Report - COP Prototype

2022 Communication on Progress

Treedom

Published date

June 14, 2022

No. of questions

Supplemental files

Privacy Policy di treedom.net.pdf Green_Office_Toolkit_ENG (1).pdf treedom_methodology_02_treedom_standard_en (1).pdf treedom_methodology_01_code_of_ethics_en.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

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

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

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

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

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

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

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

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

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

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

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

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?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

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?

Board Composition

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

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	5
Male (%)	75
Female (%)	25
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	100
Above 50 years old (%)	0
From minority or vulnerable groups (%)	0
Executive (%)	25
Independent (%)	75

Data Assurance

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

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Limited assurance for majority of metrics

Financial auditors also certified our impact report

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Optional comment

Specific data about labor, work condition and other metrics are performed under national law, for which the absence of infraction procedures certified that we follow the law on that topic

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	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
Rights of women and/or girls
2017
Freedom of expression
2017
Rights of refugees and migrants
Digital security / privacy
2022
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights 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 human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

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?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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?

	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
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human 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.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human 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)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

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.

Treedom in 2016 has drafted an important corporate internal code related to the implementation of human rights in all its operations. Based on this document we choose all the NGOs we collaborate with or we establish new business relations. To better ensure the compliance of the new partners with our human rights code, Treedom asks possible partners to fill a questionnaire in which they inform the organization about their human rights commitment. Furthermore, Treedom promotes human rights within the activities of our business partners and clients by advising them on human rights issues and measures to respect, protect and promote human rights. https://www.treedom.net/pdf/methodology/treedom-methodology-01-ethical-code- en.pdf Over the next two years, we expect to organise a detailed corporate policy on human rights for the company and its suppliers, so we plan to organise regular due diligence procedures by third parties.

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
Freedom of association is enshrined in Article 39 of the Italian Constitution and is detailed in Law No. 300 of 20 May 1970 (Workers' Statute). The trade union in the company is a right that employees can exercise if there are more than 15 people employed in each site, factory, branch, office or autonomous department. Currently, there is an internal RSA, an employee, who is in charge of maintaining relations with the trade union and promoting regular meetings with it. It also submits some agreements outside the CCNL to the approval of the Trade Union (e.g. Welfare On Top regulation active from 2020). Everyone is free (in accordance with the law) to join the "United Trade Union Representatives", which are governed by interconfederal agreements, to which bargaining is delegated at company or territorial level. Their responsibility is the negotiation of relevant aspects such as national collective agreements. They can support workers in case of disputes with the company management. At the moment some of the employees have chosen to join different trade union representatives including CGIL, UIL etc. At the moment, the small number of employees has always made it possible to settle disputes directly with management, but it cannot be excluded that as the number of employees grows, they will decide to start an internal union representation. Trade union representatives are autonomous and independent from state bodies and public authorities as well as unconnected to the company. Forms of representation on the site There are internal procedures for the assessment of an individual or collective workers' issues, which are managed in the first instance by Human Resources and in the second instance by company management. We are an unionised company with an internal RSA. Collective bargaining agreements In the Italian legal system, agreements on the treatment of workers are concluded by trade union and industrial representatives through the CCNL collective labour agreements. The CCNL are acts that regulate the minimum economic and regulatory treatment common to all workers in the sector. Treedom adheres to the CNNL Tertiary, Commerce, Distribution and Services, valid from 1/4/2015 to 31/7/ 2018 was signed by Confcommercio and the trade unions Filcams-CGIL; Fisascat-CISL; Uiltucs - UIL, UGL Tertiary. The trade CCNL was signed by the trade unions on 30 March 2015 and came into force on 01/04/2015. The national contract for commerce, which expires on 31/12/2019, has not yet been renewed for both the economic and regulatory aspects. When the new CCNL comes into force, the company informs its employees and adjusts their contractual treatment if necessary. Employees can ask management for clarification at any time, and the company employs external consultants who are experts in this field to make the changes.
Forced labour
Treedom complies with the obligations imposed by the Italian Civil Code, pursuant to Article 2118 of the Italian Civil Code, whoever intends to withdraw from an open-ended contract (therefore both dismissal and resignation) must give notice (the duration of which is established by the CCNL applied to the case in question). However, it is possible to pay an indemnity in lieu of notice. No notice is required if the termination is for a just cause (Art. 2119 of the Civil Code): in this case, it is the withdrawing party who is entitled to payment of the indemnity in lieu of notice. In any case, a consensual termination of the relation for an indefinite period is also possible). Mitigate the risk of bonded labour We do not make advances that may extend the employment contract. Ensure that there are no employment fees deducted, or payments or deposits made to commence employment. Payments to employees are only made after the payroll has been processed. This is done by an external consultant who must check that all regulations in force that do not provide for this practice are complied with. Ensure that the workers do not experience any form of mobility restriction The company complies with workplace safety legislation D.Lgs.81 which stipulates that emergency doors must always be open, and under no circumstances may the personal freedom of other citizens, including employees, be restricted. In addition, under no circumstances are employees required to provide original identity documents, allowing them to travel and move freely at all times. Ensure that the workers have access to their passports and identification documents at all times while at the same time offering a safe place for storing the documents. In no case are employees required to provide original identification documents, allowing them to travel and move freely at all times. Ensure that there are no threats of denouncing workers to the authorities We are an unionised company with internal union representation.
Child labour
Treedom complies with the Italian legislation on the right to work that provides for a minimum age of 16 years. This limit was regulated by art. 3 of Law n. 977/1967, amended by art. 5 of Legislative Decree n. 345/1999: "the minimum age of admission to work is set at the time when the child has completed the period of compulsory education". The principle, therefore, applies that the minimum age of admission to work cannot be lower than the age at which compulsory schooling ends. In view of the above, since the 2007 Budget Law (296/2006) expressly states that the increase in compulsory education will take effect "from the 2007/2008 school year", the increase in the age at which minors can enter the labour market to 16 will also take effect from 1 September 2007. Regulations: Note prot. 9799 of 20 July 2007 of the Ministry of Labour and Social Security. In order to ensure that this regulation is respected, all workers are asked to provide an identity document and tax code when they are contracted and taken on, so that the exact age of the holder can be verified. At the moment, in 10 years of activity, we have never employed a person under the age of 18. For our operations abroad we also ask our partners to respect our code of ethics which expressly prohibits the use of child labour. We record the age of all our employees and combine their identity card and tax identification data. In addition, these data are sent to the relevant authorities for the registration of contracts and compliance with social security obligations. In this case, if there is a problem of correspondence, the public authorities will inform us of the problem themselves.
Non-discrimination in respect of employment and occupation
Treedom complies with the Italian legislation on this matter art.19, paragraph 2, of Legislative Decree no. 175 of August 19, 2016, regulates the procedures of research and selection of employees applied by Treedom in compliance with the principles, also of EU derivation, of impartiality, publicity, equal conditions and transparency, as well as the principles referred to in Article 35 paragraph 3 of Legislative Decree no. 165/2001. In carrying out the activities of recruitment and selection of employees, according to the above criteria, Treedom guarantees, in access to employment, equal opportunities, without any discrimination, in line with current legislation (Legislative Decree no. 198/06 as amended by Legislative Decree no. 5 of 25.01.2010). Recruitment of company personnel is carried out on the basis of the annual plan of activities, the budget and the organisational needs of the company itself, in compliance with current legal provisions, collective bargaining and company regulations. The search and selection of employees takes place through comparative selection procedures aimed at ascertaining the correspondence of the professionalism, skills and attitudes of the candidates to the characteristics of the positions to be filled. Treedom makes public the search for personnel through selection notices published on its institutional profile LinkedIn and its corporate website - section "work with us" - and may also make use, in relation to the specificity of the search, of contacts with external organizations and/or companies specialized in research and selection of personnel. The selection notices published specify: the activities envisaged for the position sought, the minimum requirements necessary for participation in the selection process, as well as any additional requirements to complete the profile that will be assessed as a plus with respect to the previous ones, the personal characteristics, the procedures for carrying out the selection and the contractual treatment envisaged. The selection notice may also provide for the possibility of using the published ranking list for recruitment needs arising in the course of the following 6/12 months. The curricula received in response to the selection notices or with spontaneous applications through the search channels of the Human Resources Department are collected. The verification of whether the curricula meet the requirements for admission to the selection process is carried out by the Human Resources Department, possibly with the support of specialised external companies, and is shared with the contact person of the requesting Department, who will be available as one of the members of the Examination Board. In particular, the Examination Committee shall be composed of three members, one of whom shall act as Chairman, and shall be specifically identified from time to time and shall be made up of the representative(s) of the Human Resources Department and of the requesting Company Departments who have proven experience in matters pertaining to the job position being selected or in personnel selection matters. The Selection Committee may also include an external member with specific expertise in personnel search and selection or in the field of the professionalism sought. The members of this Committee will be appointed on each occasion by the Head of the Human Resources, Organisation and General Affairs Department. For highly specialised professional profiles, the composition of the Selection Board may be supplemented by 1 or 2 additional members. In compliance with the principle of transparency, the Commission will adopt the pre-determined assessment criteria prior to the completion of the selection tests, which must be followed by the relative scores for the individual stages, on the basis of assessment criteria which are also pre-determined. The Commission will begin the selection of successful applications. The selection procedure may consist, by way of example, of one or more of the following elements - a technical test with a mark - psycho-aptitude test, with marks for each of them - group tests - individual interview On the basis of the results of the above selective tests, the Commission identifies the shortlist of suitable candidates, determined by the merit list. On the basis of the merit list, the Examination Committee identifies the most suitable candidate(s) to proceed to the recruitment phase. The Human Resources Department, having obtained the necessary approvals and authorisations, carries out the recruitment and/or employment procedures. In the event of failure to fill the position offered due to renunciation on the part of the persons already selected, other suitable candidates, present in the ranking list, with the score immediately lower than that of the selected candidate shall be recruited or, failing this, a new selection procedure shall be started. Should the recruitment be delayed or, for reasons of force majeure, no longer possible, the cancellation or suspension of the search will be communicated by publication on the website. Recruitment is by means of an individual employment contract of indefinite or fixed-term duration in compliance with the relevant national legislation in force, following successful completion of the trial period provided for in the contract for the category and level of classification. The level of classification and the relative economic treatment will be those provided by the CCNL for workers in the service industry and applied by the Company and any Supplementary Company Agreement.
Occupational safety and health
2010
Working conditions (wages, working hours)

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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
Treedom complies with the obligations imposed by the Italian Civil Code, pursuant to Article 2118 of the Italian Civil Code, whoever intends to withdraw from an open-ended contract (therefore both dismissal and resignation) must give notice (the duration of which is established by the CCNL applied to the case in question). However, it is possible to pay an indemnity in lieu of notice. No notice is required if the termination is for a just cause (Art. 2119 of the Civil Code): in this case, it is the withdrawing party who is entitled to payment of the indemnity in lieu of notice. In any case, a consensual termination of the relation for an indefinite period is also possible). Mitigate the risk of bonded labour We do not make advances that may extend the employment contract. Ensure that there are no employment fees deducted, or payments or deposits made to commence employment. Payments to employees are only made after the payroll has been processed. This is done by an external consultant who must check that all regulations in force that do not provide for this practice are complied with. Ensure that the workers do not experience any form of mobility restriction The company complies with workplace safety legislation D.Lgs.81 which stipulates that emergency doors must always be open, and under no circumstances may the personal freedom of other citizens, including employees, be restricted. In addition, under no circumstances are employees required to provide original identity documents, allowing them to travel and move freely at all times. Ensure that the workers have access to their passports and identification documents at all times while at the same time offering a safe place for storing the documents. In no case are employees required to provide original identification documents, allowing them to travel and move freely at all times. Ensure that there are no threats of denouncing workers to the authorities We are an unionised company with internal union representation.
Child labour
Treedom complies with the Italian legislation on the right to work that provides for a minimum age of 16 years. This limit was regulated by art. 3 of Law n. 977/1967, amended by art. 5 of Legislative Decree n. 345/1999: "the minimum age of admission to work is set at the time when the child has completed the period of compulsory education". The principle, therefore, applies that the minimum age of admission to work cannot be lower than the age at which compulsory schooling ends. In view of the above, since the 2007 Budget Law (296/2006) expressly states that the increase in compulsory education will take effect "from the 2007/2008 school year", the increase in the age at which minors can enter the labour market to 16 will also take effect from 1 September 2007. Regulations: Note prot. 9799 of 20 July 2007 of the Ministry of Labour and Social Security. In order to ensure that this regulation is respected, all workers are asked to provide an identity document and tax code when they are contracted and taken on, so that the exact age of the holder can be verified. At the moment, in 10 years of activity, we have never employed a person under the age of 18. For our operations abroad we also ask our partners to respect our code of ethics which expressly prohibits the use of child labour. We record the age of all our employees and combine their identity card and tax identification data. In addition, these data are sent to the relevant authorities for the registration of contracts and compliance with social security obligations. In this case, if there is a problem of correspondence, the public authorities will inform us of the problem themselves.
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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 (%)	100

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	85

Optional comment

All the employees in Italy are part of the company trade union representatives (RSAs) and 6 employees are also subscribed to a Union of their choice (all the workers have this possibility). Article 19 of the Workers' Statute guarantees the presence of trade unions in the workplace through the possibility of establishing company trade union representatives (RSAs). RSAs can be established at the initiative of workers, but only within the framework of trade union organisations with certain requirements. Company trade union representatives may be set up at the initiative of workers in each production unit, within the framework of trade union associations that are signatories to collective labour agreements applied in the production unit. For workers in UK, Germany (tot 7 ) this data in unknown

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

	Percent of women (%)	Unknown
Senior leadership level position	60
Non-executive board	50

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

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

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

As already mentioned, Treedom drafted a corporate labour rights code which shows the commitments of Treedom toward the defence of their rights in the job place. Treedom CEO discusses monthly with each employee regarding their work conditions and satisfaction, collecting any valuable comments to improve the work environment. Furthermore, Treedomʼs staff holds weekly meetings to discuss its activities and verifies the state of its initiatives and new ideas are proposed during the sessions. Internally, the health and safety of all employees are ensured by the Italian and branch countries' law requirements. In our global projects, Treedom operates through NGOs that involve local communities respecting human and labour rights and giving them an adequate income. According to Italian law, before starting their activities, each employee must follow a training organised by external agencies recognised by public authorities and national labour unions on safety in the workplace and labour law and rights. In the next two years, we plan to formalise internal procedures to ensure that all the employees are always aware of their rights and condition. Moreover, we expect to organise a detailed corporate policy on labour rights for the company and its suppliers. We plan to organise regular due diligence on our suppliers on this topic by third parties.

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
2016
Water
2020
Oceans
Forests / Biodiversity / Land Use
2016
Air Pollution
2016
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2020
Energy & Resource Use
2020

Optional comment

We are revising all these policies

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

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

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
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

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	At the moment we are completing the life cycle assessment of the company to set scientific reduction goal for our emissions. We are also promoting tree planting in the agroforestry system in 12 countries realizing more than 40 projects in rural communities.
Energy & Resource Use
Water
Forests / Biodiversity / Land Use	In 2022 the company would like to reach 2,2 million trees planted in Camerun, Colombia, Repubblica Dominicana, Ecuador, Ghana, Guatemala, Haití, Honduras, Italia, Kenya, Madagascar, Malawi, Nepal, Tanzania, Thailand, and Uganda. We want to promote agroforestry projects with high environmental and social impact mainly.
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Oceans

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

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

Optional comment

Through the planting of trees, we have compensated for our emissions.

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

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 (%)

3.6

Unknown

Not applicable (Please provide additional information)

Optional comment

Is a prevision, we will have a precise data when we close the financial audit on the 30 of June 2022

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

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Unknown

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

Unknown

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

Technology

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

Percent of total revenue (%)

100

Treedom is the first platform globally that allows consumers and corporations to plant trees and see their impact online, supporting farmers and NGOs worldwide. Since its foundation in 2010, Treedom has introduced innovation and transparency in a traditionally charitable sector, transforming the long-standing idea of planting trees to guarantee longevity to the planet into a modern tool of communication and engagement. So far, Treedom has planted more than 3,2 million trees involving 1 million users, 9 thousand companies and supporting more than 190.000 beneficiaries in rural communities.

Unknown

Not applicable (Please provide additional information)

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
Groundwater:
Surface water:
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
Groundwater:
Surface water:
Rainwater:
Wastewater:
Percentage of water consumed in regions with high or extremely high water stress (%)

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

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/$):

Unknown

Not applicable (Please provide additional information)

In our business model, we finance the planting of trees that are sustainable for the local environment considering also the stress caused to the water resources of any kind. Because the trees are planted by independent small and micro farmer producers we do not have the exact metrics of their water consumption.

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
SOx
Volatile Organic Compounds (VOC)
Hazardous air pollutants (HAP)
Particulate matter (PM10)
Persistent organic pollutants (POP)
Other (please specify in text box)

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

Sector-specific: Waste

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

Waste Generated (t)

Unknown

Not applicable (Please provide additional information)

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

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 (%)

Unknown

Not applicable (Please provide additional information)

Optional comment

We do not use any materials that produce hazardous waste

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

Single-use plastics (tonnes)

Unknown

Not applicable (Please provide additional information)

Optional comment

Lyfe Cycle assessment ongoing to be released before the end of 2022

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.

To reduce the environmental impact of our activities, we take the following measures: we only buy recycled paper, we recycle 100% of the waste we produce, we use energy-saving lights, and we pay great attention to the food products consumed in the office: we prefer to buy zero-kilometre or fair-trade products. In addition, being an environmental consulting company that offers the possibility of offsetting emissions, we set a "good example", and every year, we cancel our carbon footprint. In 2021 we started a complete and thorough analysis of our LCA. Based on this, we will set scientific targets for decreasing emissions and pollutants.

Anti-corruption

Commitment

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

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?

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

Prevention

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

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?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Response and Reporting

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

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
no incidents
Confirmed during the current year, and related to this year	0
no incidents

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

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

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

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

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.

Transparency is one of the core Treedom’s values. Treedom repudiates any form of corruption and consequently, it is committed to the Italian and European Union anti-corruption laws. The organization does not engage with business partners and clients with a track record of corruption. To avoid a conflict of interest, the appearance of a conflict of interest, or the need for our employees to examine the ethics of acceptance, our company, and its employees do not accept gifts from vendors, suppliers, customers, potential employees, potential vendors or suppliers, or any other individual or organization, under any circumstances. Finally, the organization only accepts assignments that are within the range of our expertise and experience and are compatible with our vision and mission. There have been no cases of corruption over the course of the Treedomʼs existence. According to Italian law, we provide national authorities with our financial documentation and we respect the National and International procedures and law for the obtainment of grants and public funds. Over the next two years, we expect to organise a detailed corporate policy on corruption issues for the company and its suppliers, so we plan to organise regular due diligence procedures by third parties.