2022 Communication on Progress

Bilfinger SE

Published date

July 21, 2022

No. of questions

60

Supplemental files

Code of Conduct

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

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

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

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

    Yes, related to our own operations

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

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

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

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

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

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

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

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

    No, this is not a current priority

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

    Yes, related to our own operations

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

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

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

    No

    Yes

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

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

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

    Are there processes in place to avoid retaliation?

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

    Other (Please provide additional information)

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

    No process to enable remedy to stakeholders

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

    Remedy is available to all affected stakeholders

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

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

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

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

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

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

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

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    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 (#)

    15

    Male (%)

    86.7

    Female (%)

    33.3

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    33.3

    Above 50 years old (%)

    86.66

    From minority or vulnerable groups (%)

    0

    Executive (%)

    20

    Independent (%)

    40

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

    Assurance by auditor

  • 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
    Comment regarding selection: The online questionnaire appears to be limited in the amount of topics which can be selected. The 5 most relevant are selected. Working conditions and data secutrity / privacy are also relevant in our business model.

    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.

    Human Rights are firmly anchored in our company values and their protection is one of our core tasks. This applies with respect to our own employees and our supply chain. The key document and reference point for any other policies, procedures or processes is our Code of Conduct. The Code of Conduct was approved by the executive management and is publicly available on our website in both German and English. 18 different language versions are available for internal Group-wide use, ensuring that the Code of Conduct can be read and understood throughout the Group. The Code of Conduct defines the principles of acting with integrity toward both other employees as well as toward external persons and organizations and addresses all of our managers and employees. Our managers and employees are obligated to adhere to the principles formulated in the Code of Conduct and to confirm in writing that they have received and familiarized themselves with them. The topics contained in our Code of Conduct are part of our Group-wide training program, both through in-person trainings and e-learnings. We operate a confidential whistleblower to record any instances of possible violations of our Code of Conduct, including the respect for human rights principles that it contains. The whistleblowing hotline is open to (anonymous, if preferred) reporting by our own employees as well as external parties. Bilfinger applies a zero tolerance policy to violations of our Code of Conduct and reviews any cases for process improvements and lessons learned, which will be shared for example through communication measures or will be added as relevant training contents. More generally, we have implemented a Compliance Management System (CMS) well above industry standards, which operates in the prevent – detect – respond-cycle and is subject to ongoing review and optimization. In addition, to our Code of Conduct, we have implemented a separate Code of Conduct for our suppliers (our Vendor Declaration), which we request our suppliers to sign and to adhere to. Please also refer to the publicly available Non-Financial Group Declaration in our Annual Report 2021, which includes additional information on our governance and sustainability efforts. Currently, we are reviewing our policies, procedures and processes against the background of the German supply chain due diligence act and respective additional EU legislation. We use this opportunity to further benchmark and strengthen our CMS in the area of Human Rights and Social Compliance. Adjusted reporting will be mandatory starting from January 2023 on.

  • Labour

    Commitment

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

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

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

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    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

    In the reporting year, we generated the vast majority of our revenue in regions where employee rights are guaranteed by law: more than 80 percent of our revenue was generated in the EU as well as the United Kingdom, Switzerland and Norway. Here, at the end of the year around 80 percent of our people were employed.

    Forced labour

    In the reporting year, we generated the vast majority of our revenue in regions where employee rights are guaranteed by law: more than 80 percent of our revenue was generated in the EU as well as the United Kingdom, Switzerland and Norway. Here, at the end of the year around 80 percent of our people were employed.

    Child labour

    Non-discrimination in respect of employment and occupation

    In the reporting year, we generated the vast majority of our revenue in regions where employee rights are guaranteed by law: more than 80 percent of our revenue was generated in the EU as well as the United Kingdom, Switzerland and Norway. Here, at the end of the year around 80 percent of our people were employed.

    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

    To be able to record, process and communicate HSEQ incidents worldwide in accordance with uniform standards, we use a management software (Synergi Life, referred to at Bilfinger as ACTIVE). All types of HSEQ incidents can be captured by executives and employees using an app, allowing them to be promptly recorded on site. Event analysis is key to ongoing improvement. An IT-based workflow helps employees and supervisors analyze root causes and facilitates the development of corrective actions to avoid similar situations in the future. Workplace safety is the subject of the HSEQ quarterly report that is submitted to the Executive Board. Particularly serious accidents are reported immediately to the Executive Board. It is informed on an ongoing basis regarding their analysis as well as necessary corrective measures. The objective pursued by all the measures we take is to continually improve occupational safety. Our objective, ‘Zero is possible,’ helps us to consistently reduce the number of accidents. To achieve this objective, we pursue a twofold approach: we take the technical and organizational measures this requires, and we address occupational safety again and again in a variety of communications channels in order to raise awareness for HSEQ issues.

    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 (%)

    80
    Optional comment
    In the reporting year, we generated the vast majority of our revenue in regions where employee rights are guaranteed by law: more than 80 percent of our revenue was generated in the EU as well as the United Kingdom, Switzerland and Norway. Here, at the end of the year around 80 percent of our people were employed.

    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 (%)

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    6

    Non-executive board

    33

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

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

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

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0.21
    Optional comment
    LTIF: Lost Time Injury Frequency – Accidents per 1,000,000 working hours performed.

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    1
    Optional comment
    Fatalities

    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 cases in this category

    Forced labour

    No cases in this category

    Child labour

    No cases in this category

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

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

    In the reporting year, we generated the vast majority of our revenue in regions where employee rights are guaranteed by law: more than 80 percent of our revenue was generated in the EU as well as the United Kingdom, Switzerland and Norway. Here, at the end of the year around 80 percent of our people were employed.

  • 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

    2021

    Oceans

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Forests / Biodiversity / Land Use

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Air Pollution

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

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

    2021

    Energy & Resource Use

    2021

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    Prevention

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

    No engagement on this topic

    To better understand the risks/ impacts in question

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

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

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

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

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

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

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

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

    Energy & Resource Use

    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

    Emissions (tCO2e)

    35608

    Scope 2 Emissions

    Emissions (tCO2e)

    23765

    Scope 3 Emissions

    We plan to design the setup of Scope 3 data collection and then implement it step by step in our system. However, due to the significantly greater complexity compared to Scope 1 and Scope 2, this is not expected to be completed in 2022.

    Emissions (tCO2e)

    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 (%)

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

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    Technology

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

    Percent of total revenue (%)

    Optional comment
    EU Taxonomy alignment to be reported frist time in 2023, reporting on other certificates not available

    Sector-specific Questions

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

    Sector-specific: Water

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

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Groundwater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Surface water:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Rainwater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Wastewater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

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

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Groundwater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Surface water:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Rainwater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Wastewater:

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

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

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    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/$):

    As an industrial service provider, Bilfinger does not use more material and water than other service companies, and the quantity and quality of the waste produced does not differ from that of other companies that provide services. Potential savings and reductions are therefore limited to using materials and water as efficiently as possible in our office buildings and to treating waste with care.

    Sector-specific: Air pollution

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

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    SOx

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    Sector-specific: Waste

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

    Waste Generated (t)

    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 (%)

    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.

    We have implemented the concept developed in the 2020 financial year for reporting in 2021. We work with WeSustain’s Enterprise Sustainability Management (ESM) software. Energy requirements have the greatest direct impact on our greenhouse gas emissions. The most significant share of energy requirements comes from our properties as well as the Bilfinger vehicle fleet. In the coming financial year, we intend to conduct a detailed analysis of the data that was collected for the first time in 2021 in order to derive appropriate measures and sub-targets and to manage the development of our GHG emissions. Internally, we rely on a participatory approach. It is important to us to involve the entire workforce in the implementation process at all levels. This also enables us to take account of regional differences in regulations and legislation. Various instruments will be used to ensure the goals are firmly anchored, for example by defining personal goals accordingly or positioning the sustainability strategy as a focus topic at management events and executive development programs. From today’s perspective, the main levers for achieving the net zero target are the electrification of the fleet - especially passenger cars - and a change in the purchased electricity mix toward more renewable energies. In addition, we want to further develop the collection of our GHG emissions. We plan to design the setup of Scope 3 data collection and then implement it step by step in our system. However, due to the significantly greater complexity compared to Scope 1 and Scope 2, this is not expected to be completed in 2022. This applies equally to the definition of differentiated sub-targets. In this context, we also want to address the requirements of the science-based targets initiative and evaluate the possible implications for Bilfinger.

  • Anti-corruption

    Commitment

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

    2022
    Optional comment
    Counterracting corruption and bribery is a central component of our compliance management system. For this reason, Corporate Compliance is responsible for the framework to counteract corruption and bribery at Bilfinger. Bilfinger’s compliance management system covers all areas of the business and pursues the objective of preventing compliance violations through preventive measures, recognizing early any type of misconduct and, in the case of confirmed violations, reacting quickly and consistently punishing misconduct Bilfinger applies the prevent, detect, respond cycle. Our compliance management system is subject to continuous review and optimization, as we apply the concept of the prevent, detect, respond cycle. The program is adjusted by means of risk mitigating measures resulting from our periodically executed compliance risk assessments. The most recent compliance risk assessment took place in the first quarter of 2022. In 2021 and 2022 we also revised several compliance governance documents to adopt recent changes.

    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
    Bilfinger works with different layers of governance documents. On top there is our Code of Conduct. For our anti-corruption program we have a Group Policy Anti-Corruption and a Group Policy Conflict of Interest in place. Topics like gifts and hospitality, sponsorship and donations as well as third party due diligence are governed in group wide applicable standard operating procedures. We have a central compliance help desk in place which employee can contact for any kind of compliance related questions. Besides the compliance help desk we have an independent reporting line which employees and third parties can use to report any misconduct.

    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

    Optional comment
    We use customized trainings formats for different target groups. Employees, who have a high exposure regarding ABC risks receive customized in person trainings. All employees with a PC workstation and access to the Bilfinger network receive CoC and ABC e-learnings. Employees without PC workstation and access to the Bilfinger network participate in Code of Conduct Tool Box talks at the work site.

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

    1. The Compliance Review Board (CRB) manages and monitors the organization and implementation of our compliance management system. It is comprised of the full Executive Board as well as selected heads of the corporate departments and meets quarterly under the chairmanship of the Chief Compliance Officer. The CRB has a central role in ensuring the ongoing effectiveness of our compliance management system. 2. Our standardized ICS (internal control system) framework includes ABC related ICS controls 3. We developed a so called Compliance Cockpit in place, which helps operational management and our compliance professional to steer the compliance management system based on Compliance KPIs. 4. Bilfinger employees participate in ABC surveys, which are prepared by regional compliance teams..

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    No incidents

    Confirmed during the current year, and related to this year

    0
    Our internal investigations team processed one allegation related to corruption. However, it was established that in fact a facilitation payment was made by another subcontractor of a customer who did not have a direct business relationship with Bilfinger. Our internal investigation concluded that no Bilfinger employee violated the Bilfinger Code of Conduct in connection with the allegation. Nevertheless, measures were taken in response to the allegation, in particular trainings. The subcontractor in question was blocked from any future cooperation with Bilfinger.

    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.

    To prevent future misconduct, we employ, among other things, practical compliance advice from Compliance Managers and Officers as well as the Compliance Help Desk, guidelines, supporting compliance IT tools as well as training and communication measures. Our compliance training modules include both on-site training and e-learning programs in which knowledge is conveyed and case studies are discussed. All employees also have access to a central Compliance Help Desk that offers support in all compliance-related questions. In addition to prevention, the rapid identification of any misconduct and an appropriate response to such misconduct are essential components of our compliance management system. There is a whistleblower system in place for the receipt, documentation and processing of suspicious cases in connection with possible violations of our Code of Conduct: Our employees and external parties can, on a confidential basis and if desired also anonymously, provide information on potential misconduct on the part of Bilfinger employees. In the extremely rare event that an employee is found to have engaged in serious misconduct, the Disciplinary Committee, chaired by Corporate Human Resources, decides on disciplinary action and sanctions to be taken. These range from informal warnings through to immediate termination including negative financial consequences. If misconduct on the part of a business partner is identified, the Independent Allegation Management Committee decides on necessary measures. These measures can include, among other things, termination of the business relationship, assertion of civil claims or the filing of an official complaint.