8th September 2021

To our stakeholders:

I am pleased to confirm that Averda 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 share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Mr Malek Sukkar
Chief Executive Officer
Averda

We have a Human Rights Policy in place which is guided by the UN Principles on Business and Human Rights.
We have a Business Code of Conduct and Ethics Code
Our Safety Standards and practices in the workplace are aligned with OHSA (ISO) standards which is best practice.

Our Safety and Sustainability Programs are monitored at Board level with a Board Sub Committee for Safety and Sustainability having been established under the leadership of a Non-Executive Director
We have Procurement Vendor onboarding standard and process to ensure that we only engage with 3rd party vendors that meet with our international safety, sustainability and ethical business standards
Other than the normal annual financial audits we have a number of external audits that take place annually to ensure that we are in compliance with our standards and international best practice, e.g. ISO audits and External ESG audit
We have a number of systems in place whereby all employees, contractors and other third parties can raise concerns/grievances. We have a formal whistleblowing system run through our general counsel, a grievance system and a Speak Up system. All issues raised are recorded, investigated and closed off expediently.
At all our locations in the diverse markets we work in we comply with the host countries legislation, we engage with the local communities where we work, we have our environmental standards on place to ensure we comply with international norms, we employ people from the host countries and contribute greatly to the development of the local economies

Our Human Rights Policy is strictly adhered to with ongoing monitoring for compliance.
Our Business Code of Conduct and Ethics Code is strictly adhered to with ongoing monitoring for compliance
We have a formal whistleblowing system run through our general counsel, a grievance system and a Speak Up system. All issues raised are recorded, investigated and closed off expediently.
Our Safety and Sustainability Programs are monitored at Board level with a Board Sub Committee for Safety and Sustainability, under the leadership of a Non-Executive Director

As an employer of over 14,000 people worldwide we take our responsibilities towards our people very seriously. We are particularly aware of the extra responsibility we have towards expatriated employees, who form the largest proportion of our staff in the GCC region, and for whom we are more than just an employer, for example we also provide accommodation and healthcare.

We have a Human Rights Policy in place which is guided by the UN Principles on Business and Human Rights. This is strictly adhered to with ongoing monitoring for compliance. The Policy covers the following areas such as discrimination, diversity and inclusion, safe and healthy workplace, freedom of association and code of business conduct

We have a number of Human Resource Policies and systems in place to ensure fair and non-discriminatory employment practices. We are fully compliant with all labour laws in the countries we operate. Some of the relevant HR Policies are, our Recruitment Policy, our Reward Policy, our Grievance Policy and our Disciplinary code

In all our markets we pay above prescribed minimum wages. We annually review our Compensation and Benefits offer to ensure we are competitive within our markets and internationally.

In many of our markets (in the GCC) we provide accommodation for our expatriate front line employees as well as health care and annual travel home to their families. During the reporting period, Covid restrictions prevented many of our employees returning home as normal. We invested in installing free wifi across our accommodation facilities to enable family contact to continue during this difficult time.

In South Africa we are level 2 BBBEE (Broad-Based Black Economic Empowerment) certified. This is above or in line with the industry norms in South Africa

Based on local norms in some of our markets we have unions and/or bargaining councils to which many of our employees have membership. We fully recognise the right of freedom of association and as a Company are fully engaged with the Unions and Bargaining Councils where applicable.

We have in place REMCO Board Sub Committee under the leadership of a Non-Executive Director that oversees our HR and Reward Policies and Practices

Protection and responsible stewardship of the planet is our obligation to our children and future generations, every day. In addition to offering tailor-made, environmentally friendly services and treatment options to help meet our clients’ environmental goals, we also take care to minimise our own environmental footprint, focusing on the following four areas:

1. Fossil fuel and energy use.
2. Fresh water use and effluent treatment.
3. Air quality impacts.
4. Sustainable sourcing and practices to enable reuse, recovery and recycling.

Averda consistently implemented an ISO 14001 framework environmental management system across all operations to deliver continuous improvement of environmental and social related impacts.

Emergency planning and preparedness to mitigate and control environmental and health impacts are in-place and reviewed annually.

Over the reporting period, Averda appointed a Global Director of Sustainability and set 2024 Corporate environmental goals to minimise climate, social and environmental impact

The use of a large fleet of heavy vehicles is an unavoidable part of our waste collection service. We are working to ensure all our vehicles are fuel efficient, appropriate for the purpose and are operated by drivers trained in smart driving techniques that cut engine idling and over-revving. Most effectively, we have – as part of the digitalisation of the company – employed a route optimisation solution which provides dynamic options to avoid traffic and reduce travel distance whilst optimising delivery efficiency.
Our other energy reduction initiatives include an assessment and optimisation of treatment plant power requirements and a significant drive towards online meetings, which reduces flights and travel costs, and its associated carbon emissions. We actively promote walking and cycling options where appropriate.
We have developed methods to reduce our reliance on potable water whilst maintaining the cleanliness of vehicles. Modifications included grey water collection and recycling systems and environmentally friendly substitutes.
Where possible, only FSC certified and sustainably sourced paper is procured. The procurement and use of single‑use plastics is discouraged via education of our employees. However, loading bins is thirsty work and where we cannot eliminate the use of plastic, we actively encourage recycling and safe reuse.

Consumption of natural resources and climate change impacts have been assessed in-house using science-based methodology.
The control of possible ground and surface water impacts is actively managed in the design of our landfill and surface water is diverted from the active cells by cut-off drains. The runoff from these is regularly analysed to ensure effectiveness.
Any possible impact we might have on groundwater is mitigated by our state-of-the-art landfill construction that includes leak detection systems. Furthermore, disposed liquid waste is treated and stabilised prior to disposal to prevent leaching of toxins that could impact soil and groundwater. Verification of the waste leachability potential and impact is assessed upfront by laboratory analysis and mitigated by our novel treatment solutions.
In addition to the particulate and emission reduction being made through our fleet optimisation, Averda also maintains the highest compliance standards and quality control of impacts from our treatment and disposal facilities, including our incinerators. Continuous online stack monitoring equipment alerts us to any deviations and the process is adjusted in real time. The data is shared with community engagement groups and regulators.
Waste, particularly organic waste, can smell bad. We have installed online ambient air monitors around waste treatment and disposal facilities to provide early warnings so we can investigate and mitigate the source. Installation of odour neutralisers that operate continuously assist with this process.

Averda takes a clear, zero-tolerance approach to bribery and corruption and are determined to conduct all our business in an honest and ethical manner. Our Anti-Bribery and Corruption Policy clearly sets out Averda’s responsibilities and those of people working with us. Ensuring all employees at every level understand and adhere to these rules is essential.
All our principles and core standards of conduct are encapsulated in our ‘How We Do Business’ guide, our Anti Bribery and Corruption Policy and Averda’s global whistleblowing policy (Speak Up), each of which must be followed in every country where we do business. This important document is included in on-boarding for new joiners and is annually reviewed by Averda’s General Counsel. These policies do not stand alone: they are supplemented by a range of other company policies as well as applicable laws.
How We Do Business’ doesn’t try and anticipate every possible scenario, rather it provides guidance to help apply Averda’s values and code of conduct into practice every day. Where there is a discrepancy between Averda’s standards and the local customs or regulations then the higher standard of behaviour must be applied.

We annually conduct mandatory anti-bribery training and require annual confirmations from employees with respect to How We Do Business.

We include anti bribery and corruption provisions in all of our joint venture and similar agreements. Additionally, confirmations about anti bribery corruption are required to be made by all third party suppliers which are engaged by the business.

We have a whistleblowing framework to encourage and support colleagues at all levels of the business to ‘Speak Up’ about any concerns they may have. Information about the whistleblowing policy is provided to all employees in all the major languages.

Clear delegation of authority allows senior management to have oversight and ensure good governance without stifling initiatives and decisions made by experts in their field. Averda’s Delegated Authority Matrix (known internally as the DAM) clearly sets out which roles need to sign-off specific types of decisions and enhances internal accountability.

At present, the company is not formally measuring this area of our performance. We are currently recruiting a senior compliance manager and a large part of their role will be monitoring and auduting these types of policies against organisational behaviour.