13. TRANSPARENCY AND CORPORATE REPORTS
MUHAMMAD M. Ma’aji, RADU Mares
Releasing a social report is the last step of the human rights due diligence process. Today, the private sector enjoys a lower level of trust from stakeholders compared to some decades ago, as numerous corporate scandals and human rights abuses have come to light through the influence of 24-hour media, social media, and the internet. Even if a company makes genuine efforts to manage its impacts diligently (chapters 7-12), it will not be taken at its word. It is today increasingly expected that companies publish an honest and informative CSR report and communicate with affected stakeholders in other ways. This need for social reporting has become well recognized since the late 1990s when the Global Reporting Initiative was formed as a multistakeholder initiative (chapter 5) to offer guidance and indictors on how to write a proper CSR report. Despite this early start and other models of reporting, it apparently remains very difficult to strike the right balance: how to deliver a report that captures meaningful information on performance, can be communicated in an understandable manner, with just the right level of specificity and comprehensiveness? After the UNGPs were finalised in 2011, a specific reporting framework just for the UNGPs was launched in 2015, with the aim of promoting the production of those elusive simple yet meaningful corporate reports. Transparency is strategically important not only for building trust with stakeholders, but also as a regulatory technique (chapter 4). Global supply chains are very difficult to regulate with more prescriptive and coercive types of ‘strong’ regulation (chapters 1 and 6); while in contrast, transparency laws are not as prescriptive and allow for an increasing number of private and public actors to exercise pressure on companies through rewards and sanctions. They are therefore more politically acceptable and may make up an intermediary step towards much stronger regulations to hold abusive companies accountable. Increased transparency is therefore essential: it is a key governance tool that empowers stakeholders to monitor and engage with companies, allows market actors to exercise their leverage, facilitates exposing abuses of power, and creates opportunities for legislatures to shape business conduct in new ways (chapters 16, 28).
Sustainability reporting is a relatively new concept in Cambodia. Most companies and their stakeholders are not aware of the strategic importance of such reporting in generating competitive advantage. Corporate commitment to sustainable development can significantly contribute to raising people’s living standards, reducing poverty, and strengthening economic competitiveness. At present, a relatively small number of companies in Cambodia have actively engaged in sustainability reporting. Studies have showed that sustainability reporting by companies in Cambodia had increased continuously over the last ten years. The largest share is accounted for by companies in the financial sector, followed by the tourism and leisure sector and the telecommunications sector. However, at present, there is no national standard for sustainability reporting for companies in Cambodia. Nonetheless, companies are involved as stakeholders in the country’s development strategy. The majority of Cambodian companies base their sustainability reporting on the internationally recognized and employed GRI framework. According to the G20/OECD Principles of Corporate Governance, a strong disclosure regime that promotes transparency is a pivotal feature of market-based company monitoring and is thus central to shareholders’ ability to exercise their ownership rights on an informed basis. Transparency and disclosure practices remain an issue in Cambodia despite the country’s implementation of the IFRS standards and that information transparency and disclosure requirements are included in many provisions of the LCE and Prakas No. 013/10 by the SECC on Corporate Governance of Listed Companies. Going forwards, businesses in Cambodia will need to change their mindset on sustainable practices and reporting as expectations on corporate responsibility increase. As transparency becomes more prevalent, companies are recognizing the need to act on sustainability.
- Sustainability reporting
- Forms of reporting
- Principles of reporting
- Reporting (process and outcome)
- International reporting frameworks
- Salient issues in reporting (severe human rights impacts)
- Materiality (of information)
- Freedom of expression
- Accountability through transparency
- Stakeholder participation
- Financial and sustainability reporting
- Sustainable development goals
- ‘New governance’ and regulation
Shift, Human Rights Reporting
What is the value of reporting? As corporate reporting on “sustainability” or “social responsibility” has become normal practice for leading companies, so too have concerns arisen about the lack of value of that reporting. Many companies complain that these reports are a significant drain on resources and fail to help the company improve its performance. Many readers, including investors and civil society organizations, find these reports offer little real insight into how well a company is managing its impacts on people.
Yet a smart approach to reporting can be a tremendous driver of improved performance. This is as true for reporting on human rights as for other non-financial or financial matters. It requires that the reporting process focus attention and resources on the critical questions the company needs to be able to answer internally, if it is to manage its risks and performance effectively. As such, the process of smart reporting serves as much to improve management systems as to identify information for disclosure. (…)
We are living in an era when companies face serious challenges to doing business responsibly. Yet expectations are only rising as increasing numbers of people around the world realize the significant implications – both negative and positive – of corporate conduct toward people and our environment. In 2016 the international community introduced the Sustainable Development Goals, with the ambition for all actors – including companies – to help more people live better lives around the globe. Doing business responsibly – respecting people’s human rights throughout the company’s own operations and value chains – represents the single greatest contribution that companies can make to the social dimensions of the Sustainable Development Goals. This is a potentially transformative opportunity for companies at a major scale – and it begins with doing business with respect for human rights.
With this sharpened focus on the role of business in the world, the value placed on sound information, transparency, dialogue and accountability should increase. As the research and analysis in this report clearly demonstrate, good reporting and good performance are integrally related when it comes to corporate respect for human rights. Good reporting processes bring to light within companies gaps in knowledge and practice that need to be addressed. Good reporting outputs also enable more informed discussions with investors and other stakeholders, which in turn help identify ways to improve systems and practices. And as performance improves, this enables companies to report on their progress and become investments, partners and employers of choice.
UN, Guiding Principles on Business and Human Rights
21. In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:
(a) Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;
(b) Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;
(c) In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.
(…) Communication can take a variety of forms, including in-person meetings, online dialogues, consultation with affected stakeholders, and formal public reports. Formal reporting is itself evolving, from traditional annual reports and corporate responsibility/sustainability reports, to include on-line updates and integrated financial and non-financial reports. (…)
Shift & Mazars LLP, UN Guiding Principles Reporting Framework
Part A: Governance of Respect for Human Rights
What does the company say publicly about its commitment to respect human rights?
A1.1 How has the public commitment been developed?
A1.2 Whose human rights does the public commitment address?
A1.3 How is the public commitment disseminated?
Embedding respect for human rights
How does the company demonstrate the importance it attaches to the implementation of its human rights commitment?
A2.1 How is day-to-day responsibility for human rights performance organized within the company, and why?
A2.2 What kinds of human rights issues are discussed by senior management and by the Board, and why?
A2.3 How are employees and contract workers made aware of the ways in which respect for human rights should inform their decisions and actions?
A2.4 How does the company make clear in its business relationships the importance it places on respect for human rights?
A2.5 What lessons has the company learned during the reporting period about achieving respect for human rights, and what has changed as a result?
Part B: Defining the Focus of Reporting
B1 Statement of salient issues: State the salient human rights issues associated with the company’s activities and business relationships during the reporting period.
B2 Determination of salient issues: Describe how the salient human rights issues were determined, including any input from stakeholders.
B3 Choice of focal geographies: If reporting on the salient human rights issues focuses on particular geographies, explain how that choice was made.
B4 Additional severe impacts: Identify any severe impacts on human rights that occurred or were still being addressed during the reporting period, but which fall outside of the salient human rights issues, and explain how they have been addressed.
Part C: Management of Salient Human Rights Issues
Does the company have any specific policies that address its salient human rights issues and, if so, what are they?
C1.1 How does the company make clear the relevance and significance of such policies to those who need to implement them?
What is the company’s approach to engagement with stakeholders in relation to each salient human rights issue?
C2.1 How does the company identify which stakeholders to engage with in relation to each salient issue, and when and how to do so?
C2.2 During the reporting period, which stakeholders has the company engaged with regarding each salient issue, and why?
C2.3 During the reporting period, how have the views of stakeholders influenced the company’s understanding of each salient issue and/or its approach to addressing it?
How does the company identify any changes in the nature of each salient human rights issue over time?
C3.1 During the reporting period, were there any notable trends or patterns in impacts related to a salient issue and, if so, what were they?
C3.2 During the reporting period, did any severe impacts occur that were related to a salient issue and, if so, what were they?
Integrating findings and taking action
How does the company integrate its findings about each salient human rights issue into its decision-making processes and actions?
C4.1 How are those parts of the company whose decisions and actions can affect the management of salient issues, involved in finding and implementing solutions?
C4.2 When tensions arise between the prevention or mitigation of impacts related to a salient issue and other business objectives, how are these tensions addressed?
C4.3 During the reporting period, what action has the company taken to prevent or mitigate potential impacts related to each salient issue?
How does the company know if its efforts to address each salient human rights issue are effective in practice?
C5.1 What specific examples from the reporting period illustrate whether each salient issue is being managed effectively?
How does the company enable effective remedy if people are harmed by its actions or decisions in relation to a salient human rights issue?
C6.1 Through what means can the company receive complaints or concerns related to each salient issue?
C6.2 How does the company know if people feel able and empowered to raise complaints or concerns?
C6.3 How does the company process complaints and assess the effectiveness of outcomes?
C6.4 During the reporting period, what were the trends and patterns in complaints or concerns and their outcomes regarding each salient issue, and what lessons has the company learned?
C6.5 During the reporting period, did the company provide or enable remedy for any actual impacts related to a salient issue and, if so, what are typical or significant examples?
Structure of the UN Guiding Principles Reporting Framework
The Reporting Framework is divided into three parts:
- Part A has two overarching questions, each with one or more supporting questions, which focus on the company’s commitment to and governance of human rights risk management.
- Part B provides a filter point for the reporting company to narrow the range of human rights issues on which it will focus the remainder of its reporting under Part C. The focus is on those human rights issues that are salient within its activities and business relationships.
- Part C has six overarching questions, each with one or more supporting questions, which focus on the effective management of each of the salient human rights issues on which the company is reporting.
The overarching questions in Parts A and C focus on general, relevant information about the company’s efforts to meet its responsibility to respect human rights. They are designed to enable responses from any company, including small companies and those at a relatively early stage in the process.
The supporting questions highlight more substantial and detailed information that would improve the quality of the reporting company’s response to the overarching question. Each company can assess how many of these supporting questions it can answer, and to what extent.
Defining salient human rights issues
The key concept for using the UN Guiding Principles Reporting Framework is the concept of salient human rights issues, since it is these issues on which the reporting company will focus its reporting.
A company’s salient human rights issues are those human rights that are at risk of the most severe negative impact through its activities or business relationships.
The focus of salient human rights issues is therefore on the most severe potential negative impacts on human rights. Most severe: defined in the Guiding Principles as those impacts that would be greatest in terms of:
- their scale: the gravity of the impact on the human right(s); and/or
- their scope: the number of individuals that are or could be affected; and/or
- their remediability: the ease with which those impacted could be restored to their prior enjoyment of the right(s).
There are a number of cross-cutting principles that should guide the use of the UN Guiding Principles Reporting Framework.
- Setting human rights reporting in the business context
- Meeting a minimum threshold of information
- Demonstrating ongoing improvement
- Focusing on respect for human rights
- Addressing the most severe impacts on human rights
- Providing balanced examples from relevant geographies
- Explaining any omission of important information
Global Reporting Initiative, Sustainability Reporting Standards
GRI 400: Social
402: Labor/Management Relations
403: Occupational Health and Safety
404: Training and Education
405: Diversity and Equal Opportunity
407: Freedom of Association and Collective Bargaining
408: Child Labor
409: Forced or Compulsory Labor
410: Security Practices
411: Rights of Indigenous Peoples
412: Human Rights Assessment
413: Local Communities
414: Supplier Social Assessment
415: Public Policy
416: Customer Health Safety
417: Marketing and Labeling
418: Customer Privacy
419: Socioeconomic Compliance
The Reporting Principles are fundamental to achieving high quality sustainability reporting. An organization is required to apply the Reporting Principles if it wants to claim that its sustainability report has been prepared in accordance with the GRI Standards (…). The Reporting Principles are divided into two groups: principles for defining report content and principles for defining report quality.
1.3 The report shall cover topics that:
1.3.1 reflect the reporting organization’s significant economic, environmental, and social impacts; or
1.3.2 substantively influence the assessments and decisions of stakeholders.
An organization is faced with a wide range of topics on which it can report. Relevant topics, which potentially merit inclusion in the report, are those that can reasonably be considered important for reflecting the organization’s economic, environmental, and social impacts, or influencing the decisions of stakeholders. In this context, ‘impact’ refers to the effect an organization has on the economy, the environment, and/or society (positive or negative). A topic can be relevant – and so potentially material – based on only one of these dimensions.
In financial reporting, materiality is commonly thought of as a threshold for influencing the economic decisions of those using an organization’s financial statements, investors in particular. A similar concept is also important in sustainability reporting, but it is concerned with two dimensions, i.e., a wider range of impacts and stakeholders. In sustainability reporting, materiality is the principle that determines which relevant topics are sufficiently important that it is essential to report on them. Not all material topics are of equal importance, and the emphasis within a report is expected to reflect their relative priority.
A combination of internal and external factors can be considered when assessing whether a topic is material. These include the organization’s overall mission and competitive strategy, and the concerns expressed directly by stakeholders. Materiality can also be determined by broader societal expectations, and by the organization’s influence on upstream entities, such as suppliers, or downstream entities, such as customers. Assessments of materiality are also expected to take into account the expectations expressed in international standards and agreements with which the organization is expected to comply. (…)
It is important that the organization can explain the process by which it determined the priority of topics. (…)
In defining material topics, the reporting organization has taken into account the following factors:
- Reasonably estimable economic, environmental, and/or social impacts (such as climate change, HIV-AIDS, or poverty) identified through sound investigation by people with recognized expertise, or by expert bodies with recognized credentials;
- The interests and expectations of stakeholders specifically invested in the organization, such as employees and shareholders;
- Broader economic, social, and/or environmental interests and topics raised by stakeholders such as workers who are not employees, suppliers, local communities, vulnerable groups, and civil society;
- The main topics and future challenges for a sector, as identified by peers and competitors;
- Laws, regulations, international agreements, or voluntary agreements of strategic significance to the organization and its stakeholders;
- Key organizational values, policies, strategies, operational management systems, goals, and targets;
- The core competencies of the organization and the manner in which they can contribute to sustainable development;
- Consequences for the organization which are related to its impacts on the economy, the environment, and/or society (for example, risks to its business model or reputation) (…)
Reasons for omission
3.2 If, in exceptional cases, an organization preparing a sustainability report in accordance with the GRI Standards cannot report a required disclosure, the organization shall provide in the report a reason for omission that:
3.2.1 describes the specific information that has been omitted; and
3.2.2 specifies one of the following reasons for omission from Table 2, including the required explanation for that reason.
International Integrated Reporting Framework
An Integrated Report
The primary purpose of an integrated report is to explain to providers of financial capital how an organization creates value over time. An integrated report benefits all stakeholders interested in an organization’s ability to create value over time, including employees, customers, suppliers, business partners, local communities, legislators, regulators and policy-makers.
The International <IR> Framework (the Framework) takes a principles-based approach. The intent is to strike an appropriate balance between flexibility and prescription that recognizes the wide variation in individual circumstances of different organizations while enabling a sufficient degree of comparability across organizations to meet relevant information needs. It does not prescribe specific key performance indicators, measurement methods, or the disclosure of individual matters, but does include a small number of requirements that are to be applied before an integrated report can be said to be in accordance with the Framework.
An integrated report aims to provide insight about the resources and relationships used and affected by an organization – these are collectively referred to as “the capitals” in this Framework. It also seeks to explain how the organization interacts with the external environment and the capitals to create value over the short, medium and long term.
The capitals are stocks of value that are increased, decreased or transformed through the activities and outputs of the organization. They are categorized in this Framework as financial, manufactured, intellectual, human, social and relationship, and natural capital, although organizations preparing an integrated report are not required to adopt this categorization or to structure their report along the lines of the capitals.
The ability of an organization to create value for itself enables financial returns to the providers of financial capital. This is interrelated with the value the organization creates for stakeholders and society at large through a wide range of activities, interactions and relationships. When these are material to the organization’s ability to create value for itself, they are included in the integrated report.
Integrated Report – Content Elements
An integrated report includes eight Content Elements that are fundamentally linked to each other and are not mutually exclusive:
- Organizational overview and external environment: What does the organization do and what are the circumstances under which it operates?
- Governance: How does the organization’s governance structure support its ability to create value in the short, medium and long term?
- Business model: What is the organization’s business model?
- Risks and opportunities: What are the specific risks and opportunities that affect the organization’s ability to create value over the short, medium and long term, and how is the organization dealing with them?
- Strategy and resource allocation: Where does the organization want to go and how does it intend to get there?
- Performance: To what extent has the organization achieved its strategic objectives for the period and what are its outcomes in terms of effects on the capitals?
- Outlook: What challenges and uncertainties is the organization likely to encounter in pursuing its strategy, and what are the potential implications for its business model and future performance?
- Basis of presentation: How does the organization determine what matters to include in the integrated report and how are such matters quantified or evaluated?
UN Global Compact, Reporting Requirements
Submitting an annual COP [Communication on Progress] is at the heart of your company’s commitment to the UN Global Compact and provides valuable information to your stakeholders. (…) Because our participants are all at different stages in their sustainability journeys, COPs are categorized into three differentiation levels based on the depth of their disclosure. We also collaborate with other frameworks — for example, the Global Reporting Initiative (GRI) — to ensure that the standards are aligned and that meeting the requirements of one framework helps to comply with the others.
Based on a company’s self-assessment, each COP falls into one of the following differentiation levels:
- GC Advanced: COPs that qualify as GC Active and, in addition, cover the company’s implementation of advanced criteria and best practices
- GC Active: COPs that meet the minimum requirements
- GC Learner: COPs that do not meet one or more of the minimum requirements
COP Minimum Requirements
Business participants are required to communicate progress annually to stakeholders A COP is a direct communication from business participants to their stakeholders. For this reason, participants are required to make their COP widely available. While the overall format is flexible, each COP must contain the following three elements:
a. A statement by the chief executive expressing continued support for the Global Compact and renewing the participant’s ongoing commitment to the initiative and its principles.
b. A description of practical actions (i.e., disclosure of any relevant policies, procedures, activities) that the company has taken (or plans to undertake) to implement the Global Compact principles in each of the four issue areas (human rights, labour, environment, anti-corruption). Note: In cases where a COP does not address one or more of the four issue areas, it must provide an explanation (“report or explain”).
c. A measurement of outcomes (i.e., degree to which targets/performance indicators were met, or other qualitative or quantitative measurements of results).
Shift & Mazars, UNGP Reporting Database
The Database currently includes 113 companies from 11 sectors. Sectors represented are: apparel and footwear; banking and financial services; food and beverage; ICT; infrastructure, construction and building materials; oil equipment and services; oil, gas and extractives; palm oil; personal care; tobacco; transportation and transport operators. Per sector, we review the largest companies by market capitalization.
The Database is searchable by sector, headquarters location, salient issue, company and question of the Reporting Framework. The results are viewable in your browser or downloadable as an Excel file.
Apple, Supplier Responsibility Report
A supplier employee takes worker voice to new heights
In 2013, Xu Yuexia joined CSMC, an Apple final assembly facility in Jiangsu, China, as an operator. On her first day of work, Xu was trained on local employment laws, as well as Apple’s Supplier Code of Conduct.
Through the years, Xu rose up the ranks from management trainee to multifunction employee to supervisor. While developing her career, Xu also worked to develop a team of employees dedicated to providing worker rights advocacy to the over 40,000 employees at CSMC. In 2015, Xu became a member of the Moral Support team. The team acts as a support network for employees, providing a place where they can voice their concerns, which are then brought to management. The Moral Support team also arranges community service projects and team-building activities, and promotes company culture.
Xu is very dedicated to the Moral Support team and has helped increase their impact significantly. In 2017, she organized over 50 employee forums. As a result of these forums, more than 100 cases were brought to management and workplace improvements were made. Xu and team also work directly with Apple to identify employees with grievances during assessment visits and interviews. Xu finds that her role is always evolving, but she enjoys the challenge of learning new things. She’s very proud of the Moral Support team’s results and their ability to improve the lives of her fellow employees.
Going further to fight bonded labor
Bonded labor occurs when a person is forced to work in exchange for the repayment of a debt or other obligation — sometimes levied as a fee for receiving a job in the first place. In 2008, we made this a Core
Violation of the Apple Supplier Code of Conduct and limited permissible fees to one month’s wages.
In 2015, Apple went even further — leading the way in mandating that zero fees can be charged to supplier employees for recruitment opportunities, even if those fees fall within the legal limits of the supplier’s operating country. If bonded labor is discovered, the supplier is required to repay the recruitment fees in full to all impacted employees.
If debt-bonded labor is uncovered, immediate action is taken:
Underage labor is unacceptable
Apple strictly prohibits underage labor in our Supplier Code of Conduct. In addition to a zero tolerance policy, we partner with suppliers to continuously improve training, communication, and detection methods for false identification to eliminate underage labor throughout the supply chain.
How We Identify Underage Labor:
Identifying underage labor is not enough, the supplier must:
Adidas, Annual Report
Working Conditions in Our Supply Chain
In 2019, we conducted initial assessments (IA), the first approval stage for new entry into our supply chain, in 189 factories (2018: 221), a decrease of 14% compared to 2018, mainly due to our decision to grow in existing factories rather than onboarding new ones. 49 factories (2018: 55 factories) were either rejected directly after the initial assessment identified zero-tolerance issues, or were ‘rejected with a second visit’ due to identification of one or more threshold issues, which means they were rejected but given the chance to remediate the non-compliance issues within a specific timeframe. The vast majority (84%) of all initial assessments were undertaken in Asia (2018: 90%), with China accounting for 38% of these assessments (2018: 41%).
Overall, at the end of 2019, the ‘first-time rejection rate’ of 34% of all new factories visited was slightly higher than in the previous year (2018: 30%), as was the ‘final rejection rate’, which increased to 4% in 2019. The latter was due to the rigor applied to the initial assessments. The remediation of factory issues is beneficial for workers as it raises the bar in terms of better and timelier pay, improved benefits, reduced hours, and the legal protection of formal employment contracts, and it results in significant improvements in basic health and safety within the workplace. Suppliers who have threshold issues are normally given three months to remediate those issues before being re-audited for final acceptance.
Shortcomings identified in active factories
Our suppliers’ factories are evaluated against a number of critical compliance issues. While threshold issues are serious but correctable non-compliances that can be addressed in a specified timeframe through remedial action, zero-tolerance issues – such as forced labor, child labor practices and critical life-threatening health, safety and environment conditions – immediately trigger a warning and potential disqualification of a supplier. We report these non-compliance findings that were identified through performance audits, collaboration audits and self-governance assessments in 2019. We follow up on all cases of non-compliance and seek to remediate them within a given timeframe. As can be seen below, the identified issues in 2019 remained largely the same as those in 2018.
Warning letters are an essential part of our enforcement efforts and are triggered when we find ongoing serious noncompliance issues that need to be addressed by our suppliers’ factories. We work closely with our suppliers to help them improve their performance. However, where we face situations of severe or repeated non-compliance, we do terminate business relationships with factories.
Warning letters: In 2019, we had a total of 41 active warning letters (2018: 39) across 14 countries. The largest number of warning letters continues to be issued in Asia. Compared to the previous year, the overall number of active first warning letters decreased slightly; the total number of second warnings increased from one in 2018 to six in 2019. Factories that receive second warning letters are only one step away from being notified of possible termination of the manufacturing agreement and receive focused monitoring by the SEA team. The number of third warning letters issued to business partners (which result in factory terminations) remained stable in 2019 (2018: 1). It is difficult to generalize about the grounds for a warning letter as it may be issued for a single unresolved non-conformance or for multiple breaches of our standards. The range of issues that resulted in warning letters in 2019 due to non-compliance regarding fire safety practices, receipt of wages, social and medical insurance, hazardous chemicals management, overtime, deductions, transparency or safety controls in high-risk areas remained the same compared to the previous year.
Terminations: In 2019, we terminated agreements with two suppliers for compliance reasons (2018: 1). In one case there was inadequate progress in remediating serious migrant labor issues and in the other the supplier refused to grant the SEA team access to audit the factory.
While terminations happen at our existing factories, we pre-screen all new factories and if our initial assessments uncover zero-tolerance or threshold issues factories are rejected.
Nike, Sustainable Business Report
At NIKE, we look at sustainability throughout our value chain. This view is vital because most of our environmental and social impacts – as well as our opportunities – occur within our influence, but outside of our direct control. (…)
In FY14/15, we conducted an in-depth quantitative analysis to review and prioritize our key sustainability issues. First, we reviewed multiple ESG standards, frameworks, and rating systems. Next, we added current megatrends, stakeholder feedback, and the priorities of our key coalitions and partnerships to develop a complete universe of issues that would be relevant to NIKE’s business model. This netted us upwards of approximately 400 potential topics. Then, we filtered for relevance by looking at location, risk, and other measures to determine 12 priority issues and mapped these against each stage in our value chain.
These results were key to internal strategy conversations and have supported our understanding that the two leading drivers of our environmental and social impacts are:
- The materials we use in our products, and
- The outsourced manufacturing of those products.
In FY17, we brought the voices of internal and external stakeholders into this analysis. We reached out to a wide range of stakeholders, including employees, NGOs, academics, investors, suppliers, and corporate peers.
Our survey was designed to identify the most relevant issues at each value chain stage and the impacts most directly linked to those issues. (…)
FY16/17 priority issues
|active kids (previously community impact)|
|child labor (previously labor compliance)|
|freedom of association (previously labor compliance)|
|non-renewable resource depletion|
|material waste (new issue)|
|occupational health & safety|
In 2011, we established a 2020 target to source only from factories that meet our definition of sustainable, or rate ‘Bronze’ on our Sustainable Manufacturing & Sourcing Index (SMSI). To assess progress, we regularly audit contract factories against our Code of Conduct and Code Leadership Standards, often with the support of independent third-party organizations such as Better Work (a joint program of the United Nations ILO and the International Finance Corporation, a member of the World Bank Group) and the Fair Labor Association (FLA). Results of audits done by these third-party organizations are shared transparently through their sites.
While 91 percent of our factories now achieving bronze status or higher represents real progress, 10 percent of our contract manufacturers did not meet our required standards for compliance at the end of FY17. When factories fall below compliance, they are given time to correct the issues. Those failing to remediate issues prior to their next audit are placed on probation and re-audited six months later. Failure to meet NIKE’s bronze standard at that point will prompt consideration of a potential responsible exit. If critical issues are found, immediate remediation is required. We continue to review the most frequent areas of non-compliance, such as hours, wages, and benefits to identify ways we can work with our contract factories to strengthen compliance.
BHP, Sustainability Report
As a global company, we interact with a range of stakeholders. Our methods and frequency of communicating to, and with, stakeholders are also diverse.
- Globally, we communicate via our Annual General Meetings, corporate publications (including the Annual Report, Sustainability Report and other topic-specific reports), our website (bhp.com), releases to the market and media, analyst briefings, speeches and interviews with senior executives.
- At a regional and local level, each asset is required to plan, implement and document stakeholder engagement activities. This includes newsletters and reports; community perception surveys and consultation groups; implementing community complaints and grievance mechanisms; and representation on specific industry association committees and initiatives.
- As a key stakeholder group, we also engage with our people (employees and contractors) via tailored internal channels.
These channels include our intranet; email and newsletters; town halls; and by inviting feedback and comment through employee perception surveys.
Our key stakeholders include:
- business partners
- community-based organisations
- employees and contractors
- governments and regulators
- industry peers and associations
- labour unions
- local and Indigenous communities
- non-government organisations
- shareholders and investment organisations
- society partners
- suppliers and customers
Reporting boundary and scope
This Sustainability Report covers BHP’s assets (including those under exploration, projects in development or execution phases, sites and closed operations) that have been wholly owned and operated by BHP and assets that have been owned as a joint operation which are operated by BHP (referred to in this Report as ‘assets’, or ‘operated assets’ or ‘operations’) during the period from 1 July 2016 to 30 June 2017. Our Marketing and Supply business and our functions are also included.
Respecting human rights
Respecting human rights is critical to the sustainability of our business. (…) We are committed to operate in a manner consistent with the United Nations’ (UN) Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the Voluntary Principles on Security and Human Rights and the 10 UN Global Compact principles.
We aim to identify and manage human rights-related risks in all our activities. (…) A risk-based approach that includes consideration of human rights and community impact issues is required for our decisions around acquisitions and divestments, new activities in high-risk countries and major capital projects. The most relevant human rights issues for our industry include occupational health and safety, labour conditions, activities of security forces, and the rights of Indigenous peoples and communities near our operations. (…)
We set minimum mandatory requirements for all our suppliers and relevant contractors, including zero tolerance in relation to child labour, forced or compulsory labour, freedom of association, living wage, non-discrimination and diversity, workplace health and safety, community interaction and treatment of employees.
Corporate Human Rights Benchmark
In FY2017, BHP received a score of 69 out of 100 in the inaugural Corporate Human Rights Benchmark (CHRB) published by investors and civil society organisations to create a public benchmark of corporate human rights policy, practice and performance. The CHRB is based on publicly available information.
Among the 98 publicly traded companies assessed, BHP was the highest ranked company overall and the highest ranked of 41 extractives companies. We have carefully reviewed the assessment to identify areas where we may be able to enhance our human rights performance.
Vodafone, Sustainable Business Report
Supply chain integrity and safety
Our businesses rely on a very large supply chain spanning around 17,000 companies across dozens of countries. We seek to ensure the safety, wellbeing and ethical treatment of all who work with Vodafone in any capacity, anywhere in the world. However, there is a broad range of labour rights and safety and environmental risks inherent with such a complex supply chain, and many of those risks also arise in the business operations under our own direct control.
Digital rights and freedoms
In 2014, we published our first Law Enforcement Disclosure transparency report setting out the details of how we responded to lawful demands for access to our customers’ private data from law enforcement and intelligence agencies. The report has been updated and expanded since the initial publication and is now widely considered to be the most comprehensive of its kind in the world. During the year, we decided to move away from a static ‘moment in time’ annual transparency report in favour of a continuous disclosure model, reflecting the fact that the issues in question tend to emerge and transform rapidly. We have now launched our new online Digital Rights and Freedoms Reporting Centre containing our policies, principles and views on a wide range of topics including law enforcement surveillance, privacy, data protection, freedom of expression, censorship and the digital rights of the child.
Unilever, Human Rights Progress Report
Our ambition is to embed the respect and promotion of human rights into every function, role and corner of our organisation. As part of meeting that ambition, we made a commitment in 2014 to disclose our efforts and challenges in implementing the UN Guiding Principles on Business and Human Rights.
This report follows our inaugural report on human rights, published in 2015, which was the first report by a business to use the UN Guiding Principles Reporting Framework comprehensively. That first report, ‘Enhancing Livelihoods, Advancing Human Rights’, contains an in-depth analysis and description of our strategy and the foundational steps we have taken, as well as information on our eight salient human rights issues. (…)
Promoting respect for human rights in our business and value chain is an important way of transforming people’s lives and furthering Unilever’s contribution to the UN’s Sustainable Development Goals.
Our Five Focus Areas
We continue to have five areas of focus for our work in embedding human rights across our business:
Salient human rights issues
We define them as the human rights that are at risk of the most severe negative impacts through a company’s activities or business relationships.
We have worked with a range of expert internal and external stakeholders to identify where, and how, our activities could result in risks to human rights, so that we could establish which issues were most salient.
- Fair wages
- Forced labour
- Freedom of association
- Health and safety
- Land rights
- Working hours
Willing to learn
Resolving human rights challenges is often complex, and relies in part on a willingness to listen and learn. In 2016, Oxfam published ‘Labour Rights in Vietnam – Unilever’s Progress and Systemic Challenges’, a follow up to their initial 2013 report on a two-year research project, ‘Labour Rights in Unilever’s Supply Chain’, designed to learn how we could best operationalise the UN Guiding Principles on Business and Human Rights.
Oxfam’s progress update reported considerable improvements against the original report’s recommendations in the areas of supporting workers’ livelihoods, providing human rights training, implementing more ways in which workers can raise areas of concern, and working more closely with suppliers and partners to ensure standards are met. There had been progress in Unilever’s own factory, for example in the areas of wages and direct employment. There is still more work to do such as increasing the opportunities for female factory workers and continuing to ensure that our engagement with suppliers supports both progress on human rights and the business case for responsible sourcing.
Open, frank dialogue and understanding of the challenges and opportunities, particularly at the local level, have been a key part of this work with learnings on both sides.
Hess, Sustainability Reporting as a Regulatory Mechanism
This chapter encourages academics, policy makers, and others, to consider more fully the system required for sustainability reporting to have a meaningful, positive impact on corporate behavior. In short, we need to remember two things. First, transparency is not an end in itself. Any transparency-based policy initiative designed to improve the performance of corporations with respect to issues of sustainability must be based on a clear understanding of how the required disclosures will lead to improved performance. The New Governance approach to regulation, and the pillars of disclosure, dialogue, and development, provide one way to think through those issues. Second, when considering mandated disclosure of sustainability reports, we must be sure to consider how those reports will be used in practice. There needs to be a clear understanding of how we expect the action cycle to work, where the potential breakdown points of the cycle are located due to various actors’ incentives, and how those breakdowns can be avoided or corrected.
North, Corporate Sustainability Practices and Regulation
Public corporations are increasingly acknowledging their role in society and the need to communicate and engage with their many stakeholders. This broader focus is evidenced by sustainability disclosures in the form of management discussion and analysis, standalone sustainability reports and integrated reports.
The paper reviews the use of soft and hard law rules and the disclosure delivery mechanisms within these developing reporting frameworks. It then considers the purposes and intended audience of sustainability disclosures, the requirement for and benefits of mandatory reporting regimes, and the design of a best practice regulatory structure.
It concludes that best practice corporate sustainability decision making, conduct, and reporting require clear objectives and rules and independent monitoring and supervision. It highlights the need for public confidence and trust in corporations and financial markets and suggest this requires companies to install a culture of continuous disclosure, engagement, and accountability with all investors and other stakeholders, especially during periods of stress or crises.
Hess, The Transparency Trap
Unfortunately, the expectation that general transparency programs will increase corporate accountability and encourage positive organizational change with respect to human rights issues is misplaced, as will be shown in this part. First, there are significant limits on the ability of available metrics to convey a meaningful picture of a company’s performance on human rights issues to external stakeholders. Second, in practice, problems such as selective disclosure, impression management, incomparable disclosures (over time and between companies), and treating disclosure as an end in itself (as opposed to a process that leads to organizational change) limit the effectiveness of these programs. (…)
First, there is the problem that “not everything that can be counted counts, and not everything that counts can be counted.” Reports on the complex issues surrounding the responsibility to respect human rights often include a selection of metrics that are based on data that can be most easily collected, as opposed to the most important. This often results in a focus on company policies and procedures, not performance outcomes. For example, metrics on the percentage of employees receiving human rights training or the percentage of suppliers screened for human right issues are easy to create, but they do not capture the effectiveness of those efforts.131 This problem, created by an evaluation of corporations based on available data and easy to construct metrics, is an example of the “streetlight effect,” which is the tendency for people to rely upon the most convenient information rather than the most relevant information. (…)
Many of the prior studies on non-financial disclosure relied upon legitimacy theory, which, as used in these studies, claims that corporations often use disclosure to influence external stakeholders’ perceptions of the corporation’s behavior. A company that does not meet societal expectations of responsible behavior may selectively disclose certain non-financial information to present a factually accurate but misleading picture of the company to influence stakeholders’ perceptions. (…)
More recent studies on non-financial disclosure sought to determine whether the increased experience with sustainability reporting, now that it has become more mainstream, has improved the quality of information and reduced strategic behaviors. These studies generally confirm the legitimacy factors of prior studies. For example, a company that suffered a negative event, or is part of an industry facing significant public issues, will often engage in selective positive disclosure.
In addition to the findings on legitimacy theory, this new evidence indicates that non-financial reporting has not improved significantly in terms of quality, comparability, and comprehensiveness. Researchers have not found evidence of improvement, despite the increased use of and experience with the GRI guidelines and non-financial reporting in general. A common problem is that companies seek to gain legitimacy with external stakeholders by simply disclosing an increased quantity of information and claiming to have complied with the GRI, even though a closer examination casts doubt on the quality of the disclosures. For instance, Michelon and colleagues studied 112 UK company reports to determine if a standalone sustainability report produced in accordance with the GRI and receiving external assurance improved the quality of disclosure. They found that the standalone report approach increased the quantity of non-financial information (though it was also diluted with additional irrelevant information), but none of the three factors studied (standalone report, use of the GRI, and external assurance) increased the quality of the information. The authors argued that these conclusions supported the legitimacy theory prediction that corporations simply disclose to manage their corporate image. (…)
Moreover, the information contained in sustainability reports is often not comparable between companies within a given industry. Comparable information is important for allowing stakeholders to determine the leaders and laggards in an industry, and then push the laggards to improve their performance. Boiral and Henri studied the comparability of information in sustainability reports by examining twelve companies from one industry (mining) that all used the same GRI guidelines. Surprisingly, the authors found that “quantitative indicators are not necessarily the most comparable [indicators].” One reason for this result was that companies used different measurement scales for the same issue. A second reason was the different contexts in which the companies operated —a potentially common problem for many human rights metrics. (…)
One consistent finding across the many studies is that non-financial disclosure, including disclosures in standalone reports in accordance with the GRI, continues to focus on positive information and ignore the negative. In the study of socially responsible investing practitioners, almost ninety percent of the interviewees agreed that “the majority of the companies do not publish information that could contribute to tarnishing their reputation.” Thus, to ensure that they have an accurate picture of the company, these practitioners must supplement the information from reports with other sources of information. (…)
Miethlich, Sustainability Reporting in Cambodia: Hidden Champion of ASEAN
This study aimed to present and analyze the current situation of sustainability reporting in Cambodia to determine whether and in what way sustainable development and its reporting is a concern of Cambodian companies. (…)
The analysis of the GRI Sustainability Disclosure Database showed that sustainability reporting by companies in Cambodia had increased continuously over the last ten years. The largest share is accounted for by companies in the financial sector, followed by the tourism and leisure sector and the telecommunications sector. The companies in the manufacturing sector, most of which are suppliers, do not appear to have sustainability reporting. In terms of company size, it is mainly large companies that carry out sustainability reporting. What is surprising, however, is that SMEs is increasingly disclosing and communicating its commitment to sustainable development. MNEs, on the other hand, only started doing so a few years ago and still make up the smallest share. (…)
Despite the efforts of the Cambodian government to promote sustainable development, only a small proportion of companies in the country communicate their CSR and sustainable development efforts. This is not unusual in the sense that companies are unable to provide sustainability reporting due to the lack of CSR data or available data, associated costs, lack of motivation, or poor corporate performance. (…)
In comparison with the other ASEAN countries, in terms of sustainability reporting, in relation to GDP (PPP), Cambodia is the leader. Thus, it can be said that considering Cambodia’s enormous and rapid development to date, the consistent strategy towards sustainable development pursued by the government and especially in relation to current economic performance, Cambodia today could be seen as a hidden champion of sustainability reporting by ASEAN countries and can thus also serve as a role model for other developing countries.
Law on Commercial Enterprises
Financial Disclosure – Article 224: Annual financial statements
At every annual general meeting of shareholders, the directors shall present an annual financial statement to the shareholders. The statement shall include the following: (a) comparative financial statements for the current financial year and the prior financial year. In the first year of the company’s existence, the financial statement shall cover the period beginning on the date the company came into existence and ending on a date not more than 6 months before the annual meeting; (b) the report of the auditor; and (c) any further information respecting the financial position of the company and the results of its operations required by the articles, the by-laws or any unanimous shareholder agreement.
SEC of Cambodia, Prakas on Corporate Governance of Listed Companies
Chapter II Shareholders
Article 7. Right to Access Information
The Listed Public Enterprise should have a website which the shareholders and the public can access information. Shareholders shall access audited annual financial statements, operating results, any quarterly financial reports, information about the directors and senior officers, and other information about the Listed Public Enterprise. If the Listed Public Enterprise does not have the website, shareholders may request the hard copies of the above mentioned information and are required to pay reasonable fees for the costs of printing and distribution.
Chapter VIII Stakeholders
Article 44. Protection of Stakeholders’ Rights
Creditors, related interest individuals or individuals who have contracted with the Listed Public Enterprise are considered as its stakeholders. All stakeholders’ rights shall be protected. The Listed Public Enterprise shall ensure the protection of all stakeholders’ rights, including:
1. Shall have a clear strategic management policy to support and protect stakeholders’ rights.
2. Shall ensure the compliance with the Labor Law of the Kingdom of Cambodia.
3. Shall not be negligent in its corporate social responsibilities (CSR), such as consumer protection and environmental protection.
4. Shall separate the recognition and protection of individual’s rights when he/she is both a stakeholder and a shareholder.
Article 45. Information and Stakeholder’s Observation
The Listed Public Enterprise shall provide stakeholders, creditors and employees, with all relevant information necessary to enable them to monitor the performance of the Listed Public Enterprise, and shall protect their rights.
Chapter IX Disclosure and Transparency
Article 46. Corporate Control Through Market Mechanism
The Listed Public Enterprise shall establish a transparent and fair mechanism when there are any actions leading to change in corporate control, such as takeovers, mergers, acquisitions and transfers of business or liquidation in accordance with the law on the General Statute of Public Enterprises and the Anukret on the implementation of law on the General Statute of Public Enterprises.
Article 47. Disclosure and Transparency
The Listed Public Enterprise shall disclose, in an efficient and timely manner, information that is required by Law and regulation and any other information that may influence the decision-making of shareholders and other stakeholders.
Material information concerning corporate governance to be disclosed by the Listed Public Enterprise includes:
- The composition of the Board, executive directors, non-executive directors, independent directors, board structure, management structure, incentive policies, policies regarding conflicts of interest and the Code of Conduct for directors and senior officers.
- Rights, roles and duties, and activities of the board’s committees.
- Activities of individual directors and the Board.
Article 48. Format of the Disclosure
The Listed Public Enterprise shall disclose information in an easy-to-understand form, to avoid ambiguous and complicate technical terms. Publicly disclosed information shall be easily accessible and low cost. Where the complicated terms are used in the disclosure, the terms shall be attached with the explanations so that the general public may easily understand.
In the case where the documents to be disclosed is prepared in a foreign language, the Listed Public Enterprise shall translate those documents into Khmer by an agent recognized by the SECC.
The Listed Public Enterprise shall designate an officer to be responsible for disclosed information, include reporting to the market and the SECC by the board, and shall have an internal information control system that can quickly transmit the material information of the Listed Public Enterprise to that officer. To disclose corporate information in a timely, accurate and effective manner, the officer shall have the right to quickly access the information of the Listed Public Enterprise.
ACLEDA Bank, Environmental and Social Sustainability Report
Environmental and social sustainability (ESS) mission statement
ACLEDA Bank is committed to achieving strong, sustainable financial returns, while respecting the environment and community within which we live. We subscribe to the concept of triple bottom line (‘people, planet, profit’) reporting and are constantly developing indicators for measuring and reporting on our performance and impacts on the society and the environment and to implement a reporting structure based on the guidelines of the Global Reporting Initiative. (…)
ACLEDA recognizes that playing our part as good citizens in the community in which we abide is vital to our mutual interests and prosperity. Major initiatives we are taking are:
- Developing and offering appropriate products and services carefully selected and developed for the particular needs of Cambodian society. In 2006 the Bank launched a housing loan scheme, with interest rates fixed for up to 10 years to enable Cambodians, especially in the lower wealth segment, to purchase their own homes.
- Expanding outreach: opening up banking services to new communities in new locations by expanding our network in the provinces and extending online banking services to mobilize savings. The expansion of our 24 hours a day/7 day a week ATM network to all provinces in 2010 has enabled our customers to access their funds at their own convenience, irrespective of the normal opening hours of the Bank or national holidays. In April 2017 we launched ‘ACLEDA Unity ToanChet‘ — a FinTech Application running on Smart Phone, enabling customers to do all ACLEDA Bank services at any time. — Which extends access to financial services in the Khmer language as well as English to every village and commune in Cambodia.
- From November to December 2019, we conducted an annual survey on our small-sized enterprise loan and medium-sized enterprise and corporate loan customers’ living standards that get loans at least twice from our branches to test the impact of our credit services. This involved 1,961 respondents (female: 53.34%) randomly selected from our 316,758 active borrowers of whom 66.95% were traders, 21.32% were farmers/workers and 11.73% were private companies/NGOs/civil servants. The responses indicated that across all sectors there were 92.40% who considered that their wealth had increased as a result of credit provided by ACLEDA Bank, 3.57% who did not detect any noticeable change while only 4.03% had the perception that they were worse off than before.
- Transparency and ‘truth in advertising’ are strictly enforced when developing, advertising and selling our products and services and full and detailed information is provided through brochures, our website and other promotional materials. (…)
- In 2019, ACLEDA Bank Plc. took part in important social and humanitarian activities through the following donations:
- Donation to the ACLEDA-Jardines Education Foundation (AJF) to support the construction of two concrete primary school buildings (Kampong Preah Ent and Pu Cha) in Preah Vihea and Mondulkiri provinces.
- Donation to the Ministry of Education, Youth and Sport to support their program “Our Business”. (…)
- Health Support
- Voluntary blood donations by ACLEDA Bank staff to the National Blood Transfusion Center to help patients in emergency situations.
- Donation to the Cambodia Kantha Bopha Foundation. (…)
NagaCorp, Sustainability Report
NagaCorp [a Cambodian company listed on the Hong Kong’s Stock Exchange] strives to be a good corporate citizen by carrying out business in a socially responsible way and aim at creating long-term values for our stakeholders and contributing to make the world a better place. This report covering the calendar year 2016 is prepared in accordance with the Environmental, Social and Governance (“ESG”) Reporting Guide of the Stock Exchange [in Hong Kong]. It provides an overview of management approach of NagaCorp and its performance relating to ESG. Nagacorp has complied with the “comply or explain” provisions set out in the ESG Reporting Guide for the Year. (…)
1.1 Workforce Overview
NagaCorp prides itself on providing a safe, fair and healthy workplace for all staff, with a diverse workforce and equal opportunities for all. As at 31 December 2016, the Group had a total of 6,153 employees, representing over 29 nationalities, with 99% of the employees based in Cambodia. Priority is given to developing our Cambodian workforce, which represents 94% of total employees. Employees follow designated working hours, meal breaks and rest days according to a rotating shift schedule prepared by each department on the basis of three 8-hour shifts per 24-hours and six consecutive days or 48 hours per work week. Employees based in Cambodia, are entitled to 1.5 days of paid annual leave for every month of service rendered. (…)
- Attracting Talent: (…) In 2016, we hired 1,095 employees (2015: 878) while 660 exited (2015: 691). Reductions in attrition have been achieved by focusing on stricter sourcing and selection criteria, providing more training and development opportunities, increased employee engagement and continuous improvement on the work environment and welfare. (…)
- NagaWorld Olympians: In May 2016, we held the first NagaWorld Olympians. This competitive event provides a platform for employees to showcase their professional skills, attitude, appearance and manners. Future competitions will inspire our employees to achieve further growth and success – not because they are driven to win or lose – but because they are recognised as doing their best at something that they care about. (…)
Founded in November 2012, Naga Academy’s goal is to be an effective and comprehensive apprenticeship-based hospitality training institute. In 2016, Naga Academy trained 297 interns of whom 246 were in apprenticeship based vocational programs of three months or more duration, of which 43% were hired by NagaWorld. During the Year, Naga Academy provided more than 159,420 total training hours to its interns which included 112 hours of pre-deployment training prior to internship in their department of choice.
Smart, Sustainability Highlights
Our sustainability framework adheres to that of the Axiata Group and guides Smart’s sustainability efforts under four key pillars: Beyond Short-Term Profits, Nurturing People, Process Excellence, and Planet & Society. By aligning our practices to the tenets of these four pillars, we can ensure that everything we do is balanced by meeting the needs of all stakeholders who support us in many ways. (…)
We go a step further by empowering Cambodians to look at positive and sustainable ways to help their families and communities through CSR initiatives in the fields of education, community sports, technology and environment. (…)
- Why do you think companies publish CSR reports even when this is not a legal requirement?
- What does ‘materiality’ mean and why is it important in sustainability reporting?
- Why do you think legislators increasingly favour mandatory reporting as a way to promote responsible business conduct?
- What makes it so difficult to identify reporting indicators for human rights and labour standards and to make it obligatory for companies to use such indicators when writing their CSR reports?
- Do investors and shareholders demand only financial information from their companies? If not, why does non-financial information interest profit-seeking investors?
- Are transparency regulations enough to guarantee corporations respect human rights?
- Who reads CSR reports?
- When will CSR reporting become widespread in Cambodia and what factors will be needed for this to become reality?
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 Adidas,Annual report (2019) https://report.adidas-group.com/2019/en/servicepages/downloads/files/adidas_annual_report_2019.pdf.
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