Kumho Tire

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 a policy for sustainable natural rubber, however, it is unclear if this policy applies to all suppliers of the company.

3. High-level position of responsibility for sustainability?

The company reports it has an 'ESG Management Committee' in place responsible for decision-making on key ESG issues. This committee comprises a total of 11 members, with the CEO participating as the chair and the heads of major divisions participating as members. However, the high-level responsibility for sustainability within this committee, excluding the board members is unclear.

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

The company reports its ESG Committee is composed of three directors (1 executive and 2 independent directors) and seeks to strategically and systematically manage the environmental, social, and governance sectors.

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

The company reports the number of female executives, research fellows, senior managers, and managers collectively as 76 (8.19%) in 2022. However, this information only covers the company's employees in Korea and doesn't include exclusive information for female senior managers.

6. Percentage or number of women board members?

11% - The company reports one woman director on its board out of the total nine board of directors. Data as of 2022.

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

[Externally verified] UNGC, WBCSD, and WBSD Tire Industry Project.

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

9. Sustainability report published within last two years?

The company's latest sustainability report was published in 2023, covering the year 2022.

10. Reports through standardised reporting systems?

The company has submitted its Climate Change and Water Security 2023 CDP Questionnaire. The company's reporting for GRI only states to be in accordance with GRI standards 2021, however, the company's report was prepared after January 2023 and does not refer to GRI 101: Foundation requirements.

11. Climate risks assessment available?

The company has conducted and published an assessment of climate-related risks including actual and potential impacts of climate change on the company; metrics, targets, and processes used to assess or manage climate risks; responsibilities. However, the information reported is not externally verified.

12. Lists countries and operations?

Manufacturing (China, USA, Vietnam, the Republic of Korea).

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 all scheme/outgrower smallholders?

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

23. Maps 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. Maps 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 company owned natural rubber manufacturing facilities?

The company reports it operates eight manufacturing plants.

30. Maps of manufacturing facilities?

The names and locations of all eight manufacturing plants of the company are available. However, only a few of them generate locations on Google Maps.

31. Number of third party supplying processing facilities?

32. Maps of all third party supplying processing facilities?

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

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

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

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

37. Percentage of supply traceable to processing facility level?

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

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

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

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

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

42. 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.

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

44. 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.

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

46. Percentage area (ha) FSC certified?

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

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

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

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

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

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

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

50. 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 or processing facilities.

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

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

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

53. Certified under voluntary sustainability certification scheme?

The company is 100% ISO 14001 certified. A higher score cannot be awarded as the certificates are not publicly available and neither is the ISO audit criteria.

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

The company's production facilities are only 100% ISO14001 certified. A higher score cannot be awarded as ISO audit criteria are not publicly available.

55. Commitment to zero conversion of natural ecosystems?

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

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

57. Commitment to zero deforestation?

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

58. 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's reporting states to not procure natural rubber produced in areas where deforestation or degradation of conservation values has occurred after April 1, 2019.

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

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

60. Criteria and cut-off date for defining deforestation and/or ecosystem conversion 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's reporting states to not procure natural rubber produced in areas where deforestation or degradation of conservation values has occurred after April 1, 2019.

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

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

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

63. 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.

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

65. Commitment to restoration of deforestation/conversion in own operations since cut-off date?

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

66. Commitment to restoration of deforestation/conversion in supplier operations since cut-off date?

The company only states to support the restoration of rubber farming areas that have been deforested or damaged. However, a clear commitment to restore ecosystems and their values to their prior condition and provide suitable compensation to restore these values in the case of deforestation or conversion applicable to all suppliers could not be found.

67. 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. A public commitment could not be found by ZSL.

68. Biodiversity policy?

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

69. Biodiversity policy applies to all suppliers?

70. 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.

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

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

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

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

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

The company commits to allowing sustainable hunting of species by local communities for subsistence purposes in their operations. However, it is unclear if this commitment applies to all suppliers.

74. Commitment to protect areas from illegal activities?

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

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

76. Evidence of protecting forest areas from illegal activities?

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

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

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

78. 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's reporting states it adheres to methodologies and guidelines that align with the HCV (High Conservation Values) and HCSA (High Carbon Stock Approach) approaches for identifying and managing development and conservation areas. However, it is unclear if this applies to all suppliers.

79. 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.

80. 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.

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

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

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

The company reports it adheres to methodologies and guidelines that align with the HCV (High Conservation Values) and HCSA (High Carbon Stock Approach) approaches for identifying and managing development and conservation areas. However, it is unclear if this applies to all suppliers.

83. High Carbon Stock (HCS) assessments available?

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

84. 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.

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

The company only commits to conducting environmental impact assessments.

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

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

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

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

89. 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's reporting only states that it does not engage in or source natural rubber from peat-based rubber farms.

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

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

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

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

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

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

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

The company only states that it is committed to protecting soil quality and preventing erosion, nutrient depletion, subsidence, and contamination. No commitment to best management practices for both soil and peat was found. Also, it is unclear if this commitment applies to all suppliers.

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

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

95. Commitment to best/sustainable tapping practices?

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

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

97. Evidence of best/sustainable tapping practices?

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

98. Commitment to zero burning?

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

99. Commitment to zero burning applies to all suppliers?

The company commits to no burning, however, it is unclear if this commitment applies to all suppliers.

100. Evidence of fire monitoring and management?

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

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

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

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

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

The company commits to reduce GHG emissions (Scope 1 and 2) by 23.6% compared to 2021 by 2030.

104. GHG emissions?

The company reports its GHG emission intensity (Scope 1 and Scope 2) for domestic and overseas operations as 0.9212 tCO2eq/ton in 2022.

105. GHG emissions from land use change in company's own operations (scope 1)?

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

106. GHG emissions from land use change in supplier operations (scope 3)?

107. Progress towards commitment to reduce GHG emissions?

[Externally verified] The company reports a reduction in GHG intensity (Scope 1 and Scope 2) in 2022 (0.9212 tCO2eq/ton) as compared to 2021 (0.9842 tCO2eq/ton). Evidence for domestic operations is externally verified by Creative Sustainable Registar (CSR) and information for overseas operations is externally verified by Korean Foundation for Quality (KFQ).

108. Methodology used to calculate GHG emissions?

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

110. Water use intensity?

4.286 - The company reports water consumption intensity for its domestic as well as overseas operations as 4.286 Tons (water weight) / ton (production weight) in 2022.

111. Progress towards commitment on water use intensity?

The company's water consumption intensity (Tons (water weight) / ton (production weight)) has decreased in 2022 (4.286) as compared to 2021 (4.932). However, the information reported is not externally verified.

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

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

Domestic BOD levels have declined from 0.631 (2021) to 0.442 (2022), however, no COD levels were reported for domestic operations in 2022. Overseas COD levels have increased from 10.499 (2021) to 16.341 (2022). The company commits to keep water pollutants below 50% of the legal limit. However, the legal limits are not reported by the company to monitor progress.

114. Treatment of effluents from processing facilities?

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

115. Treatment of effluents from manufacturing facilities?

The company reports it has wastewater treatment plants at its manufacturing facilities where the wastewater and sewage are discharged into the water bodies after going through physical and biochemical treatment. However, the information reported is not externally verified.

116. Commitment to protect natural waterways through buffer zones?

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

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

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

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

[Externally verified] The company reports it regularly measures air pollutants such as dust, NOX (nitrogen oxides), SOX (sulfur oxides), and odors generated during the production process, and manages emissions in accordance with internal standards that are stricter than legal limits. Evidence is externally verified by the Korea Management Registrar (KMR).

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

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

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

121. Commitment to no use of paraquat?

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

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

123. 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.

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

125. 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.

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

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

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

128. Implementation of commitment to minimise inorganic fertiliser usage?

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

129. Integrated Pest Management (IPM) approach?

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

130. 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 also reports its commitment to the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights.

131. Commitment to human rights applies to all suppliers?

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

132. Progress on human rights commitment?

The company surveyed 334 stakeholders for human rights impact assessments to identify risk factors in its operations. Evidence is not externally verified.

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

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

134. Commitment to Indigenous and local communities' rights applies to all suppliers?

The company commits to the UN Declaration on the Rights of Indigenous Peoples. However, it is unclear if this commitment applies to all suppliers.

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

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

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

The company only commits to respecting customary, traditional, and communal land tenure rights of Indigenous peoples and local communities. However, it is unclear if this commitment applies to all suppliers and a commitment to legal rights is not reported.

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

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

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

The company commits to free, prior, and informed consent (FPIC), however, it is unclear if this commitment applies to all suppliers.

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

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

140. Examples of local stakeholder engagement to prevent conflicts?

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

141. Details of process for addressing land conflicts available?

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

142. 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.

143. Commitment to mitigate impacts on food security?

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

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

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

145. Commitment to provide essential community services and facilities?

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

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

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

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

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

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

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. GPSNR does not reference all Fundamental ILO Conventions as amended in 2022 to include the Occupational Safety and Health Convention, 1981 (No. 155) and the Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187). The company's reporting only covers commitment to eight core ILO conventions.

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

The company only commits to eight core ILO Conventions and it is unclear if this applies to all suppliers.

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

The company reports it operates labor-management consultation systems such as the Labor-Management Council, Collective Bargaining, Employment Security·LaborManagement Joint Development Committee, strengthening job security and the competitiveness both of the company and employees. As of 2022, the company reports having four labor unions in operation. This information is not externally verified.

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

The company provides a commitment to eliminate gender related discrimination with regards to employment.

152. 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.

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

The company reports that all employees take mandatory training on preventing sexual harassment and harassment at the workplace, however no figures on how many members of staff have been trained has been reported. Evidence is not externally verified.

154. Percentage or number of temporary employees?

The company only reports the total number of non-regular workers for its domestic operations. However, this information does not cover all employees of the company and is from 2021.

155. Percentage or number of women employees?

4.2% - The company reports 232 (4.20%) women employees in its domestic operations as of 2022. The number or percentage of women in the company's overseas operations is not reported.

156. Commitment to pay a living wage?

The company provides a commitment to pay a living wage.

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

The company commits to paying a decent living wage. However, it is unclear if this commitment applies to all suppliers.

158. Progress on commitment to pay a living wage?

159. Reporting of salary by gender?

160. Commitment to address occupational health and safety?

The company provides a commitment to address occupational health and safety.

161. 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.

162. Provision of personal protective equipment and related training?

The company only provides evidence of hazardous chemical training in relation to natural rubber operations.

163. Time lost due to work-based injuries?

The company reports the accident rate for the whole group as 6% in 2022.

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

The company reports zero fatalities in 2022.

165. 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 reports its own commitment to supporting smallholders.

166. Percentage of supply from smallholders?

167. Programme to support scheme smallholders/outgrowers?

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

169. Programme to support independent smallholders?

170. Percentage of independent smallholders involved in programme?

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

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

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

The company reports it has a supply chain ESG assessment process to assess non-smallholder suppliers on compliance with the company's legal requirements.

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

79% - The company reports that 159 (79%) companies completed ESG assessments in 2022. However, this information does not cover all suppliers of the company.

175. Suspension or exclusion criteria for suppliers?

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

177. Proportion of supply from suppliers that is verified as deforestation- and/or conversion-free (DCF)?

178. Percentage of supply coming from agroforestry?

179. Commitment to ethical conduct and prohibition of corruption?

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

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

The company only commits suppliers to ethical conduct.

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

[Externally verified] The company reports it conducts compliance and corruption risk assessments. In 2022, the company conducted 17 ethical audits and 100% of its employees completed training on the company's Code of Ethics. Evidence is externally verified by the Korea Management Registrar (KMR).

182. Disclosure of the company's management approach to tax and payments to governments?

The company has published its tax policy. However, information on the governance body that is responsible for the tax policy and its review is not reported.

183. Whistleblowing procedure?

The company has its whistleblowing procedure in place.

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

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. The company also has its grievance system in place, however, it is only accessible to internal stakeholders and details of the process are not reported.

185. Details of complaints and grievances disclosed?

The company reports that a total of 42 reports were received in 2022. However, the details of the complaints are not disclosed.