Communication on Progress
- Participant
- Published
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- 03-Dec-2019
- Time period
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- December 2018 – December 2019
- Format
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- Stand alone document – Basic COP Template
- Differentiation Level
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- This COP qualifies for the Global Compact Active level
- Self-assessment
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- Includes a CEO statement of continued support for the UN Global Compact and its ten principles
- Description of actions or relevant policies related to Human Rights
- Description of actions or relevant policies related to Labour
- Description of actions or relevant policies related to Environment
- Description of actions or relevant policies related to Anti-Corruption
- Includes a measurement of outcomes
- Statement of continued support by the Chief Executive Officer
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Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.
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3 December 2019
To our stakeholders:
I am pleased to confirm that Abris Capital Partners reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.
In this our first annual Communication on Progress where we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations.
The information presented in this Report refers to our activities from the period of preparation for accession to the United Nations Global Compact and those immediately after accession, i.e. at the end of 2018. Additional information has been presented in this report and its development is included in the Abris ESG Report available on the Abris Capital Partners website.
Activities carried out in 2019 will be reported in the next annual report presenting the whole of 2019. We also commit to share this information with our stakeholders using our primary channels of communication.
Sincerely yours,
For and on behalf of
Abris Capital Partners LimitedTimothy Knight
Director
- Human Rights
- Assessment, policy and goals
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Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.
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Abris directly declares respect for Human Rights and indicates active commitment to the protection of Human Rights in two basic documents: Abris Capital Partners Compliance Manual and Abris Capital Partners Responsible Investment Policy. In the Responsible Investment Policy, it has been announced that Abris has developed a Categorization Guideline to ascertain the scope of ESG Due Diligence. Based on the adopted guidelines, Abris refrains from investing in companies that do not respect Human Rights. We have developed a monitoring tool for our portfolio companies which contains a section dedicated to Human Rights risk assessment.
- Implementation
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Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.
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The Abris Capital Partners Compliance Manual certifies that Abris Investment Committee provides guidance on a wide range of potential Human Rights challenges, which include consideration of susceptibility of Human Rights abuses, such as child or slave labour or bans on trade unions. The ESG Team in responsible for assessment and mitigation of Human Rights risks. We have internal whistleblowing procedures as well as an external, publicly available whistleblowing contact.
As the majority owner, Abris recommends to its portfolio companies where it has identified a Human Rights risk, to take measures to reduce that risk. Examples of projects demonstrate the inclusion of Human Rights requirements in the audit of suppliers or supplementing codes of ethics with issues related to Human Rights.
In 2018, Abris was a Partner of the guidelines on “Ethical and social standards as the pathway for small and medium enterprises to collaborate with large clients”. The brochure was published by the Ministry of Investment and Economic Development of the Republic of Poland. The brochure describes business and Human Rights issues and was widely promoted internally and on the market.
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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The Human Rights risks assessment has been added to our due diligence and monitoring activities. All our portfolio companies were analyzed in terms of Human Rights risks. There were no incidents of Human Rights violation. We raised awareness of the risks related to Human Rights and business through a specially prepared information brochure.
- Labour
- Assessment, policy and goals
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Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.
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Abris Capital Partners defines employee rights, responsibilities and their compensation and benefits in the Abris Capital Partners Human Resources Policy and Abris Capital Partners Compliance Manual. Requirements for business partners, in particular portfolio companies, in respect to labour rights have been defined in the Abris Capital Partners Responsible Investment Policy. Every investment activity is assessed considering international labour standard risk. We check portfolio companies in terms of general compliance, working hours, wage, fair working conditions, training, health and safety.
- Implementation
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Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.
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Our Compliance Manual is regularly updated and fully implemented in our organization. One of our priorities is the HR management system with clear and transparent procedures for hiring, evaluating and promoting. We have implemented anonymous whistleblowing channels.
Our Response Procedure regarding Reports of Irregularities and Fraud defines situations subject to notification. In particular, the following situations and behaviors can be subject to notification: breaches of the generally applicable law; breaches of internal regulations, including but not limited to, labor bylaws, procedures related to occupation safety and health, financial and accounting procedures and practices, mobbing, discrimination, anti-corruption procedures, as well as other policies, procedures, instructions and orders.
More than 12,500 employees work in our portfolio companies. That is why Abris Investment Committee provides guidance on a wide range of potential ethical, governance, social and environmental challenges, which include consideration of: susceptibility bans on trade unions; compliance with social legislation, such as laws and best practice governing discrimination, diversity, employment terms and health and safety.
- Measurement of outcomes
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Description of how the company monitors and evaluates performance.
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The Response Procedure regarding Reports of Irregularities and Fraud defines how to deal with violation incidents of the Global Compact labour principles.
In the portfolio companies, we worked on e.g.: implementation of the employee evaluation process; introduction of a new fleet policy; introduction of a bonus program; implementation of an HR management system: procedures for hiring, evaluating, promoting employees.
We checked and analyzed approximately 70 indicators in terms of labour standards in each portfolio company. The details are described in the Abris ESG Report 2018, which is publicly available.
- Environment
- Assessment, policy and goals
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Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.
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Our approach to environmental issues is presented in the Abris Capital Partners Responsible Investment Policy. We work to build value in our investments through close collaboration and strong respect for our business partners. Our businesses must be cognizant of the social impact and environmental consequences arising from their operations. We select investment opportunities not only in terms of the expected financial return. We also consider environmental, social and governance (ESG) issues when contemplating investment opportunities. As a socially responsible investor, we aim to invest in companies that act responsibly in terms of environmental issues.
We have incorporated environmental issues from the Abris Capital Partners Responsible Investment Policy and the Environmental, Social and Governance (ESG) Monitoring Procedure into our investment process. Once an investment is made, we continue monitoring e.g. environmental risks to ensure our limited partners' interests are well protected. We actively advocate responsible investing by integrating environmental, social and governance factors (ESG) at every stage of the investment process.We are aware that the climate-related risks and opportunities can have serious impact on our investments and reduce value of the investment portfolio. Responding to this challenge, we have incorporated the climate-related issues into our ESG monitoring practices. Annually, we ask our portfolio companies about their practices in assessing the climate-related risks and opportunities. When it is relevant, we periodically monitor the status of implementing these projects in the portfolio companies exposed to the challenges of climate change.
- Implementation
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Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.
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Examples of environment projects in Abris’ portfolio companies: reducing water consumption in the production process; energy efficiency audit; implementation of the ISO 14001 management system; purchase of a mixer reducing the amount of waste.
We have promoted our approach to environment challenges during different conferences. We use a range of tools to promote Abris’ approach to the climate change and water crisis, for example videos: (https://www.youtube.com/watch?v=pXE_E3wGp1w)
- Measurement of outcomes
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Description of how the company monitors and evaluates environmental performance.
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We checked and analyzed approximately 100 indicators in terms of environmental and climate change issues in each portfolio company. The details are described in the Abris ESG Report 2018, which is publicly available.
- Anti-Corruption
- Assessment, policy and goals
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Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.
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Abris Capital Partners defines its anti-corruption policy in two basic documents: the Abris Capital Partners Compliance Manual and Abris Capital Partners Responsible Investment Policy.
- Implementation
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Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.
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Our 2018 ESG priority was to implement a “zero-tolerance” policy in the areas of ethical standards, anti-corruption and whistleblowing in every portfolio company.
This program consisted of the following:• Presentation of corruption risks and an anti-corruption program to the Management Board of each portfolio company
• Templates of procedures and instructions on book-keeping and financial reporting compliance tests; gifts and benefits procedures; Anti-Corruption Clauses; procedures on managing Conflicts of Interest
• Appointment of a Compliance Officer in each portfolio company
• Compliance Officer training regarding corruption risk, whistleblowing and internal investigations delivered by a recognized law firm and a whistleblowing services firm
• Implementation of internal and independent, anonymous whistleblowing channelsThe training for Compliance Officers was prepared and executed. There were also movies about how to use whistleblowing in notifying corruption cases.
An Ethics Officer was appointed at Abris.
- Measurement of outcomes
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Description of how the company monitors and evaluates anti-corruption performance.
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The Response Procedure regarding Reports of Irregularities and Fraud defines how to deal with corruption incidents.
All Abris’ employees participated at the training about anti-corruption and whistleblowing.
There was no corruption case at Abris Capital Partners.