ESRS disclosure: ESRS S1 \ DR S1-1 \ Paragraph 24a

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  • Has the company established grievance procedures to address complaints, manage appeals, and offer recourse for employees in instances of identified discrimination? Additionally, is the company attentive to both formal structures and informal cultural issues that may hinder employees from voicing concerns and grievances?
  • Question Id: S1-1_21

    As a general principle we aim to resolve issues and concerns at the lowest level of the organisation by ensuring continuous dialogue between placemakers and management at relevant levels. This principle is firmly prescribed in our Global People Standards.

    We acknowledge that certain impacts or concerns may not be addressed or resolved appropriately at a lower organisational level and our Code of Conduct therefore formally codifies access to the Head of People & Culture, the Head of Legal and the CFO in each of our operating countries for raising concerns.

    In addition, we have for years made available a Speak Up channel for our placemakers as well as business partners and other stakeholders. Reports can be made anonymously or non-anonymously by phone or electronic form to an independent third-party or personally to our Head of Group Internal Audit.

    Our Speak Up Policy refers to the EU external reporting channels available in countries for any matters that reporters are not comfortable reporting through ISS’s available grievance mechanisms. We are not aware of any reports to any national authority designated to receive whistleblowing reports, including National Contact Points, in regard to our operations and practices having been made during 2024.

    Our ordinary grievance mechanisms are supported by our Escalation Policy, which ensures that serious events across the organisation are ultimately escalated to the EGM level. Incidents covered by the scope of our Code of Conduct and Speak Up Policy are also covered by our Escalation Policy. When incidents or information within the scope of the Speak Up Policy is escalated outside our Speak Up reporting channel, it will manually be recorded within our Speak Up system.

    Report Date: 4Q2024