Goodyear Tire & Rubber Company

1. Sustainable natural rubber policy or commitment for all its operations?

This indicator is disabled as the company does not operate rubber plantations.

2. Sustainable natural rubber policy or commitment applies to all suppliers?

The company has published a sustainable natural rubber policy which applies to all suppliers.

3. High-level position of responsibility for sustainability?

The company has a Chief Sustainability Officer having high level of responsibility for sustainability excluding the board.

4. One or more members within the board of the company have responsibility for sustainability?

The company has a corporate responsibility and compliance committee, however, it does not have a singular board member for sustainability.

5. Percentage or number of women in senior management team?

11.11% - The company reports total nine members in its executive leadership team, out of which one member is a female. The gender balance is not directly reported by the company and was calculated from staff profiles and photos.

6. Percentage or number of women board members?

28.5% - The company reports four women board members out of the total 14 board members. Data as of 2021.

7. Member of multiple industry schemes or other external initiatives to reduce negative environmental or social outcomes associated with natural rubber production?

[Externally verified] The company is a member of WBCSD.

8. Collaboration with stakeholders to reduce negative environmental or social outcomes associated with natural rubber production?

The company collaborated with different stakeholders such as WBCSD's Tire industry project, regional tyre trade associations (RTTAs), including the European Tyre and Rubber Manufacturers' Association (ETRMA) and the U.S. Tire Manufacturers Association (USTMA) to support positive environmental or social outcomes associated with natural rubber production.

9. Sustainability report published within last two years?

The company has published its corporate responsibility report for 2021.

10. Reports through standardised reporting systems?

The company has prepared its Sustainability report in accordance with the GRI core option. The company has also submitted CDP questionnaires for Climate Change, Forests and Water Security in 2022.

11. Climate risks assessment available?

The company has discussed the summary of risks and opportunities related to climate change in the company's CSR report 2021. However, the information is not externally verified.

12. Lists countries and operations?

Manufacturing (Brazil, Canada, Chile, China, France, Finland, Germany, India, Indonesia, Japan, Luxembourg, Malaysia, Mexico, Netherlands, Peru, Poland, Singapore, Serbia, Slovenia, South Africa, Thailand, Turkey, United States).

13. Lists countries sourcing from?

14. Total land area managed/controlled for natural rubber (ha)?

This indicator is disabled as the company does not operate rubber plantations.

15. Total natural rubber planted area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

16. Scheme smallholders/outgrowers planted area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

17. Unplanted area (areas designated for future planting) (ha)?

This indicator is disabled as the company does not operate rubber plantations.

18. Conservation set-aside area, including HCV area (ha)?

This indicator is disabled as the company does not operate rubber plantations.

19. Maps of estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

20. Management plans for natural rubber production are available for all estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

21. Monitoring of management plan implementation available for all estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

22. Maps of scheme/outgrower smallholders?

This indicator is disabled as the company does not operate rubber plantations.

23. Names and locations of all third-party supplying industrial estates/management units?

24. List of jurisdictions where sourcing from smallholders?

25. Number of company owned natural rubber processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

26. Names and locations of company owned natural rubber processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

27. Number (or percentage) of company-owned processing facilities that source from company-owned operations and third parties?

This indicator is disabled as the company does not operate rubber plantations.

28. Reports total volumes (or percentages) sourced by company-owned processing facilities that come from company's own operations and third-parties?

This indicator is disabled as the company does not operate rubber plantations.

29. Number of third party supplying processing facilities?

30. Names and locations of all third party supplying processing facilities?

31. Number (or percentage) of third party supplying processing facilities that source from their own plantations and third party plantations?

32. Reports total volume (or percentages) sourced from third-party supplying processing facilities that come from the supplying facilities' own operations and third parties?

33. Total volume (or percentage) sourced for manufacturing that comes from intermediary traders rather than directly from processing facilities?

34. Time-bound commitment to achieve 100% traceability to processing facility level?

The company commits to audit all active suppliers of natural rubber every two years.

35. Percentage of supply traceable to processing facility level?

The company has reported 100% of its natural rubber suppliers were audited in 2021.

36. Time-bound commitment to achieve 100% traceability to industrial plantation level?

The company commits to achieve 50% raw material spend traceability by 2025. A commitment to achieve 100% traceability is not reported by the company.

37. Percentage of supply from own processing facilities traceable to industrial plantation level?

This indicator is disabled as the company does not operate rubber plantations.

38. Percentage of supply from third-party processing facilities traceable to industrial plantation level?

39. Time-bound commitment to achieve 100% traceability to jurisdictional level for smallholders?

The company commits to achieve 50% raw material spend traceability by 2025. A commitment to achieve 100% traceability is not reported by the company.

40. Percentage of supply from own processing facilities traceable to smallholder at jurisdictional level?

This indicator is disabled as the company does not operate rubber plantations.

41. Percentage of supply from third party processing facilities traceable to smallholders at jurisdictional level?

42. Member of the Global Platform for Sustainable Natural Rubber (GPSNR)?

[Externally verified] The company is a member of GPSNR. This has been verified via the GPSNR website.

43. Submitted self-declaration form for the Sustainable Natural Rubber Initiative (SNR-i)?

The company has submitted a self-declaration form for SNR-i.

44. Percentage area (ha) FSC certified?

This indicator is disabled as the company does not operate rubber plantations.

45. Time-bound plan for achieving FSC FM certification of estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

46. Percentage of scheme/outgrower smallholders (ha) FSC-certified?

This indicator is disabled as the company does not operate rubber plantations.

47. Time-bound plan for achieving FSC certification of scheme/outgrower smallholders?

This indicator is disabled as the company does not operate rubber plantations.

48. Percentage of natural rubber supply (tonnes) from independent smallholders/outgrowers/third-party natural rubber suppliers that is FSC-certified?

This indicator is disabled as the company does not operate rubber plantations.

49. Percentage of all natural rubber products handled/traded/processed (tonnes) that is FSC-certified?

50. Percentage area (ha) PEFC certified (excluding FSC certified area)?

This indicator is disabled as the company does not operate rubber plantations.

51. Certified under voluntary sustainability certification scheme?

The company reports that its 47 sites globally have ISO 14001 certification. However, the certificates are not publicly available.

52. Commitment to become 100% certified under voluntary sustainability certification scheme?

53. Commitment to zero conversion of natural ecosystems?

This indicator is disabled as the company does not operate rubber plantations.

54. Commitment to zero conversion of natural ecosystems applies to all suppliers?

The company commits all suppliers to no/zero conversion of all natural ecosystems.

55. Commitment to zero deforestation?

This indicator is disabled as the company does not operate rubber plantations.

56. Commitment to zero deforestation applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to no deforestation in its natural rubber procurement policy.

57. Criteria and cut-off date for defining deforestation and/or ecosystem conversion?

This indicator is disabled as the company does not operate rubber plantations.

58. Criteria and cut-off date for defining deforestation in supplier operations?

The company makes this commitment through the GPSNR Policy Framework. GPSNR defines natural rubber sourced from deforested areas or where HCVs have been degraded after 1 April 2019 to be non-conformant with its policy. The company also defines deforestation as HCV areas and specifies any deforestation/conversion past 1st April 2019 will not be accepted.

59. Evidence of monitoring deforestation and/or ecosystem conversion?

This indicator is disabled as the company does not operate rubber plantations.

60. Evidence of monitoring deforestation and/or ecosystem conversion in supplier operations?

61. Amount of deforestation and/or ecosystem conversion recorded in own operations since cut-off date?

This indicator is disabled as the company does not operate rubber plantations.

62. Amount of deforestation and/or ecosystem conversion recorded in supplier operations since cut-off date?

63. Commitment to restoration of deforestation/conversion?

This indicator is disabled as the company does not operate rubber plantations.

64. Commitment to restoration of deforestation/conversion applies to all suppliers?

The company commits to support suppliers restore deforested or degraded landscapes. However, it is unclear if suppliers are required to restore deforestation/conversion within their own operations caused by themselves or third parties.

65. Implementing a landscape or jurisdictional level approach?

The company makes this commitment through the GPSNR Policy Framework. Partial points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that do not fully meet the SPOTT indicator criteria.

66. Biodiversity policy?

This indicator is disabled as the company does not operate rubber plantations.

67. Biodiversity policy applies to all suppliers?

68. Identified species of conservation concern, referencing international or national system of species classification?

This indicator is disabled as the company does not operate rubber plantations.

69. Examples of species and/or habitat conservation management?

This indicator is disabled as the company does not operate rubber plantations.

70. Commitment to no hunting or only sustainable hunting of species?

This indicator is disabled as the company does not operate rubber plantations.

71. Commitment to no hunting or only sustainable hunting of species applies to all suppliers?

The company commits all suppliers to no hunting of all species in their operations.

72. Commitment to protect areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

73. Commitment to protect forest areas from illegal activities applies to all suppliers?

The company commits its suppliers to protect forest areas from only certain forms of illegal activities like poaching, over-hunting and habitat loss. A clear commitment to protect forest areas from unauthorised or illegal resource use, settlement and other illegal activities is not reported.

74. Evidence of protecting forest areas from illegal activities?

This indicator is disabled as the company does not operate rubber plantations.

75. Commitment to conduct High Conservation Value (HCV) assessments?

This indicator is disabled as the company does not operate rubber plantations.

76. Commitment to conduct High Conservation Value (HCV) assessments applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits suppliers to conduct HCV assessments.

77. High Conservation Value (HCV) assessments available for all new plantings since 1st April 2019?

This indicator is disabled as the company does not operate rubber plantations.

78. High Conservation Value (HCV) management and monitoring plans available for all new plantings since 1st April 2019?

This indicator is disabled as the company does not operate rubber plantations.

79. Commitment to the High Carbon Stock (HCS) Approach?

This indicator is disabled as the company does not operate rubber plantations.

80. Commitment to the High Carbon Stock (HCS) Approach applies to all suppliers?

The company commits all suppliers to apply the HCS Approach, as defined by the HCS Approach Toolkit.

81. High Carbon Stock (HCS) assessments available?

This indicator is disabled as the company does not operate rubber plantations.

82. Peer review of all High Carbon Stock (HCS) assessments undertaken since April 2015 by the HCSA Quality Assurance Process?

This indicator is disabled as the company does not operate rubber plantations.

83. Commitment to conduct social and environmental impact assessments (SEIAs)?

84. Commitment to conduct social and environmental impact assessments (SEIAs) applies to all suppliers?

85. Social and environmental impact assessment (SEIAs) undertaken, and associated management and monitoring plans?

86. Commitment to no planting on peat of any depth?

This indicator is disabled as the company does not operate rubber plantations.

87. Commitment to no planting on peat of any depth applies to all suppliers?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits all suppliers to no planting on peat of any depth.

88. Landbank or planted area on peat (ha)?

This indicator is disabled as the company does not operate rubber plantations.

89. Implementation of commitment to no planting on peat of any depth?

This indicator is disabled as the company does not operate rubber plantations.

90. Commitment to best management practices for soils and peat?

This indicator is disabled as the company does not operate rubber plantations.

91. Commitment to best management practices for soils and peat applies to all suppliers?

The company commits its suppliers to only a limited section of practices for soils, which includes protection against soil erosion, nutrient degradation, subsidence and contamination, and other degradation of soil quality, as a result of supplier's action or activity. A clear commitment to best management practices for soils and peat is not reported by the company.

92. Evidence of best management practices for soils and peat?

This indicator is disabled as the company does not operate rubber plantations.

93. Commitment to best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

94. Commitment to best/sustainable tapping practices applies to all suppliers?

The company only reports that its suppliers must offer or support training to the smallholders that supply them with raw materials with cultivation practices such as clone usage, fertilizer application, tree density and tapping techniques. A clear commitment to best tapping practices that is applicable to all suppliers is not reported by the company.

95. Evidence of best/sustainable tapping practices?

This indicator is disabled as the company does not operate rubber plantations.

96. Commitment to zero burning?

This indicator is disabled as the company does not operate rubber plantations.

97. Commitment to zero burning applies to all suppliers?

The company commits its suppliers to "avoid" the use of open burning/fire in new or ongoing land-use operations. A clear commitment is not reported by the company.

98. Evidence of fire monitoring and management?

This indicator is disabled as the company does not operate rubber plantations.

99. Details/number of hotspots/fires in company estates/management units?

This indicator is disabled as the company does not operate rubber plantations.

100. Details/number of hotspots/fires in suppliers operations/jurisdictions?

101. Time-bound commitment to reduce greenhouse gas (GHG) emissions intensity?

The company commits to reduce GHG emissions intensity by 25% by the year 2023.

102. GHG emissions intensity?

The company reports global GHG emissions intensity (scope 1 and scope 2) (tonnes CO2e/ton) as 0.68 for the year 2021.

103. GHG emissions from land use change?

This indicator is disabled as the company does not operate rubber plantations.

104. Progress towards commitment to reduce GHG emissions intensity?

The company reports progress over time for global GHG emissions intensity (scope 1 and scope 2) (tonnes CO2e/ton) for 2021 as 0.68, for 2020 as 0.721, and for 2019 as 0.740. However, the information reported is not externally verified.

105. Methodology used to calculate GHG emissions?

The company reports it uses the WBCSD and World Resources Institute (WRI) GHG protocol for calculating emissions.

106. Time-bound commitment to improve water use intensity?

The company has already achieved its target in 2021 by reducing 17% of its water usage. No further target has been set by the company.

107. Water use intensity?

1192 - The company reports 'Global Water Usage (Gal/Ton)' for 2021 as 1,192.

108. Progress towards commitment on water use intensity?

The company reports that in 2021, it reduced its global water usage by 17% compared to 2020, using 1,691 gallons of water per ton of production at its tyre and chemical manufacturing sites. However, the information reported is not externally verified.

109. Time-bound commitment to improve water quality (BOD or COD)?

110. Progress towards commitment on water quality (BOD or COD)?

111. Treatment of effluents from processing facilities?

This indicator is disabled as the company does not operate rubber plantations.

112. Treatment of effluents from manufacturing facilities?

113. Commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company does not operate rubber plantations.

114. Implementation of commitment to protect natural waterways through buffer zones?

This indicator is disabled as the company does not operate rubber plantations.

115. Reducing odours from natural rubber processing or manufacuring facilities?

The company only reports controlling odours from natural rubber production. Clear information on treatment of gas emissions from natural rubber manufacturing facilities to reduce negative effects of odour is not reported by the company.

116. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers?

This indicator is disabled as the company does not operate rubber plantations.

117. Commitment to minimise the use of chemicals, including pesticides and chemical fertilisers, applies to all suppliers?

The company commits all suppliers to minimise the use of chemical fertilisers and pesticides.

118. Commitment to no use of paraquat?

This indicator is disabled as the company does not operate rubber plantations.

119. Commitment to no use of paraquat applies to all suppliers?

120. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides?

This indicator is disabled as the company does not operate rubber plantations.

121. Commitment to no use of World Health Organisation (WHO) Class 1A and 1B pesticides applies to all suppliers?

122. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention?

This indicator is disabled as the company does not operate rubber plantations.

123. Commitment to no use of chemicals listed under the Stockholm Convention and Rotterdam Convention applies to all suppliers?

124. Chemical usage per ha or list of chemicals used?

This indicator is disabled as the company does not operate rubber plantations.

125. Implementation of commitment to minimise inorganic fertiliser usage?

This indicator is disabled as the company does not operate rubber plantations.

126. Integrated Pest Management (IPM) approach?

This indicator is disabled as the company does not operate rubber plantations.

127. Commitment to human rights?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company commits to the Universal Declaration of Human Rights.

128. Commitment to human rights applies to all suppliers?

The company commits all suppliers to the Universal Declaration of Human Rights.

129. Progress on human rights commitment ?

In 2021, the company reports it trained 340 associates on human rights policies/procedures and launched Human Rights Steering Committee. The information is not externally verified.

130. Commitment to respect Indigenous and local communities' rights?

This indicator is disabled as the company does not operate rubber plantations.

131. Commitment to indigenous and local communities' rights applies to all suppliers?

The company commits suppliers to the UN Declaration on the Rights of Indigenous Peoples.

132. Commitment to respect legal and customary land tenure rights?

This indicator is disabled as the company does not operate rubber plantations.

133. Commitment to legal and customary land rights applies to all suppliers?

The company commits all suppliers to respect legal and customary land tenure rights.

134. Commitment to free, prior and informed consent (FPIC)?

This indicator is disabled as the company does not operate rubber plantations.

135. Commitment to free, prior and informed consent (FPIC) applies to all suppliers?

The company commits all suppliers to respect FPIC.

136. Details on Free, prior and informed consent (FPIC) process available?

This indicator is disabled as the company does not operate rubber plantations.

137. Examples of local stakeholder engagement to prevent conflicts?

This indicator is disabled as the company does not operate rubber plantations.

138. Details of process for addressing land conflicts available?

This indicator is disabled as the company does not operate rubber plantations.

139. Supports the inclusion of women across natural rubber operations, including addressing barriers faced?

This indicator is disabled as the company does not operate rubber plantations.

140. Commitment to mitigate impacts on food security?

This indicator is disabled as the company does not operate rubber plantations.

141. Progress on commitment to mitigate impacts on food security?

This indicator is disabled as the company does not operate rubber plantations.

142. Commitment to provide essential community services and facilities?

This indicator is disabled as the company does not operate rubber plantations.

143. Progress on commitment to provide essential community services and facilities?

This indicator is disabled as the company does not operate rubber plantations.

144. Commitment to provide business/work opportunities for local communities?

This indicator is disabled as the company does not operate rubber plantations.

145. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company commits to all Fundamental ILO Conventions.

146. Commitment to Fundamental ILO Conventions or Free and Fair Labour Principles applies to all suppliers?

The company commits all suppliers to all Fundamental ILO Conventions.

147. Progress on commitment to respect all workers' rights?

148. Commitment to eliminate gender related discrimination with regards to employment?

The company commits to prevent employment-related discrimination based on gender.

149. Commitment to eliminate gender related discrimination with regards to employment applies to all suppliers?

The company commits all suppliers to prevent employment-related discrimination based on gender.

150. Progress on commitment to eliminate gender related discrimination with regards to employment?

In 2021, the company reported more than 96% of its associates completed online training courses on such subjects as workplace respect, discrimination and harassment. However, limited information reported and not externally verified.

151. Percentage or number of temporary employees?

885 - The company reports 885 temporary associates (male-646, female-239) out of the total 59,984 associates in 2021.

152. Percentage or number of women employees?

13% - In 2021, the company reports 13% of its workforce are women.

153. Commitment to pay a living wage?

The company commits to comply with applicable wage and hour labour laws, including those related to minimum wage, overtime and legally mandated benefits. A clear commitment to pay a living wage is not reported by the company.

154. Commitment to pay a living wage applies to all suppliers?

Compliance with applicable wage and hour labour laws, including those related to minimum wage, overtime and legally mandated benefits. Suppliers should promote and support decent living wages in their supply chains.

155. Progress on commitment to pay a living wage?

156. Reporting of salary by gender?

157. Commitment to address occupational health and safety?

The company commits to address health and safety at work for all workers.

158. Commitment to address occupational health and safety applies to all suppliers?

The company commits all suppliers to address health and safety at work for all workers.

159. Provision of personal protective equipment and related training?

The company only mentions providing protective equipment as required under applicable local law in its natural rubber procurement policy. No dated evidence of the company providing personal protective equipment (PPE) and related training is not reported by the company.

160. Time lost due to work-based injuries?

The company reports a serious injury rate (rate based on 200,000 hours worked) as 0.02 in 2021.

161. Number of fatalities as a result of work-based accidents?

0 - The company reports zero work-related fatalities in its operation.

162. Commitment to support smallholders?

The company makes this commitment through the GPSNR Policy Framework. Full points have therefore been awarded on the basis of the company's alignment with GPSNR Policy Components that fully meet the SPOTT indicator criteria. The company also commits to support smallholders in its natural rubber procurement policy.

163. Percentage of supply from smallholders?

The company reports 45% of 2021 procurement spend on raw materials was from local suppliers. However, it is unclear if the local suppliers refer to smallholders.

164. Programme to support scheme smallholders/outgrowers?

The company reports it supports its suppliers of natural rubber using, and educating smallholders within their supply chain with, cultivation practices in the field to ensure maximum yield and quality are obtained from existing planted and replanted natural rubber trees. However, the type of smallholders supported is unclear.

165. Percentage of scheme smallholders/outgrowers involved in programme?

166. Programme to support independent smallholders?

The company reports it supports its suppliers of natural rubber using, and educating smallholders within their supply chain with, cultivation practices in the field to ensure maximum yield and quality are obtained from existing planted and replanted natural rubber trees. However, the type of smallholders supported is unclear.

167. Percentage of independent smallholders involved in programme?

168. Process used to engage smallholder suppliers on compliance with company's policy and/or legal requirements?

169. Number or percentage of smallholder suppliers engaged on compliance with company's policy and/or legal requirements?

170. Process used to prioritise, assess and/or engage non-smallholder suppliers on compliance with company's policy and/or legal requirements?

The company reports that its business decisions consider supplier's commitment and compliance to its rubber policy and requirements. This is assessed periodically through a supplier scorecard, which includes the sustainability scoring obtained through company audits. Material produced and processed in accordance with the rubber policy is preferred. Supplier's failure to comply with company's policy would require a time-bound implementation plan to work towards compliance. Substantiated noncompliance and/or failure to close agreed identified gaps in compliance may result in suspension or termination of the business relationship.

171. Number or percentage of non-smallholder suppliers assessed and/or engaged on compliance with company's policy and/or legal requirements?

The company reports that 184 suppliers were assessed for social and environmental impacts and 100% of new suppliers were screened using environmental and social criteria. Data as of 2021.

172. Suspension or exclusion criteria for non-smallholder suppliers?

The company reports that substantiated noncompliance and/or failure to close agreed identified gaps in compliance with the rubber policy of the company may result in suspension or termination of the business relationship with the suppliers.

173. Time-bound action plans (including Key Performance Indicators) for suppliers to be in compliance with natural rubber sourcing commitments?

174. Proportion of direct and indirect supply from third-parties that comes from natural rubber plantations which are compliant with natural rubber sourcing policies?

175. Percentage of supply coming from agroforestry?

176. Commitment to ethical conduct and prohibition of corruption?

The company commits to ethical conduct and the prohibition of corruption.

177. Commitment to ethical conduct and prohibition of corruption applies to all suppliers?

The company commits all suppliers to ethical conduct and the prohibition of corruption.

178. Progress on commitment to ethical conduct and prohibition of corruption?

The company reports it conducts compliance and ethics training for all its employees. In 2021, more than 96% of associates completed online training courses on anti-corruption and anti-bribery. Additionally the company reports it has organised a compliance awareness campaign. The company has an integrity hotline which can be used to report any actual, suspected, or potential misconduct to management. All the information reported is not externally verified.

179. Disclosure of the company’s management approach to tax and payments to governments?

The company gives limited detail on tax strategy and it is unclear who is responsible for the strategy and its review.

180. Whistleblowing procedure?

The company reports to have an integrity hotline and details the steps involved in reviewing concerns including how whistleblowers are protected.

181. Own grievance or complaints system open to all stakeholders?

The company has an EthicsPoint webpage with a form open to all stakeholders to report complaints and grievances.

182. Details of complaints and grievances disclosed?