Environmental, Social and Governance Policy

1  Introduction

1.1 Purpose  This document presents Getronics’ policy for Environmental, Social and Governance as advocated by Standard ISO 26000, Guidance on Social Responsibility. Getronics also reports against the Sustainability Accounting Standards Board (SASB) reporting standards.   ESG is defined as the environmental, social and governance responsibility of an organisation for the impacts of its decisions and activities on society and the environment, through transparent and ethical behaviour that: 

• Contributes to sustainable development, including the health and welfare of society  
• Takes into account the expectations of stakeholders 
• Is in compliance with applicable law and consistent with international norms of behaviour 
• Is integrated throughout the organisation and practiced in its relationships

  Standard SA8000, Social Accountability (published by Social Accountability International) also covers much of the scope of ISO 26000, with its emphasis on human and employment rights and health and safety in the workplace. However, Getronics has adopted ISO 26000 as it also focusses on community interests and environmental matters ISO14001, which are important additional aspects of its operations. 

1.2 Environmental Social and Governance Responsibility Framework 

As defined within ISO 26000, a social responsibility framework needs to consider the following key elements: 

• Stakeholders: those people or groups that are affected by the organisation’s actions, and can include workers, customers, suppliers, community residents, and investors 
• Environmental Social and Governance Disclosure Topics: core subjects that the organisation needs to focus upon to ensure a socially responsible strategy – these include organisational governance, human rights, labour practises, environment, fair operating practices, consumer issues community involvement, etc.  
• Reporting: communicating to stakeholders the organisation’s level of achievement of its policies and initiatives for promoting social responsibility and the status and results of improvement activities  

  Getronics has adopted this framework for its approach to social responsibility; the next page contains a social responsibility policy statement in support of this.    2. Getronics’ Environmental Social And Governance Responsibility Policy Statement Getronics takes its social responsibility seriously and has adopted a number of principles that form the foundation for a socially responsible behaviour of the Company: 

• Accountability: Getronics is answerable for the overall impact of its decisions and activities to those affected and to society in general 
• Transparency: Getronics will disclose to interested parties the policies for which it is responsible and ensure that its decisions and activities will not be detrimental to society 
• Ethical behaviour: Getronics’ behaviour is based on the ethics of honesty, equality and integrity 
• Respect for Stakeholder Interests: Getronics will consider the interests of internal and external parties that may be impacted by its decisions and activities 
• Respect for the Rule of Law: Getronics will comply with applicable laws and regulations and will ensure that its staff are aware of appropriate legislative requirements 

• Respect for International Norms of Behaviour: Getronics respects international norms of behaviour and will not benefit from unfair acts 
• Respect for Human Rights: Getronics respects and encourages rights set out in the International Bill of Human Rights. 

  To support these principles, Getronics has established a number of policies and procedures that are published within its management systems to ensure ethical, socially acceptable, environmentally responsible, and legally compliant working practices.  3. Getronics’ Environmental Social and Governance Responsibility Values Getronics has adopted the Environmental Social and Governance responsibility framework stated previously, with values that are described within the sections below that include examples to illustrate how Getronics addresses its social responsibility values.  References to further information, policies, or processes that are contained within its management systems are also included. The main one of these is a Policies & Procedures portal that is available to all colleagues and contains management system operational policies and processes and provides links to other portals, such as HR Policies.  3.1 Stakeholders  Getronics’ main stakeholders that can be affected by the organisation’s actions are:  3.1.1 Colleagues who have an employment contract  Throughout their terms of employment with Getronics, all colleagues who have an employment contract with Getronics and contractors are subject to a set of policies and processes to ensure that they are treated fairly, they treat others fairly, and they understand the Company’s policies and expectations in their conduct and its legal and social responsibilities.   This commences with the new starter process that covers recruitment, pre-employment vetting, employment contract including terms and conditions, and provision of formal company induction. During employment, regular performance reviews and objective setting are undertaken.   Some of the policies and processes that apply to colleagues include: 

• Joiners, Movers, Leavers Process 

• Bullying and Harassment Policy 
• Disciplinary Policy and Procedure 
• Flexible Working Policy 
• Grievance Policy and Procedure 
• Maternity Policy 

• Parental Leave Policy 
• Paternity Leave Policy 
• Performance Improvement Policy 
• Attendance Management Policy 
• Working Time Regulations 

• Equal Opportunities and Diversity Policy. 

  3.1.2 Customers Getronics provides managed services to its customers, which can include managed cloud provision, data centre hosting services, provision of service desks, mobile break-fix, IT infrastructure support, desktop support, and service delivery management. Each customer account has a Client Manager/Director and a Customer Success Manager (CSM) assigned to ensure that the requirements of the contract are fully met, and that customer satisfaction and service improvement are key considerations.  Processes that apply to the provision of customer services are delivered under the Company’s ISO 9001 (Quality Management) and ISO 20000 (IT Service Management) registered management systems and include: 

• Customer Complaints Process 
• Getronics Service Management Plan 
• Business Relationship Management Process 
• Continual Service Improvement Programme Process 
• Customer Satisfaction Process
• Operational Escalation Process 
• Service Level Management Process. 

  3.1.3 Partners and Suppliers This group primarily includes members of the Getronics Workspace Alliance (GWA), which is an alliance of a number of global IT service providers. The GWA is designed to combine the value of experienced national providers with a consistent international service methodology, with a specific focus on workspace outsourcing.   It also includes suppliers of services directly to Getronics, which are required to comply with a supplier code of conduct to operate in a socially responsible manner; this is backed-up by performance reviews carried out by the Procurement Team as defined in: 

• Procurement Policy.

3.1.4 Community Residents Getronics operates from several locations globally, mainly within office environments; in many cases, they are located within business parks.   However, Getronics endeavours to minimise its impact on its community, by restricting the use of outside lighting, ensuring that any CCTV systems in operation do not overlook beyond premises boundaries and ensuring that noise levels are kept to a minimum. 3.1.5 Investors Getronics is owned by the Kennic Trust and various investors and is not a publicly listed company. However, Getronics needs to operate in an economically viable manner to achieve EBITDA targets and satisfy its stakeholder expectations. Getronics has invested in the development of next-generation IT services, such as the provision of its cloud-based managed services, as well as providing IT service management and hosting services.   3.2 Disclosure topics Getronics focuses on the following core disclosure topics as part of the Environmental, Social and Governance strategy. Disclosure topics are publicly reported on yearly and closely monitored through specific KPIs during the reporting time-frame.   3.2.1 Environment Disclosure Topics  3.2.1.1. Carbon footprint  Carbon footprint refers to the amount of carbon dioxide released into the atmosphere as a result of the activities of a particular organization. Carbon footprint disclosure topic includes Scope 1,2 & 3 emissions. Scope 1 and 2 emissions cover everything that is in Getronics direct operational control such as: 

• Scope 1 e.g.: Fuel Combustion, Owned transport, Process emissions, Fugitive emissions 
• Scope 2 e.g.: Purchased electricity, heat and steam 

  Scope 3 emissions cover emissions outside of own operations, and not the result of activities from assets owned or controlled by Getronics, but by those that it’s indirectly responsible for, up and down its value chain.  Getronics is committed to calculating a reasonable Carbon footprint based on real time data such as e.g.: electricity bills, owned transport mileage and fuel consumption, etc; where such data is in our direct control. Getronics also operates in managed service type of offices where there is no visibility or control on direct consumption, nonetheless we strive to minimise our carbon footprint in such environments. Getronics is committed to engaging with our suppliers to provide accurate data for Scope 3 emissions.   3.2.1.2. Waste, including e-waste  Waste, including e-waste refers to the processes and actions required to manage, reduce & recycle waste from its inception to its final disposal. Getronics monitors waste produced data points such as waste recycled/diverted; landfilled waste and hazardous waste where such data points are in our direct control. Getronics strives to engage with waste processors that are environmentally conscious and preserve the same values as Getronics regarding responsible operations.     3.2.1.3. Water Conservation  Water conservation refers to the practice of using water efficiently to reduce unnecessary water usage. Getronics monitors water consumption data in the locations where direct supplier contracts for water supply are in place. Getronics is committed to minimize water consumption in all water stress areas where it operates by engaging in discussions with landlords over measures that can be implemented to facilitate water consumption reduction and by training it’s staff on responsible water consumption.   3.2.2 Social Disclosure Topics  3.2.2.1. Data privacy   Data privacy refers to proper handling of sensitive data including, notably, personal data but also other confidential data, such as certain financial data and intellectual property data, to meet regulatory requirements.   Getronics recognizes that the correct and lawful treatment of Personal Data will maintain confidence in the organization and will provide for successful business operations critical responsibility that we always take seriously.  Getronics Data Protection Policy is kept under regular review and does not override any applicable national data privacy laws and regulations in countries where the Company operates.  The Group processes 3 main types of personal and confidential data:  

• Colleagues who have an employment contract with Getronics and contractor personal data. 
• Customer personal data (i) collected for our own use e.g. contract and billing and (ii) for data processing via the provision of the Portfolio services. 
• Other stakeholders (i) Marketing data of prospective customers (ii) vendor data. 

  3.2.2.2. Data security   Data Security refers to protecting digital information from unauthorized access, corruption, or theft throughout its entire lifecycle.  Getronics upholds the Information Security Management System (ISMS) policy at Group Level as part of the ISO 27001:2013 certification.   The Information Security Management System (ISMS) policy requires that the Getronics ISMS reliably delivers the appropriate IT services, establishing guidelines and  procedures necessary  to  ensure  security  confidentiality,  integrity,  availability  and  privacy  of  the information and data.  Getronics is committed to following best practices and standards within the industry. For this purpose, various certifications are maintained. These can be found at: https://www.getronics.com/policy-pages/iso-itil/. Business partners and description can be found here: https://www.getronics.com/partners/  3.2.2.3. Inclusion, Diversity and Equal Opportunity   Inclusion, Diversity and Equal Opportunity refers to fair treatment and opportunity for all colleagues while eradicating prejudice and discrimination based on an individual or group of individual’s gender, race, sexual orientation, religious beliefs, and the practice of ensuring that people feel a sense of belonging and support from the organization.   At Getronics we want to celebrate diversity across all parts of the business. Our objective is to build a “safe” place for our staff by creating an open, respectful, empathic, fair, and inclusive place to work. When considering this topic, we closely monitor aspects such as: recruiting, pay, career growth, reward systems, management behaviour, and much more.  3.2.2.4. Employee Wellbeing & Engagement   Employee Wellbeing & Engagement refers to colleague wellness, including physical health, emotional or psychological well-being, community or social relationships, and financial stability and the ability for colleagues to be present, focused, and energized, while feeling connected to their organization’s purpose. We closely monitor the initiatives we implement in order to ensure our colleagues wellness and we routinely engage with our colleagues to understand their level of engagement within the organization, through exercises such as Employee Engagement Surveys.   3.2.2.5. Talent Attraction, Retention & Development  Talent Attraction, Retention & Development refers to the ability of an organization to present itself as an employer of choice and retain top talent through career growth opportunities and fair, competitive, and transparent recognition and reward systems. We closely monitor KPIs that are relevant to our capacity to attract and retain talent within the organization such as: offer acceptance rate, attrition, no of hour of training, etc.   3.2.2.6. Fair labor practices  Fair labour practices refers to the commitment of an organization to respect standard conventions regarding workers, in matters of basic worker rights, working conditions, wages to be paid & also related to job security, in all its activities as well as when engaging with different partners or suppliers.  Getronics is committed to observing and respecting fair labor practices in accordance with the global as well as local legislation requirements in all the countries where we operate.   In order to ensure transparency and equality on different job roles with similar levels of seniority Getronics has adopted a job grading structure: The Job Family System Manual (JFS). All positions created within the organization are analyzed and placed within the specific job grading and remuneration and compensation are aligned with the specific job grade, while respecting local market trends and minimum wage legislation.   Getronics is committed to eradicating human exploitation from our supply chain. All Getronics suppliers must comply with the Getronics Business Code of Conduct as well as Supplier Code of Conduct.   Getronics engages with local labor consultancy companies or in house specialists to ensure all local labor legislation is being respected and in some of the countries, depending on organizational size we also work with workers councils, for example in France, Germany, Spain, Hungary, Belgium and Luxembourg.  In terms of job security Getronics generally engages the collaboration with its staff on indefinite work contracts with some exceptions based on the nature of the role and dictated by local legislation requirements.  3.2.2.7. Health & Safety  Health and Safety refers to regulations and procedures adopted by an organization intended to prevent accident or injury in workplaces or to safeguard and improve the mental health of colleagues.  Getronics is committed to high standards of health and safety in all its’ locations covering all of our colleagues and governs this through Getronics Health and Safety policy. Getronics ensures that colleagues, and others, are not put at risk and, as far  as reasonably practicable, the working environment is safe and does not pose a risk to health. Getronics also has Safety Committee appointed to ensure compliance with these principles.    3.2.2.8. Community Giving  Community Giving refers to the level at which an organization is involved in the community life through various acts of charity giving, volunteering and education support.  Getronics actively encourages it’s colleagues to participate in volunteering activities and regularly facilitates acts of charity giving for it’s colleagues.  3.2.2.9. Respecting Human Rights   Respecting Human Rights refers to the level at which an organization recognizes the value of each person, ensuring their dignity, safety and health, equal working conditions and promoting diversity.  Getronics endeavors to treat all individuals with respect and it ensures that it complies with all laws that apply to human rights, typically including:  

• Equal Pay  
• Disability Discrimination  
• Sex Discrimination  
• Race Relations  
• Employment Equality  

  The adoption of fair employment practices, ensuring safe working environments for colleagues and customers, and providing living wages to its colleagues, is fundamental to Getronics’ operation. Our supporting policies include:  

• Bullying and Harassment Policy 
• Flexible Working Policy   
• Grievance Policy   
• Working Time Regulations Policy 

  The Company operates Works Councils or Employee Consultative Forums as appropriate, with members representing a cross-section of the workforce to ensure that colleague concerns are communicated to Management and that Company policy changes and plans are discussed and reviewed before wider publication.  3.2.2.10. Responsible sourcing  Responsible sourcing is a voluntary commitment by companies to consider social and environmental considerations when managing their relationships with suppliers.  Getronics Supplier Selection is governed by our Procurement Policy and is led by the Vendor Management Organization, in a joint discussion with the requestor. 3.2.3 Governance Disclosure Topics  3.2.3.1. Ethics & Integrity  Ethics and Integrity refers to the rules and regulations that an organization has in place to ensure the company as well as individuals within the organization work in accordance with moral principles, honesty and fairness. This topic also refers to Intellectual Property & Competitive Behavior, as well as Legislation & Regulation Adherence.  Getronics Code of Business Conduct (COBC) prevents occurrences of violence, discrimination or harassment in the workplace by raising awareness, sharing prevention strategies and identifying when action is required and what actions to take to maintain an inclusive work environment. Our COBC includes:  

• Tax evasion and money laundering; 
• Bribery and corruption;  
• Human rights violations;  
• Discrimination, bullying or harassment;  
• Retaliation and speaking up safely. 
• Mitigating Anti-Corruption, Anti-Bribery, Anti-Money Laundering 

  At Getronics we are committed to managing and counteracting the potential risk of financial crime including bribery, tax evasion, corruption, money laundering, extortion and kickbacks through the deployment of our policies, systems, financial and other controls, training and awareness for our colleagues, which we believe is appropriate for our industry and which meets the legal and regulatory requirements.   3.2.3.2. Enabling Clients’ Sustainability  Enabling Clients’ Sustainability refers to key sustainability initiatives and planned improvements, in order to achieve reduction of client environmental impact derived from our services.  To ensure Getronics is helping our customers on sustainability issues we closely monitor several KPIs such as: Environmental standards implemented; Environmental certifications achieved; Number of clients with Sustainability objectives in contract or SLA; Number of clients with Sustainability reporting in place  3.2.3.3. Transparency and Reporting  Transparency and Reporting refers to the way an organization creates access to proper disclosure of various financial as well as non-financial information, the consistency of data sources used to disclose as well as the reliability of data.  As a responsible corporate citizen, Getronics believes that open, honest engagement with its colleagues, investors, customers, vendors, and other stakeholders correlates to the long-term success and sustainability of the Group and strongly aligns with our values of authenticity, incorporating integrity, trust and honesty as core principles in all of our activities.  Our management adopts a continuous improvement mindset in its pursuit of excellence and as a result continues to enhance and refine its systems, processes and reporting capabilities in order to develop robust data and business insights, which are underpinned by high standards of governance and internal control. The Group maintains comprehensive risk registers at a consolidated group and regional level, including but not limited to commercial, legal, financial, tax and people risk.   The establishment of the Board, Executive Committee (ExCo), Operations Board and Investment Committee ensures that a culture of strong governance, accountability and internal controls not only exists but is embedded throughout the organization.  This culture and attitude to internal control is integral to the way that we compile, control and report data and other financial and non-financial information both internally and externally.  Such controls include: 

• Regional CFOs, supported by qualified financial controllers take accountability for their respective legal entity on a monthly basis; 
• The majority of Getronics Group legal entities maintain their financial records on the SAP ERP system; 
• The Group Financial Control team provides a monthly close timetable and controls checklist to all Regional Finance teams; 
• The use of the Hyperion Consolidation System is used to control the integrity of the financial consolidation process through an automatic upload file which ensures the integrity of information in the system; 
• The Group Financial Control team conducts a thorough month-end review of the Balance Sheet and Income Statement for each region; 

•  All balance sheet accounts are reconciled to underlying sub-systems monthly; 
• Once the monthly review is completed the Regional leadership teams (MDs, CFOs and Controllers) complete a monthly certification declaring the completion of the month end controls. 
• The Senior Leadership Team holds monthly business review meetings with each regional MD, CFO and relevant members of the regional business units to analyse and challenge business and financial performance, risk management and future trading expectations. 

  Our approach to the management of our tax affairs is fully aligned with the Group’s wider commercial, reputational and business practices.   This consists of the following: 

• Managing our tax affairs so as to protect shareholder value; 
• Complying with applicable tax laws, rules, regulations and disclosure requirements wherever we operate; 

• Paying the right amount of tax, at the right time, and in the right place around the world; 
• Use incentives and reliefs only for the purposes intended; 
• Only taking tax decisions which are with the wider objectives of the Group; 
• To be constructive and transparent with tax authorities, based on the concepts of integrity, collaboration and mutual trust. 

  Given both the scale and different aspects of our business, risks will inevitably arise from time to time.  However, we effectively manage these risks in a number of distinct ways:  

• The Group has appointed suitably qualified third-party tax advisers at the Group and jurisdictional level to ensure that it is abiding by the latest tax rules and regulations. 
• In each business region we have suitably qualified Financial Controllers and CFO’s who ensure that our tax principles are upheld.  
• Getronics takes a zero-tolerance approach to the facilitation of tax evasion in any form by its colleagues, agents, or associates of any kind.  
• We ensure that key members of the finance organization and our tax advisers are involved in all stages of material and/or tax sensitive transactions.  
• Material tax concerns are included in the overall Group risk register.  

  3.2.3.4. ESG Management  ESG Management refers to the way an organization governs the ESG process, educates its staff, integrates through management practices and reinforces its ESG framework in the daily activity of the company.  Getronics ESG governance process involves several types of actors:  

• Reporting Units Champions: Selected colleagues that are located in each of our offices and data centers, who are delegated to report on the monitored ESG KPIs.
• ESG Team: ESG designated team whose objective is to monitor the completion of ESG objectives and implement the governance process.  
• Executive Sponsors: representatives of the ESG agenda within the Board of Executives. 
• Business Owners: Selected managers of different business areas, which fall under the ESG framework, who own the responsibility of completing the ESG approved objectives in their own business area. 

  ESG Reporting Management Tooling  Getronics has implemented an automated reporting tool which facilitates access on sustainability and compliance data and enables regular reporting on ESG KPIs as well as auditable traceability of data.  The reporting tool facilitates: 

• Data collection from offices and data centers (60 reporting units) 
• Designated users in each reporting unit or per function. 
• ESG customized KPIs information collected on a regular basis 
• Real time reports extraction (quarterly/ biannually/yearly) 

• Assessment of top 250 suppliers on ESG related topics 
• Regular reassessment of suppliers 
• Continuous updates related to legislation changes/ new trends/ new requirements / best practices/ reporting frameworks 

  Getronics will issue a regular annual ESG report to all of its stakeholder consisting of the key findings on each of the disclosure topics presented within this policy.   3.2.3.5. Managing Systemic Risks from Technology Disruptions  Managing Systemic Risk from Technology Disruptions refers to the way an organization manages its infrastructure and the policies in place to minimize disruptions to services with the objective to be more resilient.  Getronics through its Business Continuity Management System (BCMS) is committed to minimizing the risk of business interruption through implementing processes, systems, and controls, as appropriate, and maintaining viable incident response, business continuity plans and information security continuity to respond to potential business disruptions.  This Business Continuity Management System applies to Getronics’ internal business group’s data assets, information systems, networks, applications, locations, and people required for the delivery of such services. It also applies to the provision and support of services offered to external clients where Business Continuity (BC) and IT Service Continuity (ITSCM) is explicitly included as part of our contractual obligations.  Getronics’ Business Continuity Management System covers:  

• Getronics Global Sites & Locations;
• Information Assets; 
• Infrastructure Supporting Client; 
• DR Provision for Client Systems; 
• IT Service Continuity Management; 
• Internal and Client Support Operation. 

  3.3 Reporting We are committed to being transparent with our investors, shareholders, and other stakeholders about Getronics ESG initiatives, successes, and goals. Our ESG report provides updates regarding our ESG program firm-wide on an annual basis. We value regular, frequent engagement with our stakeholders on ESG matters.  Getronics monitors a wide range of Key Performance Indicators (“KPIs”), reflecting the main ESG disclosure topics described within this policy. In addition to our annual ESG repot, regular internal reporting will be provided on a quarterly / biannual basis to facilitate management decisions, allow debate on objective completion progress and discuss new initiatives within the ESG framework.