Scope 1 Emissions
2022 Communication on Progress
flatexDEGIRO AG
Published date
October 6, 2022
No. of questions
55
Supplemental files
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?
3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Prevention
6. Does the company have a process or processes to assess risk?
6.1. During the assessment of risk, which business relationships are reviewed?
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?
7.1. During the due diligence process, which business relationships are reviewed?
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.
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?
Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
13. Do you produce sustainability reporting according to:
Optional commentNon-Financial Reporting Directive (NFRD)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?
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.
With regard to the definition of human rights in terms of content, we referenced international accepted standards such as the Universal Declaration of Human Rights and take guidance from the UN Guiding Principles on Business and Human Rights. With our commitment to the UN Global Compact, we are committed to supporting the protection of international human rights and ensuring that we are not complicit in human rights abuses.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
1.1. For each labour rights policy, is it:
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?
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?
4. Who receives training for the following labour rights issues?
5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Performance
6. What is the percentage of employees covered under collective bargaining agreements?
Optional commentAll employees at flatexDEGIRO are paid in line with the market. Collective bargaining agreements do not apply.7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
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?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Optional commentDue to the flatexDEGIRO business model, our employees only have few reportable commuting accidents and accidents at work. In the 2021 financial year, four accidents at work/commuting accidents were identified. Therefore, the rate of reportable accidents was 0.4% in the financial year. Despite this currently very low level, it is important for flatexDEGIRO to constantly promote a culture of safety in the company.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?
Optional commentIn 2021, there were no incidents on the above topics.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.
We advanced the introduction of a dedicated HR management system in 2021, with release for operational implementation scheduled for Q2. This ensures that all relevant HR information can be mapped and accessed in a system. In addition to key HR processes from recruitment to on/off boarding, this also includes all offered training. This is made available and accessed via the platform, and prompt completion is tracked for obligatory training in particular. Alongside this, for the first time there is also a global standardised data basis available. All strategic decisions on the subject of occupational health and safety are managed on a centralised basis. The measures to be implemented in the financial year are developed by the HR Department and coordinated with the Management Board. The local points of contact at the individual locations make decisions on useful additions to this. Protecting the health of our employees is also part of our self-image as a responsible employer. For this reason, in 2021 we started to develop a safety at work strategy that is standardised Group-wide, for which the management team bears overall responsibility. An important step in this process was the Occupational Health and Safety Group guideline. The management team works together with employees to review and update this and other guidelines and procedures. We know that the consultation and participation of the workforce in our safety system is of crucial importance and improves decision-making on questions relating to health and safety in the workplace. The consultation is also included in the risk assessment process and the development of safe work procedures. Suggestions for changes and improvements to guidelines, procedures or safe working methods are promoted by means of reports to the management team. Discussions on advising and informing employees on safety-related questions take place at regular intervals. Societal changes bring different expectations for work/life balance. This has also played a crucial role at flatexDEGIRO in the past. We want to provide flexible working time models to unburden employees in their various life phases and give them the opportunity to find a balance between their professional and personal lives on an individual basis. We have been offering a range of flexible working time models for several years. These include for example flexible working hours, trust-based working hours, sabbaticals, semi-retirement, and parental leave. In particular, parents’ return to professional life is promoted through various part-time models and the assumption of childcare costs until school enrolment. flatexDEGIRO values the range of qualifications, ideas, experience and perspectives of all its employees. Our self-image includes an appreciative corporate culture that offers all employees the same opportunities for advancement. The maintenance of an environment of this type is the responsibility of each employee. Our managers lead in such a way that creates an environment that promotes respect for each individual. The company is firmly committed to promoting a supportive and integrative culture throughout the workforce. It is in our best interest to promote diversity and eradicate discrimination in the workplace. Our Code of Conduct states that flatexDEGIRO does not tolerate any disadvantages due to age, gender, ethnicity, disability, sexual identity, religion or world view. In addition, we adopted a “Diversity and Inclusion Statement” in 2021, which sets out even more precisely and describes in more detail how we interact with one another. For example, criteria such as motherhood or marital partnerships have also been explicitly ruled out as discrimination characteristics. Topics concerning appreciative interaction with one another are also addressed on a regular basis as part of compliance training. Any violations of our guidelines can be reported by the employees at any time, to their direct line manager, the Data Protection Officer, or the Works Council. Anonymous reporting paths are also available.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
1.1. For each environmental policy, is it:
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?
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?
4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
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)?
Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
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.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
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 a medium-sized company, the greatest levers for flatexDEGIRO’s continually improving environmental performance are business trips and being as economical as possible with energy. Therefore, the core of our environmental management is reducing direct and indirect energy consumption and therefore avoiding emission of greenhouse gases, which make a significant contribution to global warming. As part of our risk management, we also observe relevant developments in terms of environmental regulations, such as the carbon tax. Thanks to our innovative business model and low business carbon footprint, we do not expect any significant negative impact from this. flatexDEGIRO takes its own ecological responsibility seriously and pursues the goal of reducing the respective energy consumption at all locations. This also coincides with our objective of reducing emissions, given that at flatexDEGIRO these are largely determined by our consumption of electricity and heat. We have adopted a light concept for the buildings we use ourselves. In as far as is structurally feasible, new locations are equipped with as many glass elements as possible so that the energy requirement for lighting is kept to a minimum. Energy-efficient LED lighting is the standard at the latest flatex locations of Zwickau and Hamburg, and all locations are being gradually retrofitted. We completed the switch to LED technology at all German locations in the 2021 financial year. Intelligent control of building technology is also standard at our new flatex locations, meaning that we are now highly energy efficient due to consumption management and optimised managed usage behaviour. This prevents the air conditioning unit from working contrary to the heating, for example. A temperature in a specified range is set for each room, and the system decides whether the heating or air conditioning system is needed to achieve it. Our business model requires the use of data centres and server infrastructure, which can be very energy- and emissions-intensive. We constantly review and optimise the infrastructure and invest in new technologies in order to increase performance and – independent of that – reduce the energy requirement. We also dismantled our older existing infrastructure in the reporting year and replaced it with advanced and more efficient alternatives. The switch from traditional PCs to thin clients or notebooks was successfully completed in the past financial year. Not least, despite the constantly growing number of employees, we have been able to keep our power consumption constant. As flatexDEGIRO does not own any of its own buildings, but instead is a tenant at all locations, we exclusively generate direct carbon emissions (scope 1 emissions) through the use of our vehicle fleet. We are one step further ahead in terms of our vehicle fleet. Since April 2021, we have been using the carbon-neutral fuel card to directly offset all emissions generated by vehicle use. In the reporting year, we have adapted our vehicle fleet guidelines to advance the promotion of e-mobility. Only electric or (plug-in) hybrid vehicles will be made available as company cars in future. The majority of our emissions are created through the procurement of power and heat (scope 2 emissions). In 2021, we launched a data recording tool to refine environmental data recording in this area. With this, in future all directly and indirectly caused emissions will be recorded, analysed and documented in accordance with the specifications of the Greenhouse Gas Protocol and ISO 14064-1. We intend to have completed its launch by mid-2022. flatexDEGIRO also avoids omissions that occur in upstream or downstream parts of the value creation chain (scope 3 emissions). In this way, we orient ourselves on the sustainability benchmarks in our supply chain: to protect the environment, we procure hardware – primarily notebooks, monitors, servers and switches – directly from the manufacturer, and in this way avoid additional travel via intermediate retailers. In collaboration with our most important suppliers, we exchange knowledge and ideas on current product developments whilst also keeping an eye to sustainability aspects. All products are subject to intensive testing in advance to minimise outages. Our focus on the use of energy efficient and stable IT solutions is not only good for the environment but also for our operating cost expenditure. Additional emissions are created by our employees commuting to their workplace. flatexDEGIRO promotes the use of public transport and bikes. For example, in 2018 we gifted each employee a bike and equipped our locations with a bike pool that all employees can use. In addition, we promote switching to e-mobility in private transport by suggesting installation of charging infrastructure to our landlords at suitable sites.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
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?
Prevention
3. Who receives training on anti-corruption and integrity?
3.1. How often is such training provided?
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.
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.
Preventive work is needed to prevent compliance incidents and breaches. The basis for management is the risk strategy, which provides for compliance and money-laundering risk analyses as central instruments for assessing and mitigating potential compliance and money-laundering risks. These risk analyses are conducted at least once a year, and cover all company areas both within and outside Germany. Compliance topics such as anti-corruption or anti-money-laundering measures are organised through the use of monitoring software adapted to flatexDEGIRO. All units relevant for the risk analysis were reviewed for corruption risks for the 2021 year. Due to the business model, no significant corruption risks were determined in this process. In the current Group-wide risk assessment, all material compliance risks were for the most part mitigated through the establishment of corresponding countermeasures. In addition to the risk management system, flatexDEGIRO has a whistleblower system for preventive identification and tackling of deficiencies. Employees who would like to draw attention to deficiencies of any type as whistleblowers can contact the Compliance Office or the Anti-Money-Laundering Officer or their representative directly to do so. Tips relating to suspicious cases, possible legal breaches, and also discrimination incidents can be reported anonymously and confidentially. The precise procedure is set out in our Whistleblowing Policy, and all employees are aware of this procedure. To maintain the high level of our compliance performance and to take a preventive approach to compliance breaches, we conduct employee training on a regular basis. We expect from our employees that they always act in a legally compliant manner, i.e. that they strictly follow both internal regulations and laws. A core responsibility of the Compliance Office is therefore to train and advise employees on relevant compliance questions. In addition to general compliance training, the focuses in this financial year were anti-money-laundering and anti-corruption measures, data protection, IT security, and safety at work. This training is performed at least once a year, to actively increase employee awareness. All employees received training on anti-corruption practices in the 2021 financial year. Specific employee groups also received training on anti-bribery practices. With our intensive training activities, we want to consistently and sustainably anchor integrity and rules-compliant behaviour more deeply in our employees. In addition, in 2021 all members of the Management Board and Supervisory Board were trained in guidelines and procedures relating to anti-corruption practices.