2022 Communication on Progress

Lenovo Group Limited

Published date

June 28, 2022

No. of questions

55

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    See page 68 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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 see the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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
    https://www.lenovo.com/us/en/sustainability-ethical-business

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

    No one is specifically responsible for this topic

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

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

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    See page 68 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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
    See page 69 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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
    See page 37 in the FY 21-22 Annual Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/ar2022.pdf

    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
    Please see pages 96-99 in the FY21-22 Annual Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/ar2022.pdf

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

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    See pages 11-12 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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

    Optional comment
    See pages 82-90 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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
    See page 48 in the Lenovo Code of Conduct: https://www.lenovo.com/us/en/sustainability-ethical-business

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    Optional comment
    Please see pages 72-73 of the FY 21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf and page 48 of the Lenovo Code of Conduct: https://www.lenovo.com/us/en/sustainability-ethical-business

    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
    Please see pages 73 of the FY 21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    See pages 54-56 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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 (#)

    10

    Male (%)

    90

    Female (%)

    10

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    30

    Above 50 years old (%)

    70

    From minority or vulnerable groups (%)

    60

    Executive (%)

    10

    Independent (%)

    70
    Optional comment
    See page 67 in the FY21-22 Annual Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/ar2022.pdf Board consists of: Executive: 10%; Non-executive: 20%; Independent non-executive: 70%

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

    https://p4-ofp.static.pub/ShareResource/sustainability-resources/20.21-ghg-and-energy-verification-statement.pdf https://p2-ofp.static.pub/ShareResource/sustainability-resources/20-21-water-verification-statement.pdf

  • 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
    See pages 56-58 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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.

    Please see pages 61-65 in the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

  • 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

    https://www.responsiblebusiness.org/media/docs/RBACodeofConduct7.0_English.pdf

    Forced labour

    https://p4-ofp.static.pub/ShareResource/sustainability-resources/anti-slavery-and-human-trafficking-statement-aug2020.pdf https://www.responsiblebusiness.org/media/docs/RBACodeofConduct7.0_English.pdf

    Child labour

    https://p4-ofp.static.pub/ShareResource/sustainability-resources/anti-slavery-and-human-trafficking-statement-aug2020.pdf https://www.responsiblebusiness.org/media/docs/RBACodeofConduct7.0_English.pdf

    Non-discrimination in respect of employment and occupation

    https://www.lenovo.com/us/en/policy/eeo_aa_policy

    Occupational safety and health

    https://p4-ofp.static.pub/ShareResource/sustainability-resources/lenovo-health-and-safety-policy.pdf

    Working conditions (wages, working hours)

    Pages 83-84 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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)

    Optional comment
    See pages 57-57 and 82-88 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.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 labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Please see pages 11-12 and 83-88 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.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 this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Please see pages 83-88 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    Optional comment
    https://www.responsiblebusiness.org/media/docs/RBACodeofConduct7.0_English.pdf

    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 (%)

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    23

    Non-executive board

    10
    Optional comment
    See pages 65 of the FY 21-22 Annual Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/ar2022.pdf

    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 (%)

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

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0
    Optional comment
    please see page 98 of the FY21-22 ESG Report: : https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0
    Optional comment
    please see page 98 of the FY21-22 ESG Report: : https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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.

    please see pages 42-53 of the FY21-22 ESG Report: : https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

  • 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

    March 31, 2022: https://www.lenovo.com/us/en/social_responsibility/climate_policy/

    Water

    February 01, 2021: https://p4-ofp.static.pub/ShareResource/sustainability-resources/water-resiliency-policy.pdf

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    See pages 19-23 in the FY20-21 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2021/esr.pdf

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

    See pages 24-25 in the FY20-21 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2021/esr.pdf

    Energy & Resource Use

    https://www.lenovo.com/us/en/social_responsibility/climate_policy/
    Optional comment
    See pages 20-23 in the FY20-21 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2021/esr.pdf

    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

    Included with Lenovo's Environmental Policy: https://www.lenovo.com/us/en/social_responsibility/environmental_policy/

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

    Included with Lenovo's Environmental Policy: https://www.lenovo.com/us/en/social_responsibility/environmental_policy/

    Energy & Resource Use

    Optional comment
    https://www.lenovo.com/us/en/social_responsibility/climate_policy/

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    Scope 2 Emissions

    Emissions (tCO2e)

    Scope 3 Emissions

    Emissions (tCO2e)

    Optional comment
    See page 90 in the FY20-21 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2021/esr.pdf

    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 (%)

    Optional comment
    See Lenovo's 2021 CDP Response: C4.2 and C4.3

    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.

    % of total energy consumption

    75
    Optional comment
    See Lenovo's 2021 CDP Response, C8.2a

    Technology

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

    Percent of total revenue (%)

    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.

    The Company is working both internally and externally to minimize and mitigate climate risks. It is committed to reducing the global carbon footprint of its business activities and has demonstrated its commitment by: • Implementing a corporate Climate and Energy Policy • Executing a long-term comprehensive Climate Change Strategy • Setting corporate-wide objectives and targets which support the above Policy and Strategy. In June 2020, the Company established science-based emissions reduction targets, which were validated by the Science-Based Targets initiative (SBTi). Its Scope 1 and 2 emissions reduction targets are consistent with limiting warming to 1.5°C, the most ambitious goal of the Paris Agreement, and its Scope 3 emissions reduction targets meet ambitious criteria according to the SBTi’s methodology, which means they are in line with current best practices. These targets have a base year of FY 2018/19 and a target year of FY 2029/30. The following table details the Company’s Science-Based Targets, road maps for their achievement, and progress against the targets in FY 2020/21. Where actual direct energy reductions or use of renewable energy sources are not technically or economically feasible, the Company chooses to purchase Renewable Energy Credits (REC), International Renewable Energy Credits (I-REC), and Guarantees of Origin (GO). In FY 2020/21 the Company purchased renewable commodities that supported 100 percent renewable energy projects in Brazil (wind), China (wind), India (solar, wind), Mexico (wind), Europe (hydro, solar, wind), and the United States (wind). The images below are of solar panel installations at the Company’s Morrisville, North Carolina, USA location. The Company’s climate risk assessment in FY 2020/21 also included climate scenario analysis to explore how physical and transition risks and opportunities of climate change can impact its business. Additionally, its ESG materiality assessment identifies energy and emissions as material topics that it should prioritize and focus on in its environmental programs. Also, in support of UN Sustainable Development Goal (SDG) 13 – Climate Action; one of the Company’s ESG pillars includes a climate action goal. More details about the Company’s materiality are available on page 14. For more details please see the FY20-21 ESG Report, pages 18-26: https://doc.irasia.com/listco/hk/lenovo/annual/2021/esr.pdf

  • Anti-corruption

    Commitment

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

    Dec 2021: https://static.lenovo.com/ww/docs/sustainability/LENOVO_ANTI-CORRUPTION_BRIBERY_POLICY.pdf

    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
    https://static.lenovo.com/ww/docs/sustainability/LENOVO_ANTI-CORRUPTION_BRIBERY_POLICY.pdf and the Lenovo Code of Conduct:

    Prevention

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

    Optional comment
    Some distributers and reseller program partners also receive anti-corruption and anti-bribery training on an ad-hoc basis.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

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

    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

    Confirmed during the current year, and related to this year

    1
    Page 71 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf
    Optional comment
    Page 71 of the FY21-22 ESG Report: https://doc.irasia.com/listco/hk/lenovo/annual/2022/esr.pdf

    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?

    Lenovo's Executive Ethics Committee also reviews
    Optional comment
    The Company’s Code reflects a culture of trust and integrity, holds employees accountable for their behavior and helps employees determine when and where to seek advice. The Company’s Code, policies, and related awareness and training materials are provided periodically through various methods of communications. The ECO is supported by three committees. The Executive Ethics Committee provides executive-level oversight and guidance to the ECO. The Investigation Oversight Committee works closely with the ECO to oversee the Company’s internal investigation process. The Regional Ethics and Compliance Committee provides the ECO with global support, perspective, and insight.

    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.

    The Company is committed to conducting business legally, ethically, and with integrity. Its Ethics and Compliance Office (ECO) oversees the ethics and compliance function across the organization and strives to promote a culture that is committed to ethical business conduct. The ECO works in partnership with business units across the globe to promote legal and ethical operations. The ECO is committed to raising awareness about the importance of ethical and compliant business practices to the Company and serves a critical role in providing employees with the information, resources, and training they need to make informed ethical decisions. The ECO oversees Lenovo’s Code of Conduct (Code), which establishes clear expectations for employee compliance with its policies related to lawful and ethical business conduct. The Code reflects the Company’s culture of trust and integrity and holds employees accountable for their behavior and helps employees determine when and where to seek advice. The Code, policies, and related awareness and training materials are provided electronically and through periodic communications. The ECO is supported by various committees. The Executive Ethics Committee provides executive-level oversight and guidance to the ECO. The Investigation Oversight Committee works closely with the ECO to oversee the Company’s internal investigation process. The Regional Ethics and Compliance Committee provides the ECO with global support, perspective, and insight. The Audit Committee also oversees the ECO and receives regular updates about the program priorities and initiatives.The Company is committed to conducting business legally, ethically, and with integrity. Its Ethics and Compliance Office (ECO) oversees the ethics and compliance function across the organization and strives to promote a culture that is committed to ethical business conduct. The ECO works in partnership with business units across the globe to promote legal and ethical operations. The ECO is committed to raising awareness about the importance of ethical and compliant business practices to the Company and serves a critical role in providing employees with the information, resources, and training they need to make informed ethical decisions. The ECO oversees Lenovo’s Code of Conduct (Code), which establishes clear expectations for employee compliance with its policies related to lawful and ethical business conduct. The Code reflects the Company’s culture of trust and integrity and holds employees accountable for their behavior and helps employees determine when and where to seek advice. The Code, policies, and related awareness and training materials are provided electronically and through periodic communications. The ECO is supported by various committees. The Executive Ethics Committee provides executive-level oversight and guidance to the ECO. The Investigation Oversight Committee works closely with the ECO to oversee the Company’s internal investigation process. The Regional Ethics and Compliance Committee provides the ECO with global support, perspective, and insight. The Audit Committee also oversees the ECO and receives regular updates about the program priorities and initiatives.