8th June 2022

To our stakeholders
I am pleased to confirm that KeolisAmey Metrolink 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 annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Guillaume Chanussot
Managing Director

KeolisAmey Metrolink (KAM) complies with all relevant international and UK laws in relation to human rights and has developed a supporting suite of policies, processes and procedures including:
• An annual Modern Slavery and Human Trafficking statement which sets out KAM’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains,
• A Dignity at Work and Reporting of Bullying and Harassment policy,
• Equality, Diversity, and Inclusion policy,
• Family-friendly policies including maternity, paternity, adoption, flexible working, time off for dependants, parental leave, bereavement leave),
• A Whistleblowing policy and process,
• Grievance and Disciplinary policies,
• A Data Protection (to protect our customers’ and employees’ personal data).
• We have also developed and implemented an integrated management system approach, certified to several international standards including ISO 45001 ‘occupational health and safety’, which supports us in continuously improving our approach to safety, health, and wellbeing.

We have taken the following steps to prevent human rights violations in our work locations.
• Provided two independent and confidential whistle blowing lines where staff can report concerns about wrongdoing in confidence. Including one specifically focussed on safety, health, and wellbeing concerns.
• We have provided training to our management team on:
 modern slavery and human trafficking, which includes, the background and scale of modern slavery and human trafficking; how to identify the signs of slavery and human trafficking; what initial steps should be taken if slavery or human trafficking is suspected; what external help is available, for example through the Modern Slavery Helpline and The Salvation Army Human Trafficking Helpline.
 equality diversity and inclusion,
 mental health (understanding emotional distress, recognising the impact of workplace trauma)
 policies relating to the management of staff
• We have provided training to our frontline employees including:
 mental health and how to support customers as well as each other
 equality, diversity, and inclusion
 safe systems of working
• Implemented a mental health buddy scheme and equipped several employees with advanced skills to support someone in distress
• Developed an integrated business management system, certified to:
 ISO 9001:2015 (quality management),
 ISO 14001:2015 (environmental management),
 ISO 27001 (information security)
 ISO 45001:2018 (occupational health and safety management)
• Continued to promote the use of internally developed Stop, Think, Act, Report (STAR) health and safety reporting system which provides a simple and effective way for employees to report health and safety issues and concerns.
• Engaged with schools and colleges delivering both face to face assemblies & virtual assemblies to neighbouring schools to help support and encourage the use safe use public transport and deter anti-social behaviours.
• Worked with local youth groups and homeless charities to raise awareness of the challenges in faced in local communities, enabling us to provide additional support those most vulnerable.

The progress of our policies, processes and initiatives are monitored through a robust governance structure, with senior leadership meetings held on a four weekly basis to review and evaluate established business performance indicators, including those that support human rights such as employee relations cases (e.g., disciplinaries and grievances etc.) and whistleblowing cases.
Over the last 12 months significant progress has been made including.
• 423 STAR reports raised by KAM employees and 1 report via the confidential reporting system (CIRAS). No whistleblowing cases recorder.
• 100% of employees across both depots covered by ISO compliant management systems.
• Through our school visits programme we engaged with approximately 24,000 students.
• Provided our customers with 12,000 hand gels, 20,150 face coverings during the pandemic.
• 300 employees attended Mental Health Awareness training.
• 150 employees attended equality diversity and inclusion.

We respect the right of all employees to be represented in the workplace and have a collective bargaining agreement with a recognised Trade Union encompassing all our employees. The object of this agreement is to provide a mechanism for collective bargaining and joint consultation via a tiered, collaborative, forum-based approach.
We produce and annual Modern Slavery and Human Trafficking statement which sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and our supply chains.
Fairness, respect, equality, diversity, inclusion, and engagement (FREDIE) are the principles that sit at the heart of our approach to making KAM a great place to work. Our policy on Equality Diversity and Inclusion, which is reviewed annually, states that we (including any person acting on its behalf) will not discriminate in any situation against another individual or group, directly or indirectly on the grounds of protected characteristics as defined by the Equality Act 2010 which are; Age; Disability; Gender reassignment; Marriage and Civil Partnership; Pregnancy or Maternity; Race (including colour, nationality and ethnic or national origin); Religion or Belief; Sex; Sexual orientation.
We do not discriminate on the above grounds at any stage of the employment cycle including during recruitment, selection, and promotion; training and development; the application of employment policies and practices; providing wellbeing support.

In the last 12 months, we undertaken the following activities:
• Provided a system that enables employees to report any violations of labour principles (or any matters of concern) either through KAM’s grievance procedure, or in confidence via one of two whistleblowing lines.
• Reported our gender pay gap in compliance with UK requirements.
• Created an equality, diversity, and inclusion (EDI) steering group, comprising all levels of employees from frontline to senior management team.
• Trained our management team to identify and tackle discrimination on the grounds of protected characteristics and the correct application of our employment policies.
• Provided a confidential employee assistance programme, available to all employees free of charge.
• Evaluated our workforce to determine that minimum wage is met. However, we are going beyond our statutory requirements by ensuring that all direct employees are paid the Real Living Wage.

Through our business governance structure we have identified a number of performance indicators that enable us to measure and monitor progress in this area, including diversity, employee sentiment, training, whistleblowing reports etc.
Regular employee engagement surveys take place and are acted on and we have improved communication to all parts of the business by existing and new methods focusing on relevancy and usefulness of information for our target audiences.
KAM is a “Disability Confident Committed” employer challenging attitudes towards disability, increasing understanding of disability, removing barriers to disabled people and those with long-term health conditions, and ensuring that disabled people can fulfil their potential and realise their aspirations. We are working towards the next level accreditation “Disability Confident Employer”, which we expect to achieve within the next reporting period.
Working alongside the National Centre for Diversity, we are also working towards the Investors in Diversity accreditation, and we will increase the diversity of the workforce at all levels through positive action.
We are also working towards becoming members of Greater Manchester’s Good Employment Charter which aims to develop diverse, equal, and truly inclusive working conditions across Greater Manchester and ensure fair pay, opportunity, and progression to all.

We are committed to reducing the impact of our business on the environment and understanding the effects of climate change and the impact this may have on the business. The protection and enhancement of the environment is one of our highest strategic priorities, with ‘planet’ forming one of our seven overarching business pillars. Our full commitment is laid out in our Environmental and Sustainability policies.
As a light rail operator and maintainer we understand the role we play in protecting the environment and supporting the Greater Manchester region’s objective of achieving carbon neutrality by 2038 by helping people to transition to a zero-emission mode of transport.
The over-arching achievement made during this period is the establishment, implementation, and certification of ISO 14001:2015 environmental management system covering the full scope of our activities. This provides a framework for environmental performance and continual improvement whilst providing a risk based, precautionary approach to the prevention of pollution and protection of the environment. As an ISO system, we have also integrated this, where appropriate, to other management systems, in particular ISO 45001:2018 OHSMS and ISO 9001:2015 quality management.

We have taken measures to further understand and reduce, where applicable, some of our significant environmental impacts.
• We have continued to achieve zero waste to landfill by maximising recycling within our control and diverting other wastes from landfill via transfer and segregation to recycling and energy recovery.
• We have measured and submitted our scope 1 and scope 2 carbon emissions based on absolute and intensities.
• We continue to source REGO backed 100% renewable electricity. In addition to this we have supported our client in the delivery of decarbonisation infrastructure including 5 solar arrays, LED conversion and air-source heat pumps to reduce our supplement our electricity demand and our dependence on natural gas for building heating.
• We have commenced monitoring water usage to enable a water balance to be determined, in turn enable water usage reduction processes.
• As part of our operation and maintenance, we have commenced a trial of an organic herbicide with a view to phasing out the use of glyphosate.
• We have the launched the ‘KAM Bee Project’, a partnership between KAM and a local beekeepers association. The project has seen the creation of a ‘bee patio’ on one of our depots which houses several beehives, and the sowing of seeds to create a wild-flower meadow and small orchard to provide a habit for the bees.

3. MEASURES
KAM monitors and measures environmental performance through our strategic ‘Our Planet’ business pillar. Performance is reviewed on a four-weekly basis through our formal performance report and visualisation meetings. Our measuring and monitoring approach includes the performance of applicable operational controls, legal compliance and conformity with the company’s objectives and targets including energy & carbon, waste, and water consumption trends. identify trends, including:
• Waste Management - During the 12-month period, 59% of all waste was recycled, with 41% recovered for energy. None of the waste produced was sent to landfill.
• Energy usage – both traction and non-traction electricity usage intensity rate (per 100,000 kilometres operated) is monitored, along with depot gas usage.
• Carbon emissions – we have established our scope 1 and 2 emissions and developed a reporting process for stakeholders based on Streamlined Energy and Carbon Reporting (SECR) requirements.
• Environmental management system performance – internal and external audits. Certification was achieved to ISO 14001:2015 within the period with no adverse findings.
• Environmental incidents – no significant incidents, prosecutions or notices reported within the period.

We are committed to conducting business with honesty and integrity, and we expect all employees and suppliers to maintain our high ethical standards. We also believe that it is essential to conduct operations in full compliance of the law and to ensure our business dealings with employees, business partners, suppliers and customers are conducted professionally, fairly and with integrity in a corruption-free environment.
We do not permit or condone any acts of corruption and bribery, in any of our dealings or in the dealings of our employees, joint venture partners and suppliers.

During the last 12 months we have:
• Rolled out company-wide anti-bribery and anti-corruption online training supported by robust processes through line management to ensure that all employees are aware of their obligations pertaining to anti-corruption.
• Raised awareness of signposts towards potentially being directly or inadvertently being involved in practices which could be perceived to fall within bribery and corruption legislation or company standards. This is backed up by our anti-corruption and anti-peddling code of conduct which is communicated across the Group and to relevant interested parties / stakeholders.
• Embedded anti-bribery and corruption principles and best practice into our other policies, such as Gifts and Hospitality.
• Developed a questionnaire for our supply chain specifically related to wider governance including anti- bribery and corruption and ethical requirements. In addition to this we include commitments and checks within our supply chain tender process which is supported by our social value and sustainability policies.
• Implemented a whistleblowing policy and system to enable the confidential reporting of any anti-bribery and corruption related concerns.

Anti-corruption, bribery and influencing pedalling reports and proactive measures and monitored by the KAM senior management team as part of our business governance processes. During the reporting period, there were no reports of bribery or corruption received either directly or through the whistleblowing system. To increase awareness of this issue, all management levels underwent anti-bribery and corruption awareness training.
All gifts and hospitality are monitored through the Commercial Department with a register of all given and received invitations and gifts whether accepted or declined are recorded, including monetary value, from the Senior Management Team down to front line staff members. This includes an exceptions, thresholds, and prohibited items. These policies are refreshed annually through our online systems, group communications and line management structure.