Report - COP Prototype

2022 Communication on Progress

Obelisk International Group Holdings Ltd

Published date

May 30, 2022

No. of questions

Supplemental files

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

Optional comment

A Sustainability Statement is in draft form.

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

The following policies are in place: Modern Slavery, Dignity in the Workplace, Equal Opportunity, Anti-Bribery and Corruption. While we have an environmental policy it is not currently focused on employee conduct more on the principles of the company.

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

Human Rights & Labour Rights - Human Resources Director; Environment - SHEQ Director, Anti-Corruption - CEO.

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

Optional comment

The "P-G-018 Risk assessment and Hazard Identification" procedure describes the process to identify EHS risks at each work location, assess each and develop appropriate controls to eliminate or reduce the risk to personnel and to the environment.

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

Optional comment

Obelisk's whistle-blowing policy outlines the procedure through which members of the company's workforce can formally raise concerns about the company's conduct.

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

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

Optional comment

Obelisk's whistle-blowing policy is written in English as the working language of our business in the UK and Ireland. It applies to all employees including contractors; suppliers / clients are not explicitly mentioned.

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 (#)	8
Male (%)	100
Female (%)	0
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	62.5
Above 50 years old (%)	37.5
From minority or vulnerable groups (%)	0
Executive (%)	87.5
Independent (%)	0

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

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

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
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
POL-029 R3 Obelisk Data Protection Policy last updated in 2021, POL-031 R2 OIGHL Privacy Statement last updated in 2019
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

Optional comment

Obelisk has a separate policy for third-parties

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

Optional comment

Number of internal training sessions held on User Security Awareness

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
DarkTrace was implemented since 2017 and provides monitoring and action on user accounts and devices, and data loss prevention. Our "IT Security Incident Response Procedure" provides an organised and consolidated approach to managing prompt response and recovery actions, and incidents are logged in a register. Review activities are more sophisticated than "ad-hoc" but are not part of KPIs at this time.
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.

In 2021 the following actions were taken: - hybrid working policy was introduced amending working conditions of employees enabling them to split their working week between home and office; - right to disconnect policy was introduced which encourages our employees to set boundaries to their working days; - we partnered with Seechange a charity that aims to end stigma around mental health and a number of workshops were held which provided employees with a range of strategies to manage their own mental health; - Obelisk’s first Mental Health First Aid policy was put in place and 28 employees were trained as Mental Health First Aiders; - User Security Awareness Training was made mandatory, with all staff completing a refresher course by the end of 2021 to ensure continued vigilance on digital security and privacy risks; - Employee Consultation Committee meetings continued in 2021 with three meetings taking place in February, July and October; - we became an accredited disability confident committed employer in the UK.

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
Employee Consultation Committee 2017/ CWU Obelisk Framework Agreement 2013 (Collective bargaining for TUPE'd employees)
Forced labour
Modern Slavery Policy 2018
Child labour
Young Workers Policy Ireland 2018 / Young Workers Policy UK 2020
Non-discrimination in respect of employment and occupation
Equal Opportunity Policy 2018
Occupational safety and health
Obelisk Safety Policy 2020 - 2021
Working conditions (wages, working hours)
This is dealt with in employment contracts

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)

Optional comment

Working conditions - Hybrid working / Flexible working policy Wages - Certified Living Wage Employer UK / Benchmarked and updated salary scales in place

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

Hosted regular H&S "toolbox" talks and conducted safety audits

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

The last two points are covered in Obelisk's Induction programme

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

Employee Consultation Committee (ECC) items tracked and progress reviewed on monthly basis. Union - issues discussed and progress reviewed at each meeting

Performance

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

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	15

Optional comment

TUPE'd employees only

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 (%)	17

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

	Percent of women (%)	Unknown
Senior leadership level position	37.5
Non-executive board	0

Optional comment

3 women out of 8 on the Executive team

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)

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

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury	0

Optional comment

None reported

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

	Incident rate	Unknown	Choose to not disclose
Incident rate	0

Optional comment

3 minor incidents reported in 2021 but no work days lost as a result.

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.

In 2021, working conditions were amended with the introduction of a hybrid working policy which effectively is a form of flexible working that permits employees to split their working week between home and office. As part of Obelisk’s participation in the UNGC SDG Ambition Accelerator programme, the company is in the process of finalising an initiative to achieve gender balance at all levels of management within the company. This initiative will include gender pay gap reporting, recruitment processes and retention initiatives

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
Water
Oceans
Not identified as a material issue for the company
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
P-G-012 R5 Waste Management Procedure.pdf last reviewed in 2021
Energy & Resource Use

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
Not identified as a material issue for the company
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

The company has engaged with employees on climate action, waste and energy resources use as part of a process to develop the strategy and agree actions to benchmark our impacts.

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
Not identified as a material issue for the company
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

In 2021 baselining and data gathering had begun on emissions, waste and energy use but was not complete. No targets were set in 2021 but it is our intention to set and track annual targets.

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
Not identified as a material issue for the company
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

No incidents reported in the reporting period.

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

Scope 3 emissions have not yet been measured

Emissions (tCO2e)

Optional comment

2021 Scope 1 emissions = 1162 tCO2e; 2021 Scope 2 emissions = 26.4 tCO2e (location-based)

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 (%)

Unknown

Not applicable (Please provide additional information)

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)

At the time of writing, the organisation is in the process of benchmarking and setting targets for emissions reduction

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

1.1

Unknown

Technology

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

Percent of total revenue (%)

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 (%)

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)

Sector-specific: Forest, biodiversity, and land use

14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

	Number	Unknown	Not applicable (Please provide additional information)
Sites
Hectares

15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

Conversion of natural resources (hectares)

Unknown

Not applicable (Please provide additional information)

16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

	No	No, but we plan to in the next 2 years	Yes
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Other (please specify in text box)

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

Scope 1 & scope 2 emissions have been calculated using the GHGP Emissions Calculation Tool (currently in beta). NOx emissions from scope 1&2 are estimated to be 0.003 tN20. Where custom emissions factors are used, NOx components are not readily available and so this is not a complete number, but not believed to be materially different. Other pollutants are not readily derived from the tool. Scope 3 emissions have not been calculated.

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)

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)

There was no hazardous waste in the reporting period

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)

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.

Actions taken include: - improved separation of waste streams; - investment in baler to both bale cardboard and plastic waste reducing costs of skips in the yard and improving recyclability of certain waste streams; - replacement of fluorescent lighting with LED lighting in offices for energy efficiency; - calculation of scope 1 and 2 emissions was started in the reporting period. Planned actions: - as part of our engagement with the SDG Ambition Accelerator programme, it is the company's intention to make science-based emissions reductions in line with a 1.5 degree pathway.

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
Optional comment
The Ethical Business Behaviour Policy deals with Gifts and Hospitality but not the other categories
Prevention
3. Who receives training on anti-corruption and integrity?
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Optional comment
A policy is in place an updated regularly (Ethical Business Policy last updated 02/09/2021, Anti-Bribery and Corruption Policy last updated 02/09/2021)
4. Does the company monitor its anti-corruption compliance programme?
No, we do not monitor the anti-corruption compliance programme
We do not have an anti-corruption compliance programme, only a policy (see q1 above)
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
Confirmed during the current year, and related to this year
Optional comment
No incidents were raised in the reporting period however there is no anti-corruption programme in place to actively
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
Optional comment
No incidents were raised 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)
Optional comment
No incidents were raised in the reporting period.
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.
It is the company's intention to set up an anti-corruption programme within the next 2 years in line with the guidance provided: "Anti-corruption programmes can include (1) detailed procedures on how to handle bribes, gifts, entertainment and expenses, donations and sponsorships, political contributions, facilitation payments and conflicts of interest; (2) appointing a manager to devise, implement, monitor and improve the programme under the oversight of senior leadership; (3) communicating anti-corruption commitments to business partners’ (4) providing communication and training to ensure employees understand; (5) ensuring that appropriate measures are taken in the event the anti-corruption programme is violated; and (6) monitoring and continuous improvement to carry out regular reviews of the anticorruption programme, including internal audits, provide resulting reports to senior management and the Board and take necessary actions to improve the programme"

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years
Confirmed during the current year, and related to this year