2022 Communication on Progress

ADM Elektrik Dağıtım A.Ş.

Published date

June 29, 2022

No. of questions

63

CEO Statement

Signed
  • Governance

    Policies and Responsibilities

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

    Optional comment
    Adm Electricity Distribution’s Board of Directors, Committees and Senior Management fulfill their duties by prioritizing the profitability of the company and the interests of the shareholders with a sustainability approach, with the awareness of being accountable to the company’s legal entity and shareholders with the principle of transparency. For us, corporate governance refers to the way we manage, control and monitor the company and our activities. Leading the integration of our sustainability approach into all business processes, our Board of Directors is the highest governance body responsible for tasks such as overseeing the company’s sustainability performance, in addition to tasks such as defining strategic targets, determining corporate governance strategy, identifying and allocating needed human and financial resources, monitoring the performance of the management, observing the compliance of company activities with the legislation, Company Articles of Association, internal regulations and established policies. While aiming to strengthen the trust we provide to all our stakeholders with our strong governance understanding, experienced Senior Management and successful business results, our business results and the effectiveness of our corporate governance structure, including the results of our approaches and practices that we have adopted by taking environmental, social and governance criteria into account, are constantly monitored by our Board of Directors with our performance indicators. Our Policies, Procedures and Sustainability Report are reached on our website. www.admelektrik.com.tr

    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
    Our company commitments are published in our corporate policies, procedures and sustainability reports. Our sustainability performance indicator results, progress and impact on our commitments and targets are published in our Sustainability Report annually. Our Policies, Procedures and Sustainability Report are reached on our website. ADM requires all its main suppliers, contractors, subcontractors and partners to adopt conduct in line with the general principles of the Company related policies. www.admelektrik.com.tr

    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
    Our company commitments are published in our corporate policies, procedures and sustainability reports. Our sustainability performance indicator results, progress and impact on our commitments and targets are published in our Sustainability Report annually. Our Policies, Procedures and Sustainability Report are reached on our website. ADM requires all its main suppliers, contractors, subcontractors and partners to adopt conduct in line with the general principles of the Company related policies. www.admelektrik.com.tr

    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
    ADM Electricity Distribution’s Board of Directors, Committees and Senior Management fulfill their duties by prioritizing the profitability of the company and the interests of the shareholders with a sustainability approach, with the awareness of being accountable to the company’s legal entity and shareholders with the principle of transparency. For us, corporate governance refers to the way we manage, control and monitor the company and our activities. Leading the integration of our sustainability approach into all business processes, our Board of Directors is the highest governance body responsible for tasks such as overseeing the company’s sustainability performance, in addition to tasks such as defining strategic targets, determining corporate governance strategy, identifying and allocating needed human and financial resources, monitoring the performance of the management, observing the compliance of company activities with the legislation, Company Articles of Association, internal regulations and established policies. In order for our Board of Directors to make more inclusive and effective decisions in all its duties, we have 5 committees working actively under our Board of Directors. Through these committees, where our expert managers and Board members add value, we can make fast and effective decisions. In order to achieve successful results and create longterm value for our shareholders and stakeholders, we manage processes and activities related to audit, risk management, corporate governance, investment, sustainability, occupational health and safety and environmental issues, monitor performance results, evaluate the control environment, through our Committees, and we ensure early detection of risks. Board Level Committees: • Audit Committee • Early Detection of Risk Committee • Corporate Governance Committee • Investment Committee • Committee of Sustainability, Environmental, Occupational Health and Safety Our Policies, Procedures and Sustainability Report are reached on our website. www.admelektrik.com.tr

    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
    In order for our Board of Directors to make more inclusive and effective decisions in all its duties, we have 5 committees working actively under our Board of Directors. Through these committees, where our expert managers and Board members add value, we can make fast and effective decisions. In order to achieve successful results and create longterm value for our shareholders and stakeholders, we manage processes and activities related to audit, risk management, corporate governance, investment, sustainability, occupational health and safety and environmental issues, monitor performance results, evaluate the control environment, through our Committees, and we ensure early detection of risks. Board Level Committees: • Audit Committee • Early Detection of Risk Committee • Corporate Governance Committee • Investment Committee • Committee of Sustainability, Environmental, Occupational Health and Safety Our Effective Sustainability Governance Our sustainability governance, which we embed in our corporate governance system and which different aspects are handled by the committees under our Board of Directors, is an indicator of our Company’s integrated governance network. Through the Early Detection of Risk Committee, we monitor all risks, including sustainability, energy supply security, risks related to climate change and environmental risks, with their financial aspects, as well as their non-financial effects, including their effects on our employees, all our stakeholders, society and the environment, and we manage. Through our Investment Committee, we make the most accurate and effective decisions for our environmentally friendly investments that will contribute to ensuring energy supply security, meet all energy demands in our distribution region, and support energy distribution in an efficient and safe manner, taking into account environmental, social and governance criteria in our evaluations of investments. we take As part of the focus of our business, we contribute to ensuring energy supply security, combating climate change, responsible production and consumption, sustainable cities and communities, decent work and economic growth, industry, innovation and infrastructure, reducing inequalities, and our sustainability understanding. Through the Sustainability, Environment, Occupational Health and Safety Committee, which is one of the parts of our strong corporate governance, we take matters related to sustainability to our agenda and evaluate them in detail. Through the Sustainability, Environment, Occupational Health and Safety Committee, we ensure the proactive adoption and development of a safe behavior approach, including in environmental regulations and activities, by developing the sustainability, occupational health and safety culture covering all our fields of activity and employees of the Company. At the same time, through the Committee, we inform the Investment Committee, the Early Detection of Risk Committee and the Board of Directors about preventive/remedial measures to ensure the implementation of sustainability principles, areas that may create opportunities, and operational results. Besides The Ethics and Discipline Committee, monitors the implementation of related Policies, too. Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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
    Our Risk Perception and Reliable Risk Management As ADM Electricity Distribution, we work with the belief that protecting the interests of all our stakeholders can be achieved through effective management of financial and non-financial risks, including risks related to climate change, environmental and sustainability in order to protect our company’s assets and values in the long term, and to ensure sustainable financial performance, competitiveness and growth. In addition to the financial effects of risks, we evaluate their reputational effects, their effects on supervisory and regulatory institutions, their effects on employees and our value chain. As ADM Electricity Distribution, we use internationally accepted risk management principles in our risk management processes. As ADMElectricity Distribution, we implement a reliable risk management mechanism in all our investment decisions and processes by integrating risk management into the whole of our activities and strategic planning, and we evaluate all risks and opportunities comprehensively. Through our risk awareness, which has become a corporate culture in all our processes and units, we ensure that our strategic decisions and operational activities remain within the limits of our risk appetite, and we manage all risk factors that may adversely affect our Company and our stakeholders, including financial performance and reputation, in the most effective way. We regularly review the risk management policies and systems that we have determined in order to identify and analyze the risks to be encountered, to determine the appropriate risk limits, to key risk indicators and to monitor the risks in comparison with the relevant limits. Our Policies, Procedures and Sustainability Report are reached on our website. www.admelektrik.com.tr

    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
    Our operations are assessed for risks related to anti-corruption, human rights, labour right, environment. Significant risks are identified through our risk assessments. Risk profile is monitored by our senior management and committees.

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

    No, this is not a current priority

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

    Yes, related to our own operations

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

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

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

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

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

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

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Most suppliers are evaluated/reviewed regarding ESG criterias such as Human Rights, Labour Rights/ Decent Work, Environment, Anti-Corruption during our operations and investment processes.

    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?

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

    No

    Yes

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

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

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

    Are there processes in place to avoid retaliation?

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

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    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

    Optional comment
    Company goals have a direct impact on the performance of all employees, including executive management. Performance results directly effect wages and other benefits. The company goals include objectives/quantitative KPIs related to 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 (#)

    4

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    25

    Above 50 years old (%)

    75

    From minority or vulnerable groups (%)

    0

    Executive (%)

    25

    Independent (%)

    75

    13. Do you produce sustainability reporting according to:

    GHG Protocol for GHG Emissions

    Data Assurance

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

    Reasonable assurance on majority of environmental, OHS, social, governance metrics in our Sustainability Report on our website by third parties such as assurance firms/auditors. https://www.admelektrik.com.tr
  • 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
    +Working conditions (wages, working hours) +Freedom of expression +Access to culture +Access to water and sanitation +Digital security / privacy +Rights of women and/or girls +Rights of indigenous peoples +Free, prior and informed consent +Rights of refugees and migrants

    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.

    Our Company, which acknowledges Human Rights as an integral part of its Codes of Conduct, undertaking the following; • To ensure that our employees, business partners, suppliers, contractors, subcontractors and all affiliate companies act in accordance with the our Human Rights Policy, • To observe the rights of indigenous people, immigrants and refugees and women and girls living in the regions where we operate and to take measures against violations of rights, • To comply with national and international laws and regulations related to Human Rights, to ensure that our business partners, suppliers, contractors, subcontractors also comply, to respect the right to property, • To base our commitments on Human Rights on the United Nations Universal Declaration of Human Rights to which Turkey is a signatory, • To take decisions in line with the United Nations Universal Declaration of Human Rights in all our investment activities and operations covering these activities and to organize our activities in this direction, • Not to tolerate discrimination within the scope of race, religion, language, color, age, gender, family status, national origin, employment, profession, social background, health status, physical disability, sexual preference, possible pregnancy, union activities or other factors • Valuing the differences of our employees, adopting diversity to achieve our goals, • To provide equal rights to all our employees in terms of remuneration, performance assessment, equal career opportunities, employment and similar issues, to provide fair wages and working hours and to announce all developments related to our equal opportunity plans through internal and external communication channels, • To secure the principles of equality of opportunity for women and men in all our human resources policies and procedures by supporting the participation of women in the workforce, and to increase the rate of employment, • To improve the gender balance in the decision-making mechanisms and to increase the proportion of women in the board of directors and senior management of our company, • Not to allow the employment of personnel who are classified as child workers at any stage of our activities, • To secure the issue of not employing child labor in the contracts made with our suppliers, contractors, subcontractors and to take this issue into consideration in the audits, to defend human rights in all our activities and every step of our supply chain • To establish fair training and support processes in order to ensure equality between our employees and to specifically encourage the participation of our employees in these trainings, • Not to allow forced labor under conditions that do not comply with laws and regulations at any stage of our activities and not to purchase materials or services from companies that apply forced labor, • To value all our stakeholders by accepting age, religion, language, gender, race, culture, other differences and to ensure that our egalitarian approach is spread to all our business partners, suppliers, contractors, subcontractors • To prevent all kinds of situations that will hinder our employees from exercising their right to freedom of expression in the business environment and to allow cooperation with non-governmental organizations, • To respect the right of our employees to collective bargaining and freedom of association and to prevent discrimination against the employee representative, • To provide our employees with healthy, ergonomic, hygienic, safe and pleasant working conditions, • Not to allow any violation of occupational health and safety principles to endanger the health, safety and/or life of the employees and to take the necessary measures, • To be a socially reliable employer to our employees with our company reputation, • To provide a safe and happy work environment with the understanding of human resources that does not break away from human rights and ethical values, to take into consideration the work-family life balance and to take into consideration the needs of working parents while creating the working environment and conditions, • To continue our operations in an ethical and transparent manner, to show zero tolerance to corruption and unethical behavior, • To establish and maintain an effective corporate governance approach, • Not to tolerate incidents such as maltreatment, intimidation, inhuman or degrading treatment, psychological violence, harassment and abuse through verbal or written communication in the business environment, • To stand against all violent behaviors, including domestic violence, violence against nature and animals, in the workplaces or in the private life of our employees, • To be sensitive to the environment for a livable and green world and to consider the principle of nature conservation as a priority in all its activities, • To monitor our ESG performance continuously and to inform our stakeholders through reports/disclosures on ESG issues that may seriously affect the views of our stakeholders, • To ensure the highest level of representation within our organization of the follow-up of the issues included in the Declaration of Human Rights and Company's Policy, and to announce this committed and implemented policy to all our employees, • To create an honest and transparent Company culture in accordance with international standards and local laws and regulations, • To give importance to the sharing of employees about our policy and to evaluate possible policy violations communicated to ethic line, • To make it accessible to the public and third parties, • To increase our rate of senior and middle level female managers to 20 % by the end of 2024, • To follow up our policy by ensuring effective communication with our stakeholders. Our Company has adopted aboves as its Human Rights policy. As the company will continue to take the necessary actions to fulfill the above commitments in the future. Our Policies, Procedures and Sustainability Report are reached on our website. www.admelektrik.com.tr
  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

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

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

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

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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)

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    49

    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 (%)

    49

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    15.71

    Non-executive board

    0

    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 (%)

    100
    Optional comment
    No salary difference between women and men employees.

    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

    2.25
    Optional comment
    TRIFR: Total Recordable Injury Frequency Rate (/1.000.000 hwkd)

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    2.25
    Optional comment
    LTIFR: Lost Time Injury Frequency Rate (/1.000.000 hwkd)

    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)

    Optional comment
    No negative impact have been realized which affecting the stakeholders resulting from our activities. In addition, as a company, we contribute to the transformation and development of our country, our industry and all our stakeholders, especially with our studies and commitments in terms of Labour Issues.

    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.

    Our Company, which acknowledges Human Rights as an integral part of its Codes of Conduct, undertaking the following; • Not to allow the employment of personnel who are classified as child workers at any stage of our activities, • To secure the issue of not employing child labor in the contracts made with our suppliers, contractors, subcontractors and to take this issue into consideration in the audits, to defend human rights in all our activities and every step of our supply chain • Not to allow forced labor under conditions that do not comply with laws and regulations at any stage of our activities and not to purchase materials or services from companies that apply forced labor, • To make it accessible to the public and third parties, • To increase our rate of senior and middle level female managers to 20 % by the end of 2024, • To follow up our policy by ensuring effective communication with our stakeholders. Our Company has adopted the above as its Human/Labour Rights policy. As the company will continue to take the necessary actions to fulfill the above commitments In the future. Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr
  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    N/A for Turkey

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

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

    2021

    Energy & Resource Use

    2021
    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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

    Optional comment
    We are in a constant and transparent dialogue with our stakeholders, listening to and considering each and every feedback coming from them and collabrate in the prevention, mitigation of the risks/ impacts in question.Thus, we create value for them in line with their expectations. Opinions of our stakeholders constitute the basis of our materiality analysis as well as the strategies and goals of our Company. With this approach, we communicate with our stakeholders regularly, listen to their views with regard to our business, goals and performance and try to understand their expectations. More importantly, we want to meet those expectations with our decisions concerning investments, transformation and improvement. We define the key stakeholders as people and organizations which are affected by our current and future activities and performance while having an impact on the performance of the company with their acts and decisions. are reached on our website. https://www.admelektrik.com.tr

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    In the line with our goals, we aim to become carbon neutral in 2051. We aim to reduce our emission intensity per generation by 43% in 2025. We aim to reduce our emission intensity per generation by 86% in 2035. (based year 2017)

    Energy & Resource Use

    To make renewal, improvement and capacity increase, R&D, technology investment and maintenance work until the end of 2025 in line with investment plans and budget. With these investments to increase our line length, number of transformers and installed power of transformers until the end of 2025.

    Water

    To reduce our water consumption per employee by 5 % in 2023 compared to 2021

    Forests / Biodiversity / Land Use

    To establish respectful biodiversity plans in sensitive areas by protecting natural life, To provide support for the protection of biodiversity, flora and fauna, and habitats, To make biodiversity impact measurement and evaluation

    Air Pollution

    To reduce waste, to ensure recovery and to prevent pollution, to ensure transparent monitoring and management of waste, Based on 2017, to reduce our emissions by 43% in 2025, to reduce our emissions by 86% in 2035, to be carbon net zero in 2051 in line with these targets.

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

    To reduce waste, to ensure recovery and to prevent pollution, to ensure transparent monitoring and management of waste, On the basis of the amount of energy distributed, to reduce our waste intensity by 8% in 2023, compared to 2021, To realize recycling in the most efficient way and to minimize the wastes resulting from our activities.

    Oceans

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Oceans

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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

    N/A for Turkey

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    19386

    Scope 2 Emissions

    Emissions (tCO2e)

    273514

    Scope 3 Emissions

    Emissions (tCO2e)

    28185

    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 (%)

    R&D investment details are stated in our Sustainability Report. Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    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

    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.

    Sector-specific: Water

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

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    11.6

    Groundwater:

    1

    Surface water:

    10

    Rainwater:

    Wastewater:

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    11.6

    Groundwater:

    1

    Surface water:

    10

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Optional comment
    Drinking water is 0.6 mega-liter

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

    Water intensity of products (cubic meter/$):

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    We do not have any activity, in this context.

    SOx

    We do not have any activity, in this context.

    Volatile Organic Compounds (VOC)

    We do not have any activity, in this context.

    Hazardous air pollutants (HAP)

    We do not have any activity, in this context.

    Particulate matter (PM10)

    We do not have any activity, in this context.

    Persistent organic pollutants (POP)

    We do not have any activity, in this context.

    Other (please specify in text box)

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    19007
    Optional comment
    Waste re-cycle rate: 100%

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    1.3
    Optional comment
    Waste re-cycle rate: 100%

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    The value is reported in CDP reporting.

    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.

    ADM has just updated its Environmental Policy (2021). Furthermore in order to identify and minimize environmental risks a series of activities have been carried out such as actions for the classification and analysis of events, actipns for assessing environmental risks and opportunities, Environmental assessment/inspection of suppliers, contractors, subcontactors, biodiversity and action plans, etc. Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr
  • Anti-corruption

    Commitment

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

    2021
    Optional comment
    Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr Our policies are reviewed annually.

    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
    Please refer to link for Anti-Bribery and Anti-Corruption Policy, Ethical Rules and Working Principles, Code of Conduct and Business Principles, Donation and Aid Policy and Compliance Activities and Compliance Risk Implementation Policy, Public Relations Policy and our other related policies and procedures: https://www.admelektrik.com.tr

    Prevention

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

    Optional comment
    ADM requires all its main suppliers and partners to adopt conduct in line with the Code’s general principles and that their employees are adequately trained.

    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?

    Optional comment
    Anti-Bribery and Anti-Corruption Policy: The main purpose of our Anti-Bribery and Anti-Corruption Policy is to prevent corruption and bribery and to emphasize the importance of compliance with anti-bribery and anti-corruption regulations in our operations. The Anti-Bribery and Anti-Corruption Policy applies to all of our employees and managers, as well as relevant third parties (including their employees) with whom we work, such as suppliers and consultants. We ensure compliance with the Anti-Bribery and Anti-Corruption Policy, to the extent possible, by adopting compliance clauses (such as termination rights) in our contracts with these parties or by requesting compliance commitments from these parties. Sustainability Report p.47 and 170. Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    There is no major issue within the scope of the Ethical Disclosures made in 2021. Furthermore; there were no corruption incident during the period under review.

    Confirmed during the current year, and related to this year

    0
    There is no major issue within the scope of the Ethical Disclosures made in 2021. Furthermore; there were no corruption incident during the period under review.

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

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

    ADM has been a “Participant” member of the UN Global Compact, thanks to its commitment to organization and adherence to its ten founding principles relating to human rights, labor standards, environmental protection and the fight against corruption in a wide area from our Board of Directors to our supply chain. We became a member of the “Together We are Strong” platform, a network of companies working in the field of gender equality in the business world. In the face of all kinds of violence against women, we participated in the #UN Women Turkey’s #Don’t Remain Unresponsive Awareness call by standing by women, and we painted our lighting poles orange and illuminated our streets in order to raise awareness against violence against women. We joined the Business World Against Domestic Violence Platform in cooperation with Sabancı University and participated in the 5-month training sessions.

    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.

    ADM has a system based on compliance programs, including the Code of Ethics, Policy on Human Rights, the Zero Tolerance of Corruption Plan and (completed) actions regarding company commitments in line with company-wide principles. Sustainability Report p.100-101 Our Policies, Procedures and Sustainability Report are reached on our website. https://www.admelektrik.com.tr