery, or involving an alleged breach of regulations in this area, has been received in the aforementioned FY, nor is there any record through other internal channels.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 commentNot applicable / no incidents in the reporting period.7. Does your company engage in Collective Action against corruption?
Optional commentThis is not urgent initiative of the Company (to participate in a colective action) as the Company is strongly working in the development of Anti-Corruption initiatives, within the framework of the Compliance Program, and it has not faced any incident in this field.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.
The holding parent company of the NTT DATA EMEAL Group, NTT DATA Europe & Latam, S,.L.U., through the Compliance & Risk Management Department, has the intention to reinforce the internal measures to prevent any corruption or bribery act. In this sense, it is estimated in the following FYs to draft a new Code of Conduct, global Anti-Corruption Policy, global Criminal Prevention Policy and global Gifts &Hospitality Policy covering properly this relevant topic. Also, it is the intention of the Company to reinforce the managing of this Compliance risk by further implementing additional controls for prevention and avoidance.