COMPLIANCE

All Sonnedix employees, suppliers and contractors are subject to the high compliance expectations held by our business.

The Audit and Risk Committee of our Board of Directors has oversight responsibility for these matters. To ensure ongoing compliance, Sonnedix has developed a compliance review process summarised below:

Sonnedix compliance review process

GOVERNANCE POLICY AND STANDARDS

Code of Ethics and Business Conduct

Anti-bribery & Corruption Standard

Whistleblowing Policy

GLOBAL PARTNERS STANDARDS OF CONDUCT

Third Party

Questionnaire

Third Party Certification

Prior to entering into an agreement with any Global Partner, we undertake a documented due diligence audit of our partners.

As a first step, an initial risk assessment is carried out to establish the level of due diligence required. Once established, research is conducted by the Legal and Compliance team on the Global Partner’s background, reputation, and qualifications. Having obtained assurance of compliance with our policies and standards, the Global Partner is approved upon completion of the due diligence.

2022 PERFORMANCE

365 due diligence of third parties

Raising awareness of the compliance work carried out by the Legal and Compliance team throughout the business continued to be a priority in 2022, with refreshed training courses and communications implemented throughout the year. Furthermore, we continued to improve and utilise our legal software solutions for integrated management and oversight of our contractual work.

192 new joiners completed the compliance onboarding training

105 parties analysed out of which 6 were placed under trading restrictions

Esg Compliance

Focus On Esg Compliance

Compliance with our ESG Policies and Standards and the Sustainability Strategy is an integral part of our Legal and Compliance programme. An overview of our ESG compliance approach is presented on the right.

Our robust ESG requirements are included in all contracts with Global Partners and enable us to use our influence and commitment to sustainable growth to bring about positive change. These requirements are updated whenever new reporting or compliance needs are identified. We also regularly perform audits of our projects and suppliers to ensure effective implementation on the ground. Performance KPIs are also monitored on a regular basis through monitoring and reporting systems. Internally, we make sure that our One Team is fully aware of how we do things responsibly through mandatory ESG trainings and ESG tailored communication campaigns.

Participation in benchmarks

Training

Audits and inspections

In addition, we request all our new joiners to read and sign their acknowledgement of our ESG Policies and Standards and to complete a mandatory online ESG training within the first two weeks of their employment.

Contractual protections: ESG Exhibit

2022 PERFORMANCE

MAINTAINED 5* GRESB RATING (94/100)

Performance monitoring and reporting software

ESG Policies and Standards

ANNEXES

HSEC AUDITS OF CONTRACTORS 14

15 CRITICAL CONCERNS ADDRESSED