Dear Stakeholders
In October 2012, SWIFT decided to support the ten principles of the Global Compact with respect to human rights, labor standards, protection of environment and anti-corruption and to advance those principles within our company.
We are pleased to confirm our continued support for the Global Compact and renew our ongoing commitment to the initiative and its principles.
Since the publication of our last Communication on progress, we took a series of practical actions, focused on reducing our impact on the environment, diversity, well-being at work and enhancing our Anti-Corruption and Anti-Bribery policy. These actions and the results are described in this Communication on Progress.
Sincerely yours,

Gottfried Leibbrandt
Chief Executive Officer
SWIFT

At SWIFT the principles of human rights are included in our code of conduct, which is formally acknowledged by all employees when they join SWIFT and again when changes to the code of conduct are made.
Reference to human rights principles, respect for diversity, social responsibility etc. are made on the SWIFT public website [http://www.swift.com/].
We have published a CSR Ethical and Environmental Obligations chart for suppliers which includes the obligation for suppliers to respect human rights.

To ensure proper and continued awareness of the code of conduct, which includes the human rights policy statements, SWIFT has implemented a tool that tracks employee acknowledgement of the code of conduct in an auditable manner. Additionally, an awareness training tool is available for staff to consult before they acknowledge the code of conduct. For new staff it is mandatory to go through this training module before they can acknowledge the code of conduct.
Since 2014, the Code of Conduct is being revised on a yearly basis. A revision is currently ongoing, and will be approved in December 2014. A new interactive training module is being developed, and will be released towards the end of the year. The code of conduct includes a section on reporting and encourages all employees to report to management, HR and/or the Chief Auditor when they witness any deviations from the code of conduct.
At SWIFT’s largest location, which is located in Belgium, a system of trusted persons is in place. It further facilitates reporting of issues related to human rights.
Where applicable SWIFT has work councils in place and a health and safety committee including staff and management representatives. Although broad in terms of topics and governance, these bodies can and will also discuss human rights related topics when they are relevant or are brought up.
The CSR Ethical and Environmental Obligations Chart informs suppliers about their ethical and environmental obligation when supplying to SWIFT. Since 2014, this chart is included in all RFPs and in all new contracts.
In November 2013, SWIFT launched an independent Well-being at Work Survey, in order to understand what drives well-being in the workplace and to further improve the SWIFT working environment – in every aspect. The results were made available in Q1 2014, and a few actions were already taken during the remaining of the year – see below.

No human right violations were reported in the several available reporting channels in 2013 and 2014.
The Well-being Survey showed good results compared to the Belgian private sector level. It highlighted a number of improvement opportunities, which were taken into account by the creation of a dedicated working group with staff participation, the organization of a well-being week (successfully organized in November 2014, including conferences, workshops and stands dedicated to psychosocial risk prevention and well-being) and the planning of specific psychosocial risk analysis in Q1 2015. The next Well-being Survey will be organised in 2016.

At SWIFT all employees may engage with social bodies as permitted by local laws and regulations. Where applicable, SWIFT management organises and participates in these social bodies and engages in dialog and/or collective bargaining.
Labour rights related policies are available and visible / accessible to all employees in the areas of:
- Management principles, with references to the treatment of and respect for all people.
- The equal opportunities policy that outlines key elements for ensuring equal treatment for all people globally. A new Diversity Strategy with 3 focus areas (gender, age and culture) that was developed in 2014.
- The Open Door Policy, inviting any issues (including labour and human rights) to be escalated and followed-up.
- Through its CSR Ethical and Environmental Obligations Chart, SWIFT is requesting similar policies from its suppliers, including the recognition of the freedom of association, the prohibition of forced, bonded or compulsory labour, the abolition of child labour.

At SWIFT this is accomplished by means of the regular Works Council, Union Representatives Meetings and Health and Safety Committee Meeting at its largest location (Belgium). Such a works council is also in place and actively functioning at our location in the Netherlands. The other locations use other means referenced in above policies to ensure open communication and follow-up of filed reports (if any).
A Diversity Council was established in early 2014, and a series of activities around diversity were launched: (1) a diversity audit, which highlighted a good inclusion culture in the company, (2) the implementation of Globesmart, a cultural awareness tool, (3) a staff awareness session on diversity, and (4)the piloting of a Unconscious Bias Management Training.

No reports of violations of labour rights were received through the different channels in 2013 and 2014.
In 2014, we defined 2 Key Performance Indicators looking at gender diversity: fair representation of women in people management positions by 2020 (in line with women representation at staff level), and a yearly KPI on Young Graduates recruitment (40% female recruits).

Five years ago, we set a target to reduce our global carbon emissions by 60 percent between 2007 and 2012. We are delighted to have delivered on that commitment, and will continue to work towards a further 10 percent reduction (against our 2007 baseline) by 2015.

We are actively working to make our data centres more energy efficient. Our new operating centre in Switzerland is not only state of the art in terms of security and resilience, it is also a flagship construction in terms of energy efficiency. It features innovative use of outside air as a cooling mechanism, along with a modified computer room temperature which will ensure that the facility operates at maximum efficiency and minimum CO2 emissions. In 2014, we performed an energy audit of our data centre in the US, which highlighted a series of actions to be implemented. We are using electricity from renewable sources in our Belgian headquarters, in the Netherlands, Italy and Switzerland.
We are also looking at producing our own energy: we have installed 500 solar panels in Belgium in April 2014, and are investigating the use of geothermy to cool off our Belgian computer rooms.
Our working from home/flex time policy introduced at the end of 2012 has enabled employees to reduce their commuting impact and has led to an increase in the energy efficiency of our office buildings. Our CO2 Audit shows a positive impact in 2013 as a consequence of the take-up of these policies.
Through our commuting policy, we encourage our staff to select more environmentally friendly ways of commuting to work (electric bikes, greener cars, public transport). In 2014, we launched a project encouraging staff to select electric company cars. This project will be implemented in 2015.
We have also made further investment in telecommunication tools, which help reduce the overall necessity for business travel. When travel is mandatory, we offset the environmental impact through carbon certificates.
At our largest community event, Sibos, which took place in Boston in October 2014, we engaged with delegates to reduce the environmental impact of bringing together more than 8,000 people from around the world. We off-set emissions generated by SWIFT staff and invitees, and offered delegates the chance to offset their own travel emissions.
The Boston Convention and Exhibition Center used for this event places great attention on maintaining a clean environment and promoting green practices. For example, the Center uses energy efficient, programmable and sensor-controlled lighting, and all pallets and carpet padding left from events are donated to local organisations or shipped to a recycling facility. At the end of the conference exhibitors were able to drop leftover, non-perishable items in the blue-logoed bins that were available throughout the exhibition floor. These were made available through the C.A.R.E programme of the Center. The collected items were donated to local associations.
We also request our suppliers, through the CSR Ethical and Environmental Obligations Chart, to actively improve the efficient use of finite resources (energy, water, raw materials) and to put in place measures to minimise the release of harmful emissions and the impact of products and services on the environment. We also request them to dispose of all waste materials properly and in an environmentally responsible manner.
We also took a series of measures to protect the biodiversity in the SWIFT HQ park, by re-sowing a flower meadow, planting a conservatory meadow and maintaining 3 beehives.

In 2007, we set a challenging objective to reduce our Greenhouse Gas Emissions by 60% between 2007 and 2012. Every year since then, we perform thorough measurements in compliance with the GHG protocol (scope 1, scope 2 and scope 3 since 2012).
We have reduced our CO2 footprint by 66% between 2007 and 2013, and are in good shape to reach our new reduction objective of 70% by 2015.
In 2014, we performed a water footprint assessment for the first time. The assessment highlighted that due to low consumption, water is not a priority issue to be tackled by our company.
In Belgium, we were awarded a 5 stars label by Tous Vélos Actifs, in recognition of our very proactive and innovative policy to promote the use of bicycles to commute to work.
After a harsh winter in 2012-2013, during which we lost half of our bee population, our bees are doing better, and we collected 65 kg of honey that will be sold to employees. All the proceeds of the sale are being donated to Apibrabant, an association dedicated to bees and beekeepers.

At SWIFT anti-corruption / bribery policy statements are included in the code of conduct, which is formally acknowledged by all employees when they join SWIFT and again when changes to the code of conduct are made. The code of conduct also refers to a specific Anti-Corruption and Anti-Bribery Policy with details on expected behavior and reporting.
The purpose of this policy is to reiterate and supplement SWIFT’s commitment to prohibit corruption and bribery, as set forth in our Code of Conduct, and to comply with applicable anti-corruption and anti-bribery laws. It supplements SWIFT’s Code of Conduct and sets forth general rules, principles and key terms to which SWIFT Personnel should adhere to.

The Code of Conduct, including its Anti-Corruption and Anti-Bribery section, was reviewed in 4Q 2014. The proposed updates are subject to approval by the SWIFT Board. The new release will then be launched for re-acknowledgment of the Code of Conduct by Middle and Senior Management and the Executives early 2015. A new interactive training module on the Code of Conduct is under development.
The Anti-Corruption and Anti-Bribery Policy was reviewed in November 2014. It applies to all SWIFT staff and to all acting on SWIFT’s behalf (consultants, contractors, agents and partners) throughout the world. An e-learning module on SWIFT Anti-Corruption and Anti-Bribery Policy will be available in early 2015 and will be mandatory for all SWIFT employees and contractors.

Since our 2013 COP no reports on corruption or bribery have been filed through the available channels.