2022 Communication on Progress

Flight Centre Travel Group

Published date

June 29, 2022

No. of questions

57

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    In 2021, Flight Centre Travel Group created our first Sustainability Report which incorporated a statement from the FCTG board (the highest governance body) and it covered sustainable development, environment and people.

    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
    Please refer to the FCTGL Modern Slavery Statement - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf. Please refer to the anti-corruption policy link here - https://www.fctgl.com/investors/governance/anti-bribery-corruption-policy/

    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
    Please refer to the FCTGL Modern Slavery Statement - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf Please refer to the FCTGL code of conduct - https://www.fctgl.com/investors/governance/code-of-conduct-2/

    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
    Flight Centre Travel Group has a Modern Slavery working group and a Sustainability Taskforce overseeing all sustainability initiatives. In 2021 the role of Global Sustainability Officer was created and appointed. The GSO has direct access to the most senior leadership team along with the FCTG board of directors.

    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
    Flight Centre Travel Group has a Modern Slavery working group and a Sustainability Taskforce overseeing all sustainability initiatives. In 2021 the role of Global Sustainability Officer was created and appointed. The GSO has direct access to the most senior leadership team along with the FCTG board of directors.

    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
    Please refer to the FCTGL Risk Management Policy - https://www.fctgl.com/investors/governance/risk-management-policy-2/

    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
    Please refer to page 7 - Our supply chain within the FCTGL Modern Slavery Statement

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

    No, this is not a current priority

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

    Yes, related to our own operations

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

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    Please refer to page 8, section 4 - Actions Taken to Assess and Address Modern Slavery Risks - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf Pleasee refer to section "monitoring & review" within the anti-bribery & corruption policy - https://www.fctgl.com/investors/governance/anti-bribery-corruption-policy/

    7.1. During the due diligence process, 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
    Please refer to page 8 "Product assessment– modern slavery risk" within the Modern Slavery Statement - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf.

    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
    Please refer to the FCTGL whistleblower policy - https://www.fctgl.com/investors/governance/whistleblowing-policy-2/

    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
    Please refer to the FCTGL whistleblower policy - https://www.fctgl.com/investors/governance/whistleblowing-policy-2/

    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

    Optional comment
    Please refer to "responding to reports under this policy" with the FCTGL whistleblower policy - https://www.fctgl.com/investors/governance/whistleblowing-policy-2/

    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 (#)

    5

    Male (%)

    80

    Female (%)

    20

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    0

    Above 50 years old (%)

    100

    From minority or vulnerable groups (%)

    0

    Executive (%)

    1

    Independent (%)

    4

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

  • 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?

    Commitment

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

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

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

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    Rights of women and/or girls

    Access to culture

    Rights of indigenous peoples

    We have created a Reconcilation Action Plan which addresses our commitment to the rights of First Nation Peoples in Australia however it is not a policy. Details can be found at https://www.fctgl.com/about-us/our-commitment-to-reconciliation/

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    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.

    Continued policy review and development to ensure we are making progress.

  • 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

    Forced labour

    Please refer to Modern Slavery Statement, 30 June 2021 - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf

    Child labour

    Please refer to Modern Slavery Statement, 30 June 2021 - https://www.fctgl.com/wp-content/uploads/2022/02/211221_Signed_Flight-Centre-FY21-Modern-Slavery-Statement.pdf

    Non-discrimination in respect of employment and occupation

    Please refer to Code of Conduct, 2021 - Clauses 7.12 (Harassment, bullying and discrimination) and 7.13 (Equal opportunity) - https://www.fctgl.com/investors/governance/code-of-conduct-2/

    Occupational safety and health

    Code of Conduct, 2021 - Clauses 7.14 (Safe working environment) - https://www.fctgl.com/investors/governance/code-of-conduct-2/

    Working conditions (wages, working hours)

    Each employee is issued with a contract of employment outlining the working conditions including wages, working hours etc.

    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 2017 FCTGL created an enterprise bargaining agreement with the Flight Centre staff working in all of the retail locations within Australia (approximately 2000 staff). This agreement is due for renewal in 2022.

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    There is continuous and ongoing work regarding working conditions, wages, working hours due to the ongoing requirement to secure and retain talent within a highly competitive market.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

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

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

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

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    There is continuous and ongoing work regarding working conditions, wages, working hours due to the ongoing requirement to secure and retain talent within a highly competitive market. An example is the Global Recovery Rights scheme where every employee globally was awarded a portion of shares (or the financial equivilent) to assist in the retention of staff as detailed in the remuneration report within the annual report (p. 19) https://www.fctgl.com/wp-content/uploads/2021/09/FLT-2021-Annual-Report.pdf

    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 (%)

    15
    Optional comment
    We have bargaining agreements for our retail staff in Australia and our staff in Japan which equates to approximately 1500 people globally.

    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

    50

    Non-executive board

    20

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

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

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

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0
    Optional comment
    The number of incidences is less than 0.001%

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

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0
    Optional comment
    The number of incidences is less than 0.001%

    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 incidents

    Forced labour

    No incidents

    Child labour

    No incidents

    Non-discrimination in respect of employment and occupation

    No incidents

    Occupational safety and health

    No incidents

    Working conditions (wages, working hours)

    No incidents
    Optional comment
    No incidents

    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.

    Wage Compliance projects to ensure we are meeting our statutory obligations. Constant review of policies to ensure compliance with various legislative instruments.

  • Environment

    Commitment

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

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    No manufacturing as we are mainly a bricks/mortar travel management company.

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

    Energy & Resource Use

    Optional comment
    In February 2022, Flight Centre Travel Group committed to the Science Based Target Initiative with the intent to have interim goals established be the end of 2022 and our full commitment validated and published by the end of 2023.

    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
    In February 2022, Flight Centre Travel Group committed to the Science Based Target Initiative with the intent to have interim goals established be the end of 2022 and our full commitment validated and published by the end of 2023.

    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

    Optional comment
    We have been moving some of our operations to renewable energy sources.

    Climate Action

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

    Scope 1 Emissions

    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    Emissions (tCO2e)

    Scope 2 Emissions

    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    Emissions (tCO2e)

    Scope 3 Emissions

    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    Emissions (tCO2e)

    Optional comment
    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    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

    Optional comment
    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    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
    We are in the process of auditing our operations to prepare our Scope 1, 2 & 3 science based targets

    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

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

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

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

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

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    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.

    Flight Centre Travel Group created and placed the role of Global Sustainability Officer in December 2021. The the purpose of the role is to develop and deploy the FCTG ESG framework globally. Within the environmental pillar of this framework there will be a decarbonization roadmap for Flight Centre Travel Group as we head toward Net Zero. Through an RFP process, Flight Centre Travel Group has secured the consulting services of Edge Environment to assist with the development of our sustainability vision, strategic framework and decarbonization roadmap throughout 20222. In February 2021, Flight Centre Travel Group committed to the Science Based Target Initiative with the intent to have interim goals established be the end of 2022 and our full commitment validated and published by the end of 2023. Over the coming months FCTG will be working with Edge Environment to calculate our current greenhouse gas emissions and set ambitious decarbonization goals to submit for third party SBTi validation.

  • Anti-corruption

    Commitment

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

    Please refer to the Anti-bribery and corruption policy - https://www.fctgl.com/investors/governance/anti-bribery-corruption-policy/

    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
    Please refer to the FCTGL code of conduct 7.2 Anti-Bribery and Corruption Law compliance https://www.fctgl.com/investors/governance/code-of-conduct-2/

    Prevention

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

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

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

    Response and Reporting

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

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    Confirmed during the current year, and related to this year

    Confidential

    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.

    We will continue to provide mandatory training for all employees on the principles of anti-corruption and provide easy reporting mechanisms.