2022 Communication on Progress

Akcansa Cimento Sanayi vs Ticaret A.S.

Published date

June 25, 2022

No. of questions

64

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    Via Annual Reports and Sustainability Reports, Board of Directors and Top Management issue annual statements regarding sustainability related topics covering sustainable development initiatives of the company, impacts on society and environment, anti corruption and compliance topics, targets and performance, risks and opportunities. Beyond, at Akçansa, Board of Directors, which is the highest level management body has the ownership of the sustainability strategy, related policies, sustainability targets and performance, and risks and opportunities related to sustainability. The Board of Directors defines and approves the sustainability vision and strategy, policies, risks and opportunities of the company in line with the sustainability priorities of the company, which are reviewed periodically. All activities related to sustainability are overseen by the Board of Directors and, when necessary, by the Corporate Governance Committee with the authorization of the Board of Directors. The Board of Directors, which is at the top of the Sustainability Organization, is informed about sustainability developments at regular intervals from the bottom up through committees (Sustainability Committee, Sustainability Steering Committee) and working groups as well as the CEO. Critical sustainability issues, progress in sustainability targets and determined actions are presented to the Board of Directors at least twice a year, by the Company's General Manager (CEO), who is also the Chair of the Sustainability Steering Committee. The Corporate Governance Committee is authorized by Board and oversees critical ESG issues, monitors progress and provides guidance. The Sustainability Steering Committee under the chairmanship of the Company's General Manager and with the participation of the members of the Board, develops policies related to sustainability and submits them to the approval of the Board of Directors, examines and approves sustainability plans, targets, projects and investments, and evaluates risks and opportunities related to sustainability. Sustainability Steering Committee consisting of the members of Akçansa Executive Committee is responsible for reviewing critical ESG targets, roadmaps and ESG performance.

    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
    Under our "Code of Business Ethics" we describe our approach of human rights, labor rights, decent work and other topics. The policies cover employees, suppliers, society and all other stakeholders. Our "Code of Business Ethics" is publicly published within our website. http://www.akcansa.com.tr/en/sustainability/our-code-of-business-ethics/ Akçansa "Supplier Codes of Business Conduct" also covers labor rights, human rights, anti corruption issues and environmental related issues for our suppliers. This policy is also publicly published via our web site. http://www.akcansa.com.tr/en/sustainability/supplier-codes-of-business-conduct Akçansa has a stand alone Environment and Energy Policy which is published publicly via website. With the framework of Environment and Energy Policy Akçansa commits to provide continuous awareness raising activities on environmental and energy issues. Akçansa also has a stand alone policy on Anti-Bribery and Anti-Corruption covering all operations.

    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
    Akçansa adopts the Sabancı Code of Business Ethics (SA-ETIK) of Sabancı Group, one of the main shareholders of the company. Corporate principles, ethical values, and standards are defined within the framework of this document throughout the company. SA-ETIK serves as a guideline for company employees to fulfill their responsibilities within the scope of legal regulations, internal norms and contracts and completely for the benefit of the corporation, by avoiding behaviors that might harm the corporation. SA-ETIK principles are also supported through internal policies. The Code of Business Ethics is binding for all operations of the company, members of the Board of Directors, managers, and employees. Besides, all suppliers, subcontractors, dealers and business partners are also expected to comply with these principles. The constitution and sustenance of a corporate culture and working environment promoting ethical principles is the responsibility of managers. https://www.sabanci.com/en/management-approach/sabanci-group-code-of-business-ethics

    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
    Sabancı Group managers have additional responsibilities beyond the responsibilities defined for employees within the framework of SA-ETHICS. Accordingly, managers; Establishing and maintaining a corporate culture and working environment that supports ethical rules, being an example for the implementation of ethical rules, educating employees on ethical rules, supporting their employees in submitting their questions, complaints and notifications about ethical rules, guiding them on what to do when they are consulted, It is responsible for considering the notifications and forwarding them to the Ethics Committee as soon as possible when deemed necessary, ensuring that the business processes under their responsibility are structured in a way that minimizes the risks related to ethical issues, and applying the necessary methods and approaches to ensure compliance with ethical rules. Ethics Compliance Officers are responsible for; providing guidance and consulting to employees regarding questions and issues related to ethics within the company, directing those ethical violations which cannot be resolved within the company and need further investigation to the Ethics Board, participating and contributing to the resolution of ethical violations within the company that are directed to him/her through the Ethics Board, reporting the questions and notifications regarding ethical issues, including their resolutions to the Ethics Board regularly or when requested, acting as the point of contact within the company for the investigations conducted by the Ethics Board and supporting the investigations where necessary, monitoring the effectiveness of the SA-ETHICS program within the company and providing support in its practice.

    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
    Ethics Compliance Officers are responsible for; providing guidance and consulting to employees regarding questions and issues related to ethics within the company, directing those ethical violations which cannot be resolved within the company and need further investigation to the Ethics Board, participating and contributing to the resolution of ethical violations within the company that are directed to him/her through the Ethics Board, reporting the questions and notifications regarding ethical issues, including their resolutions to the Ethics Board regularly or when requested, acting as the point of contact within the company for the investigations conducted by the Ethics Board and supporting the investigations where necessary, monitoring the effectiveness of the SA-ETHICS program within the company and providing support in its practice. The Ethics Board has the responsibility to investigate and resolve conflict of interest, complaints and notifications concerning violation of the Code of Ethics and to advise Group companies about guidelines to be followed for the resolution of non-compliance with the Code of Ethics. The Ethics Board reports directly to the Chairperson of the Holding Company and is composed of the following position holders: Chairman: H. Ö. Sabancı Holding A.Ş. – Head of Audit, Members: H. Ö. Sabancı Holding A.Ş. – Head of Legal, Risk and Compliance; H. Ö. Sabancı Holding A.Ş. - Human Resources and Sustainability Group President

    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
    Dissemination of risk assessments related to human rights throughout the supply chain is planned. Within the scope of labor rights, documents related to control points are requested within company and from suppliers and subcontractors. As part of the overall risk management approach, environmental, social and governance risks are regularly evaluated and reviewed by Risk Manager and Sustainability Manager. For Anti Corruption, the risks of customers and suppliers are analyzed by requesting relevant information and documents and by desktop reviews.

    6.1. During the assessment of risk, which business relationships are reviewed?

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

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

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

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    All suppliers are assessed against labor rights and corruption risks before approval as a supplier. If any risk regarding labor or corruption is identified, suppliers are asked to mitigate the risk with preventive actions.

    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?

    Optional comment
    Employees report the ethical and legal violations primarily to their managers, if the violations are related to their managers, to Ethics Compliance Officer, company ethic hotline and/or to the Company’s CEO/General Manager. If no action or result is taken, then the violation should be reported to the Ethics Board. Violations concerning the top management of the Company should directly be reported to the Ethics Board. Notifications made to the Company are resolved in line with the company internal procedures. The Company informs and consult the Ethics Board for important cases and other matters if consider necessary. The Ethics Board may do the investigation itself if deem necessary. Those who violate the Code of Business Ethics and/or company policies and procedures shall be subject to disciplinary action up to and including termination of employment.

    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
    Akçansa has an internal procedure of "Compliance Incident Reporting and Case Management". There is no other local language used within the company thus the procedure was published in Turkish and English. The hotlines described within the procedure are also publicly shared and any related body can apply. The process is fully confidential and respects the privacy rights of applicants. Retaliation is also covered under the procedure. Concerns about all stakeholders can be raised inline with the procedure.

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    According to the Remuneration Policy for Members of the Board of Directors and Senior Executives, senior executive remuneration consists of two components: fixed and performance-based. Performance indicators are determined in line with the main company targets, including non-financial long-term sustainability indicators as well as financial indicators. In 2020, the company shared its 2030 targets transparently with the public through its sustainability report. 2030 targets includes targets related to Environmental, Social and Governance issues. Wage Policy for the Members of the Board of Directors and Top Managers can be reached via http://www.akcansa.com.tr/docs/Wage_Policy_For.pdf 2020 Sustainability Report can be reached via http://www.akcansa.com.tr/downloads/surdurebilirlik/2020_Sustainability_Report.pdf 2021 Sustainability Report can also be reached by website after publishing.

    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

    Female (%)

    17

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    33

    Above 50 years old (%)

    66

    From minority or vulnerable groups (%)

    0

    Executive (%)

    66

    Independent (%)

    33
    Optional comment
    http://www.akcansa.com.tr/en/management-team/

    13. Do you produce sustainability reporting according to:

    Optional comment
    Akçansa 2021 Sustainability Report can be reached via the following link: http://www.akcansa.com.tr/docs/Ak%C3%A7ansa%202021%20Sustainability%20Report.pdf

    Data Assurance

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

    Number of Accidents Number of Fatal Accidents Number of Occupational Diseases Injury-related Absenteeism Total Working Hours Lost Workday Rate (LWR) OHS Trainings Total Number of Employees Distribution of Female Employees Distribution of Female Managers Distribution of Female Managers in Revenue-Generating Roles Distribution of Female Employees in STEM Roles Total Number of Employees on Maternity Leave Total Number of Employees on Paternity Leave Distribution of the Employees Returning to Work After Maternity Leave Total Hours of Trainings by Gender Total Hours of Trainings by Age Total Hours of Trainings by Managerial Level Total Hours of Trainings by Training Categories Total Cost of Trainings Training Costs per Employee Number of Employees Hired by Gender Number of Employees Hired by Age Number of Employees Hired by Managerial Level Number of Employees Left by Gender Number of Employees Left by Age Number of Employees Left by Managerial Level Turnover Rates by Gender Turnover Rates by Age Turnover Rates by Managerial Level Employee Satisfaction Survey Results by Gender Employee Satisfaction Survey Results by Age Employee Satisfaction Survey Results by Managerial Level Results of human rights assessment studies Natural Gas Consumption Diesel Consumption Coal Fuel-Oil Gasoline Consumption LPG LNG CNG Petroleum Coke Alternative Fuels Electricity Consumption Purchased Heat/Steam/Cooling Gas Sold Heat/Steam/Cooling Gas/ Electricty Greenhouse Gas Intensity Energy Intensity Renewable Energy Generation Renewable Energy Consumption Purchased Renewable Energy Total Annual Kilometers of Air Travel Made for the purpose of Business Total Annual Kilometers of Personnel Services Direct (Scope 1) Greenhouse Gas Emissions Energy-related Indirect (Scope 2) Greenhouse Gas Emissions Other Indirect (Scope 3) Greenhouse Gas Emissions Mains water Surface water Groundwater Rain Water Total Waste Water Reused / recycled waste rate Total Hazardous Waste Total Non-Hazardous Waste Amount of recycled waste Total plastic consumption Number of Sustainable Products and Services Sum of Sustainable Product and Service Revenues Ratio of Sustainable Product and Service Revenues to Total Revenue (%) R&D and Innovation Investments Ratio of R&D and Innovation Investment Budget to Total Revenue (%) Sustainability Oriented R&D and Innovation Investments Ratio of Sustainability-Oriented R&D and Innovation Investment Budget to Total R&D and Innovation Investment Environmental Investments/ Financial Savings and Environmental/Social Benefit Through Operations Environmental Investments Environmental Expenditures Sustainable Investments/ Financial Savings and Environmental/Social Benefit Through Operations Assurance report is available following link: http://www.akcansa.com.tr/downloads/surdurebilirlik/2020_Sustainability_Report.pdf

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    Human rights and fair working conditions, freedom of assocication and the effective recognition of the right to collective bargaining, occupational health and safety, child and forced labor, and non-discrimination issues are major material topics of Akçansa included in the materiality analysis and codes of business conduct.

    Response

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

    Operations were assessed by audit team in terms of ethics and corruption risks under annual audit plans. No incidents detected during the reporting period. Ethics trainings were provided to all employees. Anticorruption and compliance basics training assigned related employees regarding to prevent their potential actions and increase their awareness. During the reporting period Anti-Bribery and Anti-Corruption trainings were provided to 7 women employees and 35 men employees.

  • 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

    Framework of the Collective Bargaining Agreement signed between the Turkish Cement, Ceramics, Pottery and Glass Industry Workers' Union (Çimseİş) and the Cement Industry Employers' Association (ÇEİS) covering the period from January 1, 2022 to December 31, 2023 after the previous period of January 1, 2020 to December 31, 2021 ended.

    Forced labour

    2022 - Code of conduct covers human rights aspects. Supplier code of conduct also covers labour conditions including human rights, forced and child labor etc.

    Child labour

    2022 - Code of conduct covers human rights aspects. Supplier code of conduct also covers labour conditions including human rights, forced and child labor ets.

    Non-discrimination in respect of employment and occupation

    2022 - According to our Gender Equality Policy, Akçansa adopts a company culture that is impartial, fair, and safe, that does not tolerate any type of violence or harassment, and is nourished by diversity; mindful of raising awareness on gender equality. We provide a work environment in which characteristics such as religion, language, color, sect, gender, conditions and preferences are not in any way questioned nor discriminated against. Any discrimination among employees within the organization based on language, race, color, gender, political opinion, creed, religion, sect, age, physical challenge and similar causes are not tolerated according to Akçansa's codes of business conduct.

    Occupational safety and health

    2022

    Working conditions (wages, working hours)

    Optional comment
    Child labour, forced and compulsory labour are prevented in supply operations by means of business ethics principles, issues such as respecting the union rights of employees, complying with occupational health and safety principles, acting in compliance with norms, ILO Conventions and legal regulations regarding operations, preventing discrimination, bribery and corruption are ensured. http://www.akcansa.com.tr/en/sustainability/our-code-of-business-ethics/

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Code of Business Ethics: http://www.akcansa.com.tr/en/sustainability/our-code-of-business-ethics/ Supplier Codes of Business Conduct: http://www.akcansa.com.tr/en/sustainability/supplier-codes-of-business-conduct Health and Safety Policy: https://view.officeapps.live.com/op/view.aspx?src=http%3A%2F%2Fwww.akcansa.com.tr%2Fdocs%2Fpolicies-new.doc&wdOrigin=BROWSELINK Gender Equality Policy: http://www.akcansa.com.tr/downloads/surdurebilirlik/Akcansa_toplumsal_cinsiyet_esitligi_politikasi_brosur_tasarimi_Convert_Spreads.pdf

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    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)

    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 (%)

    53
    Optional comment
    53% is calculated including blue collars and white collars. For only blue collars percentage is 83%

    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 (%)

    83% of blue collar employees are covered under collective bargaining agreements.

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    17

    Non-executive board

    0

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

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    Optional comment
    Akçansa is planning to get wage gap audit from a third party auditor.

    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

    9
    Optional comment
    Total recordable injury frequency rate = (Fatalities+LTI+MTI)/ 1,000,000 working hours

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    6.7
    Optional comment
    Incident rate = Total number of incidents / Total working hours x 1,000,000 (Subcontractors are not included)

    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

    No adverse impact identified

    Forced labour

    No adverse impact identified

    Child labour

    No adverse impact identified

    Non-discrimination in respect of employment and occupation

    No adverse impact identified

    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.

    Akçansa acts with the priority of creating a positive organizational climate. Human resource processes are carried out under the guidance of agreements and decisions such as ILO Conventions, UN Universal Human Rights Declaration, besides the provisions of the Labour Law. Forced, compulsory labour and child labour are not tolerated in Akçansa operations. The same principle also applies to subcontractor employees. Providing a fair and participatory work environment for its employees, being recognized for its respectability and reliability by its employees and business partners are among the most important values of Akçansa. Akçansa adopts SA-ETIK principles as code of business ethics that is recognized by Sabanci Holding, one of its principal shareholders, in order to preserve these values and defines the basic rights and responsibilities of its employees in this framework. Religion, language, race, sect, gender, physical attributes and life choices are not questioned under any conditions and any practice that might be perceived as discrimination is prohibited. Offering the work environment and conditions that its employees deserve, promoting gender equality in work life, enhancing communication and synergy among employees by recognizing the value of diversity are among the fundamental priorities of Akçansa. Akçansa published its Gender Equality Policy, which it adopted as a compass on issues such as equality, diversity and inclusion in the workplace, prevention of discrimination and harassment. Akçansa adopts this policy throughout its entire value chain. In order to ensure that sustainability impacts, primarily the principle of respect for human rights, are kept under control across the supply chain, the working principles that product and service suppliers are required to follow have been determined and attention paid to work with suppliers adopting these principles. Akçansa has started to review the supplier evaluation criteria to ensure compliance with human rights throughout the supply chain, and has also started working on integrating sustainability and human rights criteria into supplier audits. Compliance with the norms determined in Akçansa Supplier Business Ethics Principles is the responsibility of all suppliers and also a part of subcontractor service contracts. Child labour, forced and compulsory labour are prevented in supply operations by means of business ethics principles. Issues such as respecting the union rights of employees, complying with occupational health and safety principles, acting in compliance with norms, ILO Conventions and legal regulations regarding operations, preventing discrimination, bribery and corruption are ensured by these principles.

  • Environment

    Commitment

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

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

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

    2021

    Energy & Resource Use

    2021
    Optional comment
    Environment and Energy Policy that Akçansa has adopted covers topics such as climate action, water, waste management, biodiversity, air pollution, efficient use of energy and other resources. This policy is shared with the public via the website and forms the backbone of environmental and energy management systems.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    The Environment and Energy Policy of Akçansa was prepared with expertise from inside the company (i.e. Environmental Management Unit, Operations, Sustainability Department etc.) according to universal best practices and standards. Additionally expertise from outside the company was also involved in the development process of the policy. The policy is approved by the top management of the company. Policy applies to company's all operations as well as the stakeholders such as customers, suppliers etc.

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Stakeholder analysis and assessments are ongoing in collaboration with an experienced and international consultant. After completion of the stakeholder analysis, action plans will be prepared and applied within a planned timeline.

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    Akçansa has the ISO 14001 Environmental Management System and ISO 50001 Energy Management System certifications at all of its all plants including cement plants. Beyond, Ambarlı Port, all offices and all ready-mix concrete plants have ISO 14001 Environmental Management System certifications. Also Zero Waste certification from Ministry of Environment, Urbanization and Climate Change was obtained for all cement plants and ports For ready-mix concrete plants, certification processes are ongoing. Additionally Büyükçekmece and Çanakkale Cement Plants, as well as Gebze and Kemerburgaz Ready Mix Plants has the gold level Responsible Sourcing Certification from Concrete Sustainability Council. Within the scope of all these certificates, periodic 3rd party inspections, validations and additionally governmental audits are conducted, and on-site audits are made at specific control points on issues such as climate change, waste management, water efficiency, efficient use of resources, and energy efficiency. Additionally air emissions and water discharged are continuously monitored by authorities. Quarries are periodically assessed by governmental bodies within the scope of Environmental Impact Assessment requirements and land-use criteria including biodiversity issues. Akçansa plans to re-use waste water as an alternative resource to mitigate water consumption and studies are approved by Ministry of Environment, Urbanisation and Climate Change and Municipalities. At Arpaş, a subsidiary of Akçansa, who is operating the Ambarlı Port bought a sea cleaning boat to support the Municipalities cleaning activities. Akçansa also conducts sea pollution prevention drills in collaboration with governmental bodies.

    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
    Akçansa set out a set of sustainability targets for 2030 and shared publicly. In the 2030 roadmap of Akçansa, the company aims to reduce its environmental footprint and apply circular economy applications. The environmental targets include CO2 emission reduction, water usage mitigation, air emission reduction, increasing biodiversity action plans and rehabilitation of quarry areas, minimizing the waste generation and using all waste as alternative resources, increasing alternative fuel and alternative raw material usage in cement and concrete products to mitigate climate change impacts, increasing energy efficiency and renewable energy usage. Akçansa plans to set out Science Based Targets within two years. For each target, yearly targets are also set out. The progress is followed up periodically and disclosed via several reports such as CDP, climate change and water security programs, Annual Reports, Sustainability Reports etc.

    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

    CO2 emissions (intensity target)

    Energy & Resource Use

    Use of alternative raw materials in cement and concrete production (percentage) Use of alternative fuels (percentage) Increase of renewable energy usage (percentage) Energy saving from efficiency projects (absolute) Use of recycled materials (percentage)

    Water

    Mitigation in water consumption (percentage)

    Forests / Biodiversity / Land Use

    Number of quarries with biodiversity action plans (number) Rehabilitated quarry areas (hectares)

    Air Pollution

    Air emissions (volume)

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

    Waste reduction (percentage) Energy recovery from own waste (percentage)

    Oceans

    Optional comment
    Akçansa set 2030 Sustainability targets in 2020 and announced publicly. The targets includes climate-related targets such as emission reductions, alternative fuel usage, lowering clinker usage etc. Beyond climate related targets other environmental targets such as water efficiency, waste minimization, air emission reduction, renewable energy usage, alternative raw material usage were also included in the targets set. For land-use and biodiversity, increasing rehabilitated areas and increasing the number of biodiversity action plans are among the targets set.

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

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Oceans

    Optional comment
    For each target, yearly targets are also set out. The progress is followed up periodically, shared at sustainability committee and Board meetings regularly and disclosed annually via several reports such as CDP climate change and water security programs, Annual Reports, Sustainability Reports etc.

    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
    Climate Action: Alternative Fuel Usage increased up to 19% during the reporting period to mitigate CO2 emissions from fossil fuels. Water: 80,000 cubic meters of rain water was collected via collection ponds and re-used in operations. Ocean: Against the algea problem of Marmara Sea region, a sea cleaning boat was purchased and used. Forests / Biodiversity / Land Use: 2,500 trees were planted for rehabilitation of the quarries. Air Pollution: All plants has SNCR reduction system (De-NOx) in place in process stacks for reducing the air emissions. Plants are using bag filters which are the best available way to mitigate dust emissions. Waste: With a circular economy point of view, approximately 500,000 tonnes of waste from other industries and activities were used as alternative resources (alternative raw materials, alternative fuels) to support waste recovery and reducing waste disposal. Energy & Resource Use: Renewable sources such as wind energy is used in production. Additionally a waste heat recovery system is used in Çanakkale Plant. Also within 2 years, there are plans for increasing renewable energy usage via investments as well as purchasing electricity from I-REC certified suppliers. In order for conservation of natural resources alternative&recycled raw materials used in production of both cement and concrete during the reporting period.

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    5764763

    Scope 2 Emissions

    Emissions (tCO2e)

    282151

    Scope 3 Emissions

    Emissions (tCO2e)

    567977.6
    Optional comment
    Scope 1 includes fossil fuel and process emissions of clinker & cement production. Scope 2 includes indirect emissions for cement and ready-mixed concrete business lines. Scope 3 includes the following categories: Category 1 - Purchased goods and services: 261,919 Category 3 - Fuel- and energy-related activities: 195,310 Category 4 - Upstream Transportation and distribution: 49,569 Category 5 - Business Travel: 1,066.3 Category 6 - Employee Commuting: 434.3 Category 9 - Downstream Transportation and distribution: 18,483 Category 10 - Processing of sold products: 41,196 Scope 3 Total (RMC Business Line is included): 567,977.6

    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 (%)

    0.04
    Optional comment
    Total R&D budget is 1,205,000 TL. All R&D budget is directly related sustainability.

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

    Optional comment
    By investing in projects related to alternative fuel and alternative raw material increase, improvement in specific heat consumption, decreasing clinker ratio in cement, development of low-CO2 and value added products as well as the reinforcement investments to increase physical effects caused by climate change, Akçansa aims to decrease its dependency on fossil fuels, to increase its resilience and to contribute to the fight against climate change.

    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

    1.18
    Optional comment
    Akçansa generates renewable electricity via Waste Heat Recovery system and it's own wind-turbine. Total electricity generated from renewable sources corresponds to 14% of its total electricity consumption. The rate of renewable energy among all energy consumption, including the energy produced and consumed by Akçansa with fossil-based and non-fossil alternative fuels and electricity consumption, corresponds to 1.18%.

    Technology

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

    Percent of total revenue (%)

    13.67
    Akçansa has 26 different sustainable products in its product portfolio and also has the definitions of sustainable products in place considering EU Taxonomy and other taxonomies. Total revenues from sustainable products during the reporting year is 392,400,000 TL.
    Optional comment
    We have classified our cement products also considering the EU taxonomy and other taxonomies. It was defined that if the cement product have a clinker ratio between 50%-65% which is much more lower than the conventional Portland Cement, it is classified as "low-carbon product". Beyond, if the cement product have a clinker ratio between 65%-80%, it is classified as "climate-friendly product". Finally if the cement product have a clinker ratio between 80%-95% and also have additional sustainable benefits, it is classified as "environmentally-friendly product". The rest are classified as "conventional products".

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Optional comment
    Akçansa operates in cement, concrete and aggregates business lines.

    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

    2325.35

    Groundwater:

    1877.23

    Surface water:

    0

    Rainwater:

    80

    Wastewater:

    0

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

    100

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    2146.75

    Groundwater:

    2066.75

    Surface water:

    0

    Rainwater:

    80

    Wastewater:

    0

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

    100
    Optional comment
    Turkey is under water stress. Akçansa's plants are located in high water stress areas. To manage water stress risk, we continuously monitor and develop programs to decrease water consumption in all sites.

    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/$):

    0.0067
    Optional comment
    Water intensity is calculated as follows: Total water consumption from high water stress locations (all locations) / Total Revenue in $ Total water consumption from high water stress locations (all locations): 2,146,749.25 cubic meters Total Revenue in $: Akçansa's total revenue in 2021 is 2,871,403,785 TL, (Exchange rate is taken as the yearly average of 2021 which is 8.89)

    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

    18

    Hectares

    301.06
    Optional comment
    Akçansa has 18 mining site licenses. Production continues on a total area of 301.06 ha in these fields. Akçansa's all quarry areas in Samsun, Çanakkale and some quarries in İstanbul-Büyükçekmece provinces are forest areas or near forest areas. All of the quarries have Approved Recovery Plans.

    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)

    2.5
    Optional comment
    Akçansa has rehabilitated an area of 26.53 hectares in the Mining Sites where production ended as of today. During the reporting period, 2.5 ha of quarry areas were rehabilitated.

    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

    306.01 hectares of mining sites that corresponds to all active mining sites have "Approved Recovery Plans". Akçansa has rehabilitated 26.53 hectares in the Mining Sites where production ended in all of its quarries.

    Natural regeneration

    Agroforestry

    Set-aside land

    110 hectares (temporary habitat)

    Biodiversity offsetting

    Other (please specify in text box)

    In addition to planting trees for recreational purposes, we are constantly creating grasslands and habitats at our facilities and quarry sites. There is a pond with fish in the Büyükçekmece Factory. In the Muratbey quarry, habitats for animals have been created.

    Sector-specific: Waste

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

    Waste Generated (t)

    4131.78
    Optional comment
    Total waste generated in production plants including hazardous and non-hazardous waste is 4131.78 tonnes Hazardous waste sent to disposal areas: 0.19 tonnes Hazardous waste sent to recycling: 462.39 tonnes Non-hazardous waste sent to disposal sites: 157 tonnes Non-hazardous waste sent to recycling: 3512.20 tonnes

    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 (%)

    11.2
    Optional comment
    Total waste generated in production plants including hazardous and non-hazardous waste is 4131.78 tonnes. Hazardous waste sent to disposal areas: 0.19 tonnes Hazardous waste sent to recycling: 462.39 tonnes Total hazardous waste: 462.58 tonnes. Ratio of hazardous waste in total waste generated: 11.2%

    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)

    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.

    As Akçansa, we closely followed the developments regarding Climate Change in our country and on a global scale in 2021. The scientific findings that emerged in the light of the 6th Assessment Report (AR6) of the Intergovernmental Panel on Climate Change (IPCC) have guided our assessments on the risks that may arise from climate change in the near future and the fight against climate change. We reconsidered the risks that threaten our physical assets and production continuity and defined our actions for institutional resilience and capacity building accordingly. As stated in the "Net Zero by 2050" report published by the IEA, the cement industry is among the leading sectors in terms of decarbonization targets, and important windows of opportunity arise with the maturation of innovative technologies, process and product solutions. In this direction, as a leading player in the cement industry in our country, we have embodied our emission reduction targets and roadmaps in line with developing technologies.We are increasing our use of alternative fuels as fossil fuel substitutes in our 3 plants day by day. By 2021, we increased the use of alternative fuels to 19%. With the international environmental product declarations prepared for our ready-mixed concrete products, we started to present the carbon footprint of our products to our customers in a transparent manner. We have reduced our net specific CO2 emissions by 2.2% in the last three years, from 0.770 tons of CO2/ton cementitious to 0.753 tons of CO2/ton cementitious. Within the scope of our 2030 Environmental Footprint reduction targets, we aim to reduce the net specific CO2 emissions to 0.649 tons CO2/ton cementitious. In 2021, we made a total environmental investment of 41.6 million TL. By continuing our cooperation with İSTAÇ (Istanbul Environment Management Industry And Trade Company) and İSKİ (Istanbul water and sewerage administration) in 2021, we supported the prevention of 77,000 tons of sewage sludge and 12,000 tons of liquid waste collected from ships passing through the Bosphorus. As a result of practices such as optimization and transition to energy-efficient equipment, improvements in the use of alternative fuels, route and load optimization in transportation, 15,181.88 MWh savings were achieved in the production processes we carried out at our facilities. With the digital transformation projects implemented in 2021, an energy saving of 0.191 kWh was achieved in each ton of cement produced. With the energy obtained from the wind turbine with a capacity of 2.5 MW installed in our Çanakkale Factory, we met 2.1% of the electricity need of the facility in 2021. In the main site of Çanakkale, we met 24.9% of the total electricity need of the factory with the energy obtained from our waste heat recovery facility with a capacity of 15 MW, and we prevented approximately 36.000 tons of CO2 emissions with our total renewable energy use. We harvested 80,000 m3 of water with our collection ponds. We continuously monitor the air and dust emissions in cement production. We operate far below the emission limits defined in the environmental legislation in all our plants and plants, which are monitored 24/7 by the Ministry of Environment, Urbanization and Climate Change and Provincial Directorates. As part of our dedusting projects that we have invested in in the past years, our clinker stockrooms in our Büyükçekmece plant have been made dust-free. In addition, our dedusting investments continued in our Çanakkale plant. With the Non-Catalytic Selective Reduction (SNCR) systems available in all our plants, NOx emissions from the combustion process are reduced, thereby reducing NOx emissions into the atmosphere. We provide rehabilitation of the areas we operate in accordance with the unique environmental conditions and develop projects for the protection of biodiversity. As a result of the rehabilitation works carried out until 2021, we carried out the rehabilitation of 26 hectares. In 2021, a total of 2500 trees were planted, 1000 trees in 0.5 hectares of land in Ladik and 1500 trees in 2 hectares of Çanakkale. We started the preparations for our Biodiversity Action Plan in 2021 for the realization of the projects planned to be implemented. In the upcoming period, projects will be realized within the framework of the Biodiversity Action Plan and we will follow the progress of these projects. Akçansa 2021 Sustainability Report can be reached via the following link: http://www.akcansa.com.tr/docs/Ak%C3%A7ansa%202021%20Sustainability%20Report.pdf

  • Anti-corruption

    Commitment

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

    2016
    Optional comment
    Akçansa has an official policy and related internal procedures regarding anti-corruption. Scope of Anti-Bribery and Anti-Corruption Policy; • All Akçansa employees, including the Board of Directors of Akçansa, • The persons and organizations (business partners who work on behalf of Akçansa such as supplier, consultants, lawyers, external auditors. Policy is publicly available: http://www.akcansa.com.tr/docs/akcansa-anti-bribery-and-anti-corruption-policy.pdf Trainings to related employees are periodically given.

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Akçansa has an official policy and related internal procedures regarding anti-corruption. Scope of Anti-Bribery and Anti-Corruption Policy; • All Akçansa employees, including the Board of Directors of Akçansa, • The persons and organizations (business partners who work on behalf of Akçansa such as supplier, consultants, lawyers, external auditors. Policy is publicly available: http://www.akcansa.com.tr/docs/akcansa-anti-bribery-and-anti-corruption-policy.pdf Trainings to related employees are periodically given.

    Prevention

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

    Optional comment
    Trainings regarding anti-corruption and integrity are provided to selected employees regarding their roles and responsibilities.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

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

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    No incident

    Confirmed during the current year, and related to this year

    0
    No incident

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

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

    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.

    Anticorruption and compliance basics training assigned related employees eregarding to prevent their potential actions and increase their awareness.