Report - COP Prototype

2022 Communication on Progress

Clarasys Limited

Published date

June 29, 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

Human Rights & Labour Rights / Decent Work commitment (https://www.clarasys.com/en-us/modern-slavery-act-statement/), Environment commitment (https://www.clarasys.com/the-clarasys-sustainability-roadmap/)

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

Optional comment

Clarasys has a dedicated internal sustainability team that have direct influence over a number of environmental issues, such as carbon emissions, sustainable procurement and waste management. Clarasys's Chief Executive Officer, Matt Cheung, sits on the company's sustainability advisory board. We also have a dedicated People Team, who oversee labour rights / decent work issues. The head of the People Team is a member of the company's leadership advisory board.

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

Clarasys operates policies across these sustainability topics which are communicated internally for people to evaluate and raise any risks against them. We also have an external sustainability advisory board who, as part of their function, provide advice on how to address any potential strategic environmental 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

Optional comment

Clarasys operates a sustainable procurement framework which forms part of our due diligence process in relation to the above sustainability topics.

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 (#)	6
Male (%)	83.34
Female (%)	16.66
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	50
Above 50 years old (%)	50
From minority or vulnerable groups (%)	16.66
Executive (%)	83.34
Independent (%)	16.66

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)

TBC

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
2021
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
No adverse impacts were identified during the reporting period.
Rights of refugees and migrants
Digital security / privacy
No adverse impacts were identified during the reporting period.
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.

Clarasys have a modern slavery statement which affirms our commitment to acting ethically and with integrity with a zero-tolerance policy to any form of modern slavery and child labour. It sets out the steps Clarasys has taken in relation to our responsibilities under Section 54, Part 6 of the UK Modern Slavery Act 2015 (“MSA”) to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chains. Clarasys is a management consultancy headquartered in London, UK, with an office in Boston, USA. We provide professional services to a range of private and public sector organisations, as well as not-for-profit organisations. We believe the nature of what we do at Clarasys means the risk of human trafficking or slavery occurring in our business or our supply chains is low, with the majority of products and services sourced from suppliers based in the UK. However, we have a zero-tolerance approach to modern slavery. We are fully committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains. We have developed a number of policies in this topic area to ensure we are embedding our commitments, including: ~ Discrimination and harassment policy: We have zero-tolerance of any threat of physical or sexual violence, discrimination, harassment or intimidation against employees. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally and are paid at least the national living wage including those contracted through facilities partners. ~ Recruitment policy: Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK or the US (as applicable) so as to safeguard employees from any abuse or coercion. ~ Speak up policy: We organise our company around a set of structures and principles that ensure employees are able to voice their concerns about how colleagues are being treated, or suspicious practices within our business or supply chain, without fear of reprisal. This is done by ensuring there are multiple channels of communication for our people – everyone has a coach they speak to weekly, an HR People Partner who engages with them on a regular basis, feedback surveys where people can raise concerns and we regularly discuss the theme of ‘Behaviour that is counter to our values’ in coaching and business-wide forums. We pride ourselves on having a culture that prioritises trust and safety through all our processes and decisions, and if anything of concern is raised it is fully investigated and appropriate resolutions are actioned. ~ Code of conduct: We have a long-standing commitment to conducting business in a responsible way and in accordance with our code of conduct which endeavours to avoid causing any adverse impact on the human rights of our both employees and our wider stakeholder network. ~ Anti-bribery and corruption policy: Our anti-bribery and corruption policy outlines the responsibilities of Clarasys and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption. We intend to take the following steps in 2022 to mitigate risk of slavery and human trafficking: 1) Improving our purchasing policy which will include a procurement framework and code of ethics. This will ensure that Clarasys is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and yet fulfils legal and financial obligations and effectively manages commercial risk. 2) We are passionate about doing business responsibly and acting ethically in our business conduct. We will work closely with our partners and suppliers to ensure they share our commitment to human rights and the prevention of Modern Slavery and Child Labour within their businesses and supply chains. 3) We will not work with clients, partners and suppliers who are deemed to be in violation of the Modern Slavery Act or Child Labour laws.

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
2022
Working conditions (wages, working hours)
2021

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
Developed and communicated policy
Child labour
Developed and communicated policy
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 (%)

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 (%)	0

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

	Percent of women (%)	Unknown
Senior leadership level position	47
Non-executive board	25

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 (%)	48

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.

Clarasys has provided a number of measures to support labour rights principles over the last year, such as: - Expenses to cover equipment and technology to facilitate homeworking - Flexible working policy enabling employees to flex their working hours to achieve a better work-life balance - Annual salary reviews - Mental health support including the provision of a wellbeing hub, mental health first aiders and an in-house, full-time performance psychologist - Flexible holiday policy giving employees unlimited holidays

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

Optional comment

In the next year we plan to develop a Carbon Management Plan, which will include a science-based target for achieving net-zero carbon. This will include targets and actions to reduce our emissions from energy consumption, water use and waste generation.

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
As a SME professional services firm, our impacts on water score relatively low in terms of materiality as our core impact is water consumption by our employees. Beyond engaging them to change behaviours and reduce consumption, currently there are no other affected stakeholders that it would add value to engage with.
Oceans
As an SME professional services firm, our impacts on oceans are not material enough (beyond our GHG emissions) to warrant engaging any affected stakeholders.
Forests / Biodiversity / Land Use
As an SME professional services firm, our impacts on forests / biodiversity / land use are not material enough (beyond our GHG emissions) to warrant engaging any affected stakeholders.
Air Pollution
As an SME professional services firm, our impacts on air pollution are not material enough (beyond our building energy use and business travel) to warrant engaging any affected stakeholders. This is likely to become more material as we grow in size, and move to and/or occupy new office space.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

For Climate Action, Waste, and Energy & Resource Use, we have engaged with our employees (affected stakeholders) to identify and discuss risks and develop approaches to mitigating them.

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

Optional comment

Currently defining our approach to setting annual targets/goals for each of the issues noted above, so that we can track progress over time.

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

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Climate Action

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

Scope 1 Emissions

Full

None

Emissions (tCO2e)

42.251

Scope 2 Emissions

Full

None

Emissions (tCO2e)

31.13

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

138.944

Optional comment

Clarasys has calculated its carbon footprint covering the period January 2021 - December 2021 using CompareYourFootprint's online software, which uses the latest carbon factors from the Department for Business, Energy & Industrial Strategy (BEIS) and the equivalent factors for our US activities. It also adheres to the GHG Protocol Corporate Standards. We have used an operational control approach for our organisational boundary, and have included Scope 1, 2 and 3 emissions in our calculation. Our Scope 1 emissions comprise wholly of our natural gas usage for our UK office in London. Although our London office is leased, we have categorised this under Scope 1 (instead of Scope 3, Upstream Leased Assets) as we believe this the most appropriate categorisation to give us more responsibility for action. Our Boston office is all-electric and therefore does not have any Scope 1 emissions. Our Scope 2 emissions includes the purchased electricity across our leased office spaces (London and Boston). For our Scope 3 emissions, we have reported against the following categories that have been determined to be material to our operations in reference to the GHG Protocol's Scope 3 Screening Criteria: - Category 1: Purchased goods and services (water use, food and drink, electrical equipment, cloud storage services) - Category 3: Fuel- and energy-related activities (from our gas and electricity usage) - Category 5: Waste generated in operations (waste from our office premises) - Category 6: Business travel (air, rail and road, plus emissions from our hotel stays) - Category 7: Employee commuting (including emissions from home working)

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)

Clarasys is a SME professional services firm and therefore having investments in low carbon technologies is not material to our core capabilities and corporate purpose.

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

Optional comment

Clarasys does not own any physical assets and our supply chains are typically UK-based and do not involve material levels of natural resource use, therefore there is little scope for us to increase resilience to climate change in these areas (although this may change over time). However, there is scope for Clarasys to improve resilience for others via our client work and wider initiatives and projects. This is something that we will aspire to address in future CoPs.

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

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 (%)
Both Clarasys office locations (London, UK, and Boston, MA, USA) are not in regions with high water stress, as per the WRI Water Risk Atlas Tool.

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 (%)
Both Clarasys office locations (London, UK, and Boston, MA, USA) are not in regions with high water stress, as per the WRI Water Risk Atlas Tool.

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)

Both Clarasys office locations (London, UK, and Boston, MA, USA) are not in regions with high water stress, as per the WRI Water Risk Atlas Tool.

Sector-specific: Waste

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

Waste Generated (t)

7.3585

Unknown

Not applicable (Please provide additional information)

Optional comment

Clarasys does not currently have comprehensive waste stream monitoring processes in place at its London or Boston office premises to generate robust waste generation values for its operations. This is because we lease these office spaces, which restricts our choice of waste management suppliers at these facilities. We are in the process of negotiating changes to in order to enable better monitoring in the future. As an interim approach to obtaining the above waste generation total, we commissioned the cleaning contractor at our London office to monitor general, recycling and food waste streams for a one-week period. We extrapolated the data from this period across the 2021 reporting period to give us a total figure for the year at our London office. We then calculated an average waste per employee figure to allow for us to calculate an equivalent waste total for our Boston office. The total value provided above is a combination of both of these totals.

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)

Clarasys does not generate any hazardous materials are part of its operations.

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.

Over the last year our people have been driving Clarasys activity to be more sustainable. We are exploring and embedding a number of measures to ensure that we are on pathway to becoming a net-zero carbon, circular organisation that does all that we can to maximise our social impact and deliver on our purpose to be a company that “makes a lasting difference to the way people work, live and grow”. During this reporting period, we have undertaken the following practical actions to implement environmental principles in our operations: ~ Calculated our carbon footprint for 2021 ~ Established partnerships within the industry to build capability in addressing key sustainability challenges such as net zero carbon, sustainable transport and circularity ~ Created a sustainable procurement framework to reduce the negative impacts of our purchasing decisions ~ Worked with numerous clients across private and public sectors to support them in shaping and delivering their own sustainability aspirations ~ Delivered sustainability training to all our staff members to strengthen their ability to have meaningful conversations and identify solutions for tackling key issues ~ Enrolled four of our people in the Young SDG Innovators Programme (YSIP) to grow on our internal capabilities and collaborate to catalyse action towards the goals Over the next year, we will also aspire to achieve the following: ~ B-Corp accreditation and reached their maximum score of 200/200 ~ Set a science-based net-zero target and maintain our carbon neutral status by offsetting our emissions using the most credible offsets available ~ Develop and implement a social value impact plan to plan, deliver, measure and maximise our impact ~ Implement measures to become a circular organisation reducing the resources we use and our waste as much as possible ~ Create and implement a travel policy to reduce the emissions from our business travel and employee commuting

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

2022

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

no formal 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
N/A
Confirmed during the current year, and related to this year	0
N/A

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.

We have developed and implemented an Anti-Bribery and Corruption policy which sets out the responsibilities of Clarasys and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption. It also exists to act as a source of information and guidance for those working for Clarasys. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.