ESG Insights Report 2021
that positive Environmental, Social and Governance (“ESG”) practises are intrinsic to business success. We recognise that our business, although small with a modest direct influence on the environment, has wide reaching impacts through our customers, our employees, supply chain and the communities in which we operate. Our aim is to create value and long-term rewards for our stakeholders. We achieve this through the utilisation of our vigorous ESG strategy and framework which facilitates the effective management of our current and future risks and Althoughopportunities.weareproud of how far we have come, we always strive for excellence and recognise that we cannot ‘sit back on our laurels’ and we must be prepared to challenge ourselves to do better. Each year we will revise our ESG objectives and targets to ensure we improve continually. We hope you find our first ESG Highlights Report informative and we are looking forward to sharing more with you in the future.
There is wide acceptance that the telecoms sector has a vital role to play in connecting the world sustainably by facilitating the evolution of the low carbon economy and supporting society with services that address the levelling up and wellbeing agendas. Speed Fibre Group (“SFG”) is a business of 200 staff but we are proud to serve over 11,000 customers. We have big ambitions but an even bigger sense of our duty and responsibility to fulfil the potential of our business and to serve the community of Ireland collectively and move towards a more sustainable future.
Why ESG is important to us?:
SPEED FIBRE GROUP P 3
The World Economic Forum (“WEF”) suggests that the telecoms sector is at the heart of ‘the fourth industrial revolution’ by providing digitalization to industries and society. SFG are proud to play our part in delivering this theory into a reality by supporting the four essential areas WEF consider imperative, namely providing the networks of the future; going beyond the pipe; redefining customer engagement and bridging the gap on SFGinnovation.believes
Claire M. Murphy Group General Counsel, Company Secretary and Head of Shared Services
Materiality:
Our Portfolio: Our business, Speed Fibre Group consists of three network provision sector leaders: enet, Magnet+ and Airspeed Telecoms. enet is Ireland’s largest, open access network provider and their high-capacity fibre and wireless networks makes it easier and more cost-effective for service providers to deliver and support world-class broadband services to homes and businesses across Ireland. Magnet+ operates Ireland’s largest connectivity network and is the only provider to grant one-stop access to all business options offered by every major network operator in Ireland. Airspeed Telecoms offers enterprise grade, fully managed telecommunications, and bandwidth services for business customers. Their connectivity is designed with reliability at its core, enabling businesses and enterprises to thrive.
To ensure SFG has the right focus and a balanced business strategy, our ESG framework is founded upon a double materiality analysis, undertaken in accordance with the Global Reporting Initiative (“GRI”) standards. This helps us to identify and prioritise our most significant risks, opportunities and areas for value creation, that ‘fall in line’ with our business’ philosophy and commercial objectives. During 2021, we identified our key priorities and commitments by conducting a qualitative materiality assessment of our firms ESG risks and opportunities. This approach is recommended by the WEF.
Our ESG Approach: SFG understands that it has a responsibility to the environment that goes beyond our legal and regulatory commitments and as such, we have identified our most material ESG issues and we regularly engage with our stakeholders to ensure we meet their expectations. The “S” of ESG is often considered secondary to that of the environment impact which is often the main focus of legislation and media attention. Whilst undoubtedly environmental impacts are hugely important, we strongly believe our ability to contribute to society within the telecoms sector should form an element of primary focus of our commitment to sustainability by using the services we provide to promote a more inclusive, well-informed and empowered society and business community that have the tools to fulfil their own sustainability journeys. Our ESG Commitments: We have identified a number of key ESG impact areas, which we incorporate into our business commitments however we see three highlevel objectives as being fundamental to our operations;
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1. Facilitating a low carbon economy- We are committed to managing our business with climate change in mind and fulfilling our duties and obligations under the 2015 Paris Climate Agreement. Although our direct impacts as a network operator are small compared to many businesses, it is vital we properly manage those we do have and use our role within the telecoms industry to positively influence and encourage others to reduce their greenhouse gas (“GHG”) emissions.ments through our operations but also have a significant indirect influence on how others can meet their ESG commitments, especially the social dimension. We are therefore seeking to establish and evaluate our activities in order to align with the United Nation’s Sustainability Development Goals (“UN SDG’s”) and will measure our direct and indirect positive and negative contributions with respect to meeting these goals.
3. Transparency & influence- As a digital communications business we recognise we have a significant role to play in supporting Irish civic society and commercial businesses to become more sustainable in the long term. Therefore, in the interest of transparency, we commit to annually publishing our progress on ESG performance through The Global Real Estate Sustainability Benchmark (“GRESB” infrastructure scheme) so that our stakeholders can follow our progress as we work towards becoming a 5 star rated enterprise .
SPEED FIBRE GROUP P 5 Example Diagram: Carbon Emissions PhysicalRiskClimate Habitat BiodiversityandWasteManagementWaterUse GRESB Reporting Fraud Lobbying Data Security Whistle-blowerProtection ComplianceLegalConflicts EngagementStakeholderInterestofEmployeeEngagementEmployeeTrainingandDevelopment SatisfactionCustomer InclusionDiversityand Community Giving and Engagement Employee & Contractors Health and Safety Our methodology included: • Identifying ESG topics for consideration • Prioritising these topics based on relevance to our business objectives • Engaging employees in our business to understand internal priorities in relation to ESG • Consulting with a range of key stakeholders to understand their views, expectations and the importance of ESG to them The pandemic has taught us that what is material today, may not be tomorrow and thus we must be vigilant and dynamically adaptable to changing societal and economic needs. Therefore, we ensure that streamlined interim updates between the annual reassessment captures new issues or changing topics. This ongoing assessment process acknowledges emerging risks, opportunities and stakeholder views across the business. We monitor evolving external aspects by working with third parties, but also by reviewing feedback from surveys, developing our own ESG knowledge, and analysing insights generated from our social media platforms. Figure 1. Speed Fibre Group materiality matrix. Various ESG related issues are ranked based on importance to stakeholders and relevance to business success. LOW HIGHRelevance to business success stakeholderstoImportanceHIGHLOW
Figure 2. The risk management procedure
risks ACT • Continual Improvement • Updates to policies and procedures • Assess nonconformities • Take corrective action CHECKING • Performance evaluation • Ongoing Management Review • Risk assesments and internal audits • Monitoring measurementsand PLANNING • Contextualising our organisation • Defining our commitmentsESG • Assigning roles and responsibilities • Procedures and planning DO • Operations of the business • Use of procedures and plans Managing our ImpactsRisksand
managing, monitoring
Meeting Our Targets: To ensure that we meet these objectives, we have established a robust set of policies and procedures to which compliance is expected amongst all employees, investors and supply chain members to ensure conformity at all levels of the Furthermore,business.we follow a risk management framework, in some cases aligned to third party standards, to ensure we effectively monitor, track and assess the status of each of our ESG metrics and check that we are on track with both our internal targets and expectations, but also in line with industry best practices. In this way we are able to manage our obligations and commitments, reduce our negative impacts on the environment and promote continual improvement of our ESG performance. We are currently working towards achieving our ISO 14001 certification: the standard for environmental management systems. This will allow for the formalisation of our protocols, measures, controls and procedures to better manage our environmental risks and Atopportunities.SFG,wealso recognise the importance effective internal and external reporting to ensure our team remains focused, empowered and motivated to deliver on our sustainability goals. This also aids in the creating transparency so our stakeholders can see how we are making progress and potentially learn from our endeavours. We have produced our first standalone annual sustainability report this year which will be published on our website. Although this is our first iteration and therefore tailored to be high level and setting the scene for a future report structure, we will be expanding its scope and detail as we build further momentum within the business and through our key stakeholders. used at Speed Fibre Group for and ESG
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mitigating
• In 2020, enet partnered with the Irish Centre for Diversity on the journey towards obtaining an Investors in Diversity award. The company are proud to have achieved bronze award status in early 2021 and will be actively seeking to build on that success, working towards reaching the silver award status, in early 2023.
• SFG was recognised as one of Irelands Best Managed Companies by Deloitte for the second year in a row.
SPEED FIBRE GROUP P 7 2021 ESG Highlights: Here are a selection of our 2021 ESG highlights:
• We are fortunate to say that SFG is a peoplefirst culture and in 2021, following research conducted by the business, in partnership with Human Resources, surrounding what a permanent hybrid work environment would look like, reviewing the approaches of comparable companies, and through a survey sent out to all employees on their preferences, SFG had the necessary data to implement the best course of action for all. The survey results indicated a significant 80% of the workforce were happy to work from home, as a result, we announced a new 1-day hybrid working policy. We feel that our business integrity has remained true and represents one of the important key values of the business – ‘Our People’ and our new motto is ‘What we say, is what we will do’. We achieved our 4th star in our annual GRESB assessment. GRESB is the industry’s most rigorous standard for sustainability performance.
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SPEED FIBRE GROUP P 9 Page 10 Reducing Our Energy Consumption 11 Improving Waste Management 11 Addressing Travel 11 Biodiversity and Habitat 13 Our Approach to Climate Related Risk and Opportunity 13 Reducing Paper Waste 13 Sustainable Practices within Wireless Operations
Reducing Our Energy Consumption: The reduction of our carbon footprint is a key element of our ESG framework, our energy, greenhouse gas and power reduction policy clearly outline our approach to these issues. We have identified our main carbon impact areas as follows.•Scope 1: direct emissions through corporate fuel usage through heating at SFG offices and employee travel in company owned vehicles
• Scope 3: indirect emissions through employee travel in employee-owned vehicles, employee home-working emissions, emissions associated with materials and supply chain
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CO2 Tonnes per year Km/year CO2ofTonnes
Work from office (2019) Work from (2021)home Hybrid(2022) Figure 3
• Scope 2: electricity used by SFG at sites owned and/or controlled by them
We calculate our scope 1 and 2 emissions on an annual basis using a systematic data collection procedure and framework, please see Appendix 1 for our SFG’s 2021 energy and carbon data. We have embarked on the collection of Scope 3 emissions to understand the impact moving to a hybrid working environment had on our CO2 emissions. In doing so, a number of different variables were taken into account (see Appendix 1). As we have demonstrated below, we can very clearly establish the positive impact our hybrid working policy has had on reducing our overall emissions, which undoubtedly benefit the Inenvironment.ouroperational business we ensure that we procure energy on green tariffs where available, stipulate the installation of high efficiency equipment during refurbishment of any of our facilities. We are also mindful of the need to increase employee awareness through the provision of training to encourage eco-friendly behaviours. We have launched numerous employee initiatives and financial incentives (such as car-sharing) to minimise emissions from travel. We are also, like many businesses post-COVID, restructuring our operations to support flexible 4,000,0004,500,0003,500,0003,000,0002,500,0002,000,0001,500,0001,000,000500,0000 100300400500600
Environmental At both the developmental and operational phases of our activities we look to minimise our impact upon our material environmental issues, these include the reduction of energy consumption and therefore our carbon footprint, protection of biodiversity and terrestrial ecosystems, and the limitation of production and the responsible disposal of waste. We have set these principles out in our suite of environmental sustainability policies, which are available on our website. Our environmental policy specifically targets the construction element of our business and SFG expects all subcontractors and suppliers to co-operate fully in the implementation of this system. This policy is distributed amongst our staff and all contractors and suppliers to ensure that all parties play their role in managing SFG’s environmental impact.
Improving Waste Management: Although we do not produce much waste in our business, the small amount that is produced we fulfil our responsibilities under duty of care by ensuring proper recycling and/or disposal. We therefore promote sustainable waste management throughout our daily operations to limit pollution of our local habitats and ecosystems but also to encourage sensible consumption and promote circular economy principles. Throughout our business all employees and contractors are trained on general awareness and cognisance of recycling and the separation of materials such as paper, plastics and cardboard boxes occurs in all of our offices. In addition, SFG ensures that all purchased stationary and ink cartridges are recycled. During our development activities we also insist on the sustainable disposal of all construction waste and ensure that responsibilities for doing so are clearly identified in all of our contracts.
Climate Hazard Risk Level Site Score BenchmarkCountry Earthquakes None 0 0 Floods Medium 30 52 Heat Stress Low 6 4 Hurricanes & Typhoons Medium 79 74 Sea Level Rise None 0 37 Water Stress Low 19 44 Wildfire Low 23 25 CategoryRisk Basis No Risk No Exposure low Risk Not projectedhistoricalexposedsignificantlytoorrisks Medium
Flag Highly
Biodiversity and Habitat: Due to the nature of our network, and our development of telecom tower locations that are often in remote rural locations, we understand that we have a duty to conserve and protect the species, habitats and associated ecosystem services during both our construction and maintenance activities. Prior to beginning work on any location, we ensure that we are in compliance with all relevant environment authorities and planning laws, undertake Environmental Impact Assessments to identify if particular species are at risk and mitigate these impacts where possible through the implementation of conservation measures such as the creation of biodiversity corridors to avoid habitat fragmentation and ensuring the towers do not affect bird and bat flight paths. We are seeking to start regularly identifying, assessing, and reporting on these mitigation measures and disclosing nature-related risks and opportunities at an asset level. In terms of wider corporate business activities, we continually prioritise Example results report from the Speed Fibre Group physical climate risk analysis undertaken in 2021 on various facilities across the group. Risk Exposed to some projectedand/orrisks Red exposed to historical and/ negativehighrisks,projectedindicatingpotentialforimpacts
SPEED FIBRE GROUP P 11 and homeworking which help meet a twin goal of emission reductions and better work life balance.
Addressing Travel: We have detailed internal procedures for travel management as this is a key area for performance improvement for our corporate emissions. All travel in company vehicles is recorded and carbon emissions are calculated annually. We plan to capture the impact of lowered travel requirements during the COVID-19 pandemic this year and will continue eliminating unnecessary travel where possible or switch to green travel options.
Regarding the development arm of our business, we source labour and materials locally where possible, ensure that energy design is a key part of our network design and consider optimum efficiency for heating/cooling systems based on network load and facility location. For example, this year we have increased temperature set points on air conditioning in 86 collocation facilities to reduce energy consumption.
Figure 4.
or
historical
High Risk exposuretodayExposedandlevel is increasing
- In 2018 we posted and printed 4,874 invoices - In 2019 we posted and printed 5,312 invoices - In 2020 we posted and printed 6,838 invoices.
- From December 2020 onwards we began to electronically save our invoices.
- From December 2020 to April 2022, we have posted but not printed 11,890 invoices. Every ream of paper contains 500 pages, thus saving 24 reams of paper which equates to 1.5 - 2 trees. Similarly, Magnet+ undertook a paper bill conversion process with all customers as a green initiative so that invoices would no longer be sent to customers via post. Now that this scheme has taken effect no envelopes, letterheaded paper and double-sided printing is being done for our customer accounts. Sustainable Practises within Wireless Operations: enet operates a national microwave radio network consisting of circa 1,800 licensed and unlicensed microwave links and incorporates almost 4,000 radio units. From early 2020, working with our vendor, enet has introduced newer microwave technologies that are considerably more efficient than previous generations of radios, reducing spectrum consumption by 75%, tower footprint by up to 50%, and energy consumption by up to 40% per unit deployed. Almost 30% of enet’s deployed microwave equipment is now utilising this more efficient model, and it is the preferred method of delivering new services. In addition to this, enet has implemented a program of proactive replacement of legacy radio equipment which allows the consolidation of multiple independent radio units onto a single space and energy efficient chassis, which has also reduced our spectrum, energy, and space usage at our high sites. All recovered units are returned to the vendor for replacement/ repair and are upgraded through that process. Units that are unsuitable for repair are either recycled or disposed of in a responsible manner by the vendor.
Our Approach to Climate Related Risk and Opportunity: We regularly consider climate-related risks consistent with the recommendations of the Taskforce for Climate-related Financial Disclosures (TCFD) during our decision-making processes, we continue to enhance these processes to best manage the future risks we are likely to face. In 2021, we undertook a physical climate risk screening exercise for our key SFG offices and a selection of key infrastructure across our networks using the 427 risk platform, developed by Moody’s. Our physical risks are identified across two types: Chronic (heat stress, subsidence and coastal flooding and sea-level rise) and acute (flooding, storms). The 427-climate risk assessment utilises a simple index screening methodology to identify facilities that are particularly exposed to climate related risks. The index identifies risk against various climate hazards including earthquakes, wildfire, floods and water stress. Our analysis showed that all of our assets were at low risk from most climatic hazards, however the exercise did highlight the need for future planning around our infrastructure and consideration of mitigation techniques potentially required in the future to ensure reliable operation of the Followingnetwork.thecompletion of this exercise we will continue to monitor the exposure of our network to climatic risk. We also hope to assess our transition risk as we continue our climate resilience journey. Reducing paper waste: In 2021, enet Finance team undertook a significant project to stop the printing of invoices to paper and move to an electronic alternative to help ease our environmental impact as a business. Since this decision has been made, we haven’t printed a single invoice since.
SPEED FIBRE GROUP P 13 sustainable use and protection of potable water and protection of ground and marine resources by means of managing wastewater discharges from our sites. We ensure the implementation of these principles through our ISO 9001 aligned Environmental Management system which involves regular ESG-related staff training, engagement with our suppliers and contractors on ESG topics, alongside the regular monitoring and reporting of key metrics. Our annually updated SFG risk register assesses each of these risks using data KPI’s for each impact area based on impact severity and likelihood, this helps us to re-balance our efforts and renew our objectives frequently to ensure continual improvement.
P 14 SPEED FIBRE GROUP Social
SPEED FIBRE GROUP P 15 17 Connecting Communities 17 Working with our Customers: 17 SFG Case Study: Clonmel - a case study in Regional Development 18 Employee Engagement & Health and Wellbeing 19 Diversity and Inclusion 19 Charity and Philanthropy Page
P 16 SPEED FIBRE GROUP 2021 STAFF SATISFACTION SURVEY RESULTS 85% of SFG employees felt that their contributions are valued by their line manager 85% of SFG employees would recommend the company as a great place to work 86% of the SFG Workforce is happy with SFGs hybrid working model 71% of SFG employees completed the staff satisfaction survey in 2021 81% of the SFG Workforce feels they are kept up to date with business progress 100% of employees were invited to complete the survey
• Local Telecom provider Chillwifi which is a Small and Medium Enterprise (“SME”) business based in Clonmel and providing connectivity of all kinds locally within the town and wider area, uses enet connectivity to support the core of its own solutions in the local market.
Social The responsible treatment of our stakeholders, both internal and external, is intrinsic to our operations. The delivery of social value to our customers through the supply of high-quality fibre connectivity has always been embedded in the business model. Our networks support businesses, communities and people who were previously underserved, so that those areas can compete on a national and even international basis and give access to a wider variety of employment opportunities. 5G networks are set to become a driving force behind Ireland’s economy, as such SFG is at the forefront of how society can adapt and change working lifestyles. Furthermore, SFGs activities promote the transition to a low carbon economy as we provide fibre connectivity to communities across Ireland which will assist the transition away from unnecessary business travel by increasing the accessibility of remote working. Our networks will also assist innovative and low carbon technologies and new ‘green business plans’ across Ireland by providing essential network connectivity and the ability for real time management.
A recent example of such was the fast rollout of connectivity the HSE testing locations and Vaccination centres to help in the response to the COVID-19 pandemic.
Connecting Communities The very essence of SFG is focused on regional connectivity, both the MANs networks and the Wireless network we have built more recently are focused on ensuring the connectivity requirements of those in the regions and more remote locations are met so that those areas can compete on a national and even international basis. We believe that the improvement of connectivity in rural and regional locations over time will lead to more employment opportunities in regional locations, more options for remote working in hubs and homes and in turn reduced commuting distances and times. This in turn will bring positive effects for the environment, rural regeneration, work/life balance amongst the population as well as the family and societal benefits that will bring about. Our networks allow for activities (employment, trade, research etc.) to be undertaken in areas of the country where that would not be possible without the existence of SFG. Working with our Customers: We are driven by the care for our customers, and we consistently strive to improve our services and make things easier and more cost-effective for them. We are committed to delivering a reliable and flexible service to meet our customer’s needs, we do this through the creation of close relationships. This means that customers can call on us from time to time to ensure the delivery of important and urgent requirements.
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SFG Case Study: Clonmel - a case study in Regional Development: Clonmel, a county town in Tipperary benefits and relies on connectivity to SFGs network, provided by enet. See some examples below of how enet supports the development of the region:
Both the major mobile phone network providers in Ireland use enet to provide connectivity to their Telecoms towers in the area ensuring quality coverage in the area on their network.
• The three largest employers in the town all use MAN connectivity; Abbotts Vascular, Boston Scientific and Bulmer’s. These employers are supporting over 2000 jobs combined in their facilities.
• South Tipperary General Hospital makes use of enet connectivity when connecting into the National Hospitals Network.
• The Technical University of The Shannon (TUS) has a regional campus in Clonmel using enet connectivity supporting Third Level education locally.
• There are nine schools in the town currently using enet based services supporting the education of over 2200 students locally.
feedback and regular staff surveys are also incredibly important to us. We ensure that all employees have an ability to comfortably express their concerns in their role and suggest improvement measures. During 2021, as life started to return to normal after the COVID-19 pandemic we engaged with our staff and announced a commitment to hybrid working for our employees. This decision follows both our commitment to the environment, by reducing commuting travel, but also promotes the health and wellbeing of our staff.
• employee reward programmes,
• diversity and inclusion strategy. We empower our people to be the best that they can be, by investing in their potential, by enabling them to succeed, by supporting their wellbeing, by rewarding for their successes and ensuring that they work in an innovative and inclusive environment. & them their
full potential DiversityInclusionand Attract, supportdevelopretain,andaskilledanddiverseworkforce EngagementEmployment become EmployeranofChoice Reward & Benefits Reward our People for thecontributiontheirtoCompany’ssuccess Figure 5
Wellbeing Support the Mental Health and Wellbeing of all our People ManagementTalent Invest in our People to enable
P 18 SPEED FIBRE GROUP Employee Engagement & Health and Wellbeing: SFG recognises that its employees are its most valuable resource, and the fair treatment of our employees is vital. To that end, we have developed a number of employee policies, practices and initiatives to ensure that employees are appropriately trained, protected and aware of the aims of the business. We also recognise that we have a responsibility to provide a healthy, safe and inclusive community in which our employees can Employeethrive.
• professional training opportunities, • mental health and physical wellbeing workshops and training sessions,
Mental Health
to suceed to
• management feedback sessions,
In 2020, we launched our People Strategy which sets our vision to be an employer of choice. We have a range of employee engagement initiatives and attractive benefits offered to our employees including the:
Diverse and Inclusive Working Environment: We pride ourselves in creating a comfortable safe and secure work environment for our staff. Our buildings are disability friendly; Clonshaugh being located on the ground floor and Limerick having ground floor offices and a lift. All offices have disabled toilets. We have a number of standing desks available for staff to use if required. Our Limerick office has an air handling system which provides a number of air changes every hour. Limerick and Dublin offices have a large amount of natural light and all windows do open to allow fresh air. Both buildings also have showering facilities and kitchens with coffee machines and filtered water.
Results: 85% of SFG employees felt that their contributions are valued by their line 85%managerofSFG employees would recommend the company as a great place to work 86% of the SFG Workforce is happy with SFGs hybrid working model 71% of SFG employees completed the staff satisfaction survey in 2021 81% of the SFG Workforce feels they are kept up to date with business progress 100% of employees were invited to complete the survey
Diversity and Inclusion: SFG aims to provide a diverse, safe, efficient, integrated and sustainable organisation, which encourages and values the contributions of all parties - employees, contractors, agency workers, graduates, supply chain and customers. As such, SFG is committed to the principles of Equality, Diversity and Inclusion (“EDI”). We are an inclusive organisation that respects the dignity, uniqueness and intrinsic worth of every individual in the SFG and associated community. We set out our principles in our Equality, Diversion and Inclusion Policy to which all everyone working and for SFG is required to abide by. In 2021, we were proud to launch our ‘People Strategy’ in which diversity and inclusion is a key value – it describes our plan of action including targets, public commitments and reporting. A key aspect is the reflection of Diversity & Inclusion in the recruitment strategy, as such we provided unconscious bias to all for all senior and hiring managers in 2021 and plan in 2022, to investigate the best ways to attract diverse talent in the hiring process. We measure and monitor our progress in this region, respecting key performance indicators such as gender ratios, minority representation and we measure our performance against published Intargets.2021, SFG was awarded an Investors in Diversity Bronze award that affirms our commitment to embed EDI across the organisation and that we are equipped for the journey of becoming a more diverse and inclusive place to work. Charity and Philanthropy: Whilst our primary concern is for the stakeholders for which we have a direct influence on, we also try to promote charitable contributions and philanthropic actions to those communities further afield wherever possible. Creating relationships with and contributing to the local communities in which we operate is becoming increasingly important to the business because we feel it is the right thing to do. We simply call this “Giving Back”. We also find that fundraising is a great way to get our staff together and team build! enet has partnered with the Hope Foundation since the beginning of 2020 and so far, we have raised almost €135,000 to support key Hope projects in Kolkatta. The Hope Foundation does fantastic work in supporting vulnerable children, their families and communities, and in tackling the underlying causes of violence, trafficking and neglect by providing much-needed shelter, education and rehabilitation Inservices.February 2021, we held a virtual quiz and musical bingo for our employees to raise money for the Hope Foundation.
SPEED FIBRE GROUP P 19 2021 Staff Satisfaction Survey
To Kolkata and Back: In February SFG combined fundraising efforts with staff engagement and wellness activities. Our staff were tasked with covering 20,000 km virtually, by running, walking, cycling and swimming – the distance to Kolkata and back to Ireland. Funds were directly targeted to the Punorjibon Rehabilitation Home, which caters to solvent-addicted children, many of whom have been victims of daily torture, domestic violence o have been abandoned. We were delighted to raise €8,885, and we know that the funds will help the home provide education, healthcare and nutrition to the residents.
P 20 SPEED FIBRE GROUP Governance
SPEED FIBRE GROUP P 21 23 Annual GRESB Reporting 25 Key Governance Policies Page
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The board of directors (the “Board”) is ultimately responsible for measuring and ensuring governance effectiveness. It is committed to SFG’s undertaking of good corporate governance. The Board has delegated authority to the CEO to manage the business in conjunction with the management team and to do so within the strategic objectives and annual plan approved by the Board and in keeping with the values, strategies, policies, plans, and budgets endorsed by the Board. The CEO provides regular reports to the Board, keeps the Board informed and consulted on matters as appropriate and their approval is obtained when necessary (all of which is in accordance with the prescribed delegation of authority from the Board.
Whilst SFG has made great strides in improving the governance in the business, it is always striving for improvement and excellence within this area. In so doing, SFG made ESG a strategic area of focus for the company during 2021.
Governance
Management is responsible for identifying and updating the register on an ongoing basis to ensure the business is implementing appropriate controls to mitigate risks. SFG recognise that poor governance of certain risks can lead to reputational damage and economic loss. In this regard the business has developed a suite of policies and embedded certain procedures to better govern and manage arrangements right across business departments from the procurement of supplies, the management of contractors, the recruitment of headcount, to the management of network resiliency. Regular management meetings with senior management ensure each of the police and processes are always under review with a view to continuously improving and ensuring pro-active governance.
Considerable work has been conducted over the past year to enhance ESG factors being considered in all decision-making practices in the business but more particularly in respect of energy performance, greenhouse gas emissions, health and safety, customer satisfaction, and employee engagement as we identified these as our most significant ESG impact areas in a materiality assessment. We recognise the importance of external benchmarking and voluntary disclosure, and we chose to voluntarily report our efforts to GRESB which is an internationally recognised rating agency. This gave us a framework to ensure best in class practices were adopted at an environmental, social and governance level, and enabled us to set clear KPIs, transparently report, and benchmark our efforts to help us understand how we can make further progress. In the future we also look to report in line with the UN SDG’s to ensure that our activities promote real world outcomes.
SFG appreciates and understands the clear relationship between a business’s approach to governance and its ultimate success. We view corporate governance as striving to balance and manage the interests and expectations of our stakeholders in a matter which upholds the basic principles of corporate governance which include; accountability, transparency, fairness, and responsibility. SFG has taken the time to ensure there is a clear and structured governance framework within the business, and we adopt a continuous development approach that ensures we analyse our effectiveness and performance in relation to governance matters on an ongoing Governancebasis.
takes a top-down approach in SFG.
The Board established board sub-committees to ensure the adequate assistance and discharge of duties. The Board maintains an oversight over each of its Sub-Committees and they monitor these Sub-Committees by reviewing the Minutes of Sub-Committee Meetings and through discussions with the respective Sub-Committee Chairpersons on their activities, decisions, actions, or improvement recommendations on any area within their remit. The Renumeration Committee have the responsibility for setting and/or reviewing any remuneration policies as required by the Board from time to time. The A&R committee are charged to ensure that appropriate procedures are in place in the business (i) to identify, evaluate and manage risk from a strategic and operational perspective, (ii) to monitor the implementation of risk management procedures, and (iii) to oversee the relationship with the external auditor, including reviewing the findings of the audit on the Group, and to report to the Board as necessary. They also conduct an annual review of internal controls and key ESG Policies. Moreover, they ensure an adequate and appropriate level of insurance cover is in place each year. From an operational perspective, to manage and mitigate risks, legal or otherwise, the company frequently updates the business’s risk register.
SPEED FIBRE GROUP P 23
Board of Directors
Jonathan Florsheim Chariman
Annual GRESB Reporting: We have participated in the annual GRESB Infrastructure Asset Assessment since 2018, and we were delighted with our 4-star result in 2021. We achieved a score of 85/100 and came 6th in our peer group. The GRESB scheme is the leading globally recognised reporting and benchmarking scheme for infrastructure assets. It is a thirdparty independent scheme that our investors rely upon to ensure their investments are meeting best practice standards. The GRESB submission is structured around two important elements namely: management submission items, which examine what you say you will do, and performance data measuring what you actually do. Both are then benchmarked against best practice standards and relevant disclosure frameworks and additionally peer group assessed. The tool helps us identify areas for improvements and allows us to engage with our investors on sustainability topics. We continue to score highly in the management component, which is structured into five aspects: leadership, policies, reporting, risk management and stakeholder engagement, due to our ESG strategy and reporting frameworks. We also score highly in the performance component of the survey in which we submit data relating to our energy, greenhouse gas, water and waste performance, as well as health and safety and employee and customer metrics. We hope to continue reporting to GRESB and improve our score on an annual basis to drive continual development. We are currently in preparation for our 2022 report.
Members of RemunerationtheCommittee’
Members of the Audit and Risk Committee
Peter McCarthy Executive Director Philip Doyle Non-Executive Director Colm O’Neill Non-Executive Director Alastair Small Non-Executive Director
SFG Board of Directors
Figure 6
Cybersecurity Policy: Sets out the permitted use of social media, internet usage and smartphones. Sets out guidelines around SFG’s IT equipment, networks and email access/ usage; and the responsibilities of the SFG IT department.
Greenhouse Gas Policy
Data Protection Policy
The policy notes SFG’s commitment to the environment. It defines activities contributing to greenhouse gas emissions (GHG), how GHG is calculated and how it is monitored and reported Energy Policy
The policy notes SFG’s commitment to the environment and how it wishes to co-ordinate energy saving activities. It defines activities contributing to higher energy usage within SFG, how this will be calculated, monitored and reported.
Key Governance Policies:
Anti-Bribery & Corruption Policy: Sets out the responsibilities in observing and upholding our position on bribery and corruption. Sets out possible ‘red flags’, how to raise a concern and the consequences if found to be in breach of this policy.
Lobbying and Political Contributions Policy
This policy sets out the responsibilities of enet, Magnet and Airspeed as data controllers under GDPR; the rights of its data subjects; and also its procedures around the disclosure, retention and disposal of such personal data.
Employee Engagement Policy Sets out what employee engagement is, its benefits and how SFG is committed its implementation. Notes the role of management, the importance of feedback, career development and performance management.
Power Reduction Policy Notes the wastefulness and expense of Air Conditioning (A/C). The policy notes how it wishes to introduce free cooling as opposed to the traditional A/C system. Other solutions are also being considered.
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This policy defines speaking up or ‘whistleblowing’ and sets out the procedure for which an employee can raise a concern. It also notes the protection and support given to reporting employees.
Modern Slavery & Human Trafficking Polic This policy serves as a recognition of slavery and human trafficking by SFG and sets out its sets out a number of actions for identifying and mitigating modern slavery and human trafficking and notes disciplinary action if in breach of this policy.
Conflict of Interest, Hospitality and Gifts Policy: Sets out the correct procedure when receiving or providing gifts and how to report concerns. Highlights training available and is to be read in conjunction with the Anti-Bribery and Corruption Policy.
Community Development Policy Sets out SFG’s commitment to conscientious practices, community involvement, educational commitments.
This policy sets out the waste management guidelines. This includes how we monitor and report, implement and practice waste management. Also notes the responsibility of the facility manager in the co-ordination and gathering of data around this topic.
Speaking Up Policy
Waste Policy
Figure 7
This policy defines lobbying and notes that political contributions in connection with SFG are not allowed. It also highlights what relevant and excepted communications are; who a DPO is and the Lobbying Returns process.
The commitment to monitor, assess and develop the capability of the workforce. SFG will provide regular feedback to employees and wants to ensure maximal job satisfaction and job performance, as well as identifying and rectifying underperformance.
Anti-Bribery & Corruption Policy: Sets out the responsibilities in observing and upholding our position on bribery and corruption. Sets out possible ‘red flags’, how to raise a concern and the consequences if found to be in breach of this policy.
Performance Management Policy
P 26 SPEED FIBRE GROUP Greenhouse gas (GHG) emissions and energy use data for the period 1 January 2021 to 31 December 2021 of Speed Fibre Group 2021 Total energy consumption used to calculate emissions (kWh) 3,265,536 Energy consumption break-down (kWh): • gas 0 • electricity 2885297 • transport fuel 380238 Scope 1 emissions (tonnes CO2e) Gas consumption 0 Fuel Consumption in car fleet 96 Scope 2 emissions (tonnes CO2e) Purchased electricity 946 Scope 3 emissions (tonnes CO2e) Business travel in employee-owned vehicles (average car, various fuel) 43 Total gross emissions (tonnes CO2e) 1085 Appendix 1: Energy and Carbon Data The table below sets out the environmental performance data for the 2021 calendar year for Speed Fibre Group in 2021. Data is provided in both energy consumption (kWh) and carbon tonnes (CO2e). As Speed Fibre Group continues to improve the quality and accuracy of its environmental performance data, the annual figures reported below will be used for inter-annual comparison. Speed fibre Group is also investigating the feasibility of setting reductive targets for which this data will form the baseline.
Scope 3 Emissions: When calculating our scope 3 emissions to understand the effect of hybrid working on our emissions, the following assumptions were used: Hybrid (2022) Assumptions
5. Expensed milage for 2022 has been included and forecasted out to Dec 2022.
4. Assumption that all employees travel to work by car.
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4. Assumption that all employees took 4x week’s annual leave + 1 week for public holidays.
1. 5-day milage from April 2021 onwards has been included for essential roles.
Data Accuracy: EVORA Global Limited (EVORA) has been appointed by Speed Fibre Group to complete a limited check of reported energy consumption data presented within this report. Environmental performance data (electricity and gas) is based on invoiced data. Records of estimated consumption data, and methodologies used have been reviewed and are held on file.
4. Assumption that all employees will take 4x week’s annual leave + 1 week for public holidays.
1. 5-day milage has been included for all employees (aside from those who work shift)
2. 5-day milage has been included for essential roles.
3. 4-day milage has been included for NOC Engineers working on shift.
3. Assumption that all other employees travelled to the office an average of 5 times in 2021.
About EVORA: EVORA is an independent, pan-European sustainability consultancy and software provider, specialising in the real assets sector.
5. All expensed milage for 2021 has been included.
2. 4-day milage from April 2021 onwards has been included for NOC Engineers working on shift.
1. Forecasted that each employee will come to the office 1 day per week (aside from those we know travel more than 1 day)
3. Assumption that all employees travel to work by car.
2. All expensed milage for 2019 has been included.
Work from home (2021) Assumptions
Work from office (2019) Assumptions
4. Assumption that all employees travel to work by car.
