| Principles | Compliance Status | Explanation |
|---|
| A. | GENERAL PRINCIPLES | | |
| A1. | Strategy, Policy and Targets | | |
| 1 | The Board of Directors determines material ESG issues, risks and opportunities and creates ESG policies accordingly. In terms of the effective implementation of these policies; internal directives, business procedures of Companies etc. can be prepared. The Board of Directors takes decisions for these policies and they are publicly disclosed. | Partially Compliant | Some of the policies published in the field of ESG have not yet been approved at the Board level. |
| 2 | Determines the Company Strategy in line with the ESG policies, risks and opportunities. It determines the short and long term goals in line with the Company strategy and ESG policies and makes them public. | Fully Compliant | |
| A2. | Implementation/Monitoring | | |
| 3 | Determines the committees / units responsible for the execution of ESG policies and makes them public. The responsible committee / unit reports the activities carried out within the scope of the policies to the Board of Directors at least once a year and in any case within the maximum periods determined for the public disclosure of the annual activity reports in the relevant regulations of the Board. | Fully Compliant | |
| 4 | Creates and publicly discloses implementation and action plans in line with the short and long term goals determined. | Fully Compliant | |
| 5 | Determines Key ESG Performance Indicators (KPIs) and explains them on a yearly basis. In the presence of verifiable data, it presents KPIs with local and international sector comparisons. | Fully Compliant | |
| 6 | Explains the innovation activities that improve the sustainability performance for business processes or products and services. | Fully Compliant | |
| A3. | Reporting | | |
| 7 | Reports its sustainability performance, goals and actions at least once a year and makes it public. Explains the information on sustainability activities within the scope of the annual report. | Fully Compliant | |
| 8 | It is essential to share information, which is important for stakeholders in understanding the position, performance and development of the Company, in a direct and concise manner. It can also explain detailed information and data on the corporate website, and prepare separate reports that directly meet the needs of different stakeholders. | Fully Compliant | |
| 9 | Takes maximum care in terms of transparency and reliability. It objectively explains all kinds of developments about material issues in disclosures and reporting within the scope of the balanced approach. | Fully Compliant | |
| 10 | Gives information about which of the United Nations (UN) 2030 Sustainable Development Goals its activities are related to. | Fully Compliant | |
| 11 | Makes an explanation regarding the lawsuits filed and / or concluded against environmental, social and corporate governance issues. | Partially Compliant | Environmental or social issues are not directly relevant for the Holding's own activities, and there is no lawsuit filed in 2020 on this matter. However, no regular sharing is made for the lawsuits filed or concluded against Sabancı Holding. |
| A4. | Verification | | |
| 12 | If verified by independent third parties (independent sustainability assurance providers), it discloses its sustainability performance measurements to the public and endeavors to increase such verification processes. | Partially Compliant | It is carried out by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| B. | ENVIRONMENTAL PRINCIPLES | | |
| 13 | Explains policies and practices, action plans, environmental management systems (known by the ISO 14001 standard) and programs in the field of environmental management. | Partially Compliant | Some of the Group companies are in compliance. Studies are carried out to ensure full harmonization throughout the Group. |
| 14 | Complies with environmental laws and other relevant regulations and explains them. | Fully Compliant | |
| 15 | Explains the limitations of the environmental report to be included in the report to be prepared within the scope of the Sustainability Principles, reporting period, reporting date, data collection process and reporting conditions. | Fully Compliant | |
| 16 | Describes the highest responsible person, relevant committees and responsibilities in the Company on the issues of environment and climate change. | Fully Compliant | |
| 17 | Describes the incentives it offers for the management of environmental issues, including the achievement of objectives. | Fully Compliant | |
| 18 | Explains how environmental problems are integrated into business goals and strategies. | Fully Compliant | |
| 19 | Explains the sustainability performance of business processes or products and services and the activities to improve this performance. | Fully Compliant | |
| 20 | Explains how it manages environmental issues along the Company’s value chain and integrates suppliers and customers into its strategies, not just in terms of direct operations. | Partially Compliant | Some of the Group companies are in compliance. Studies are carried out to ensure full harmonization throughout the Group. |
| 21 | Whether it is involved in policy-making processes on environmental issues (sectoral, regional, national and international); It explains the cooperation it has made with the associations, related organizations and non-governmental organizations it is a member of on the subject of environment, and the duties it has taken, if any, and the activities it supports. | Fully Compliant | |
| 22 | Reports information on its impacs in a periodically comparable manner within the scope of environmental indicators (Greenhouse gas emissions (Scope-1 (Direct), Scope-2 (Energy indirect), Scope-3 (Other indirect)), air quality, energy management, water and wastewater management, waste management, biodiversity impacts) | Fully Compliant | Some of the indicators (e.g. NOx) are irrelevant for some Holding and Group companies. Disclosures are made on other relevant matters. |
| 23 | Describes the standard, protocol, methodology and base year details used to collect and calculate its data. | Fully Compliant | |
| 24 | Describes the status of environmental indicators for the reporting year (increase or decrease) in comparison with previous years. | Fully Compliant | |
| 25 | Sets short and long-term goals to reduce their environmental impact and explains these goals. It is recommended that these goals be determined based on Science as suggested by the United Nations Conference of the Parties on Climate Change. If there is progress in the reporting year according to the targets set before, it provides information on the subject. | Partially Compliant | Sabancı Holding explains on its goals in environmental issues but has not yet used Science Based Targets as a common method. |
| 26 | Explains the strategy and actions to combat the climate crisis. | Fully Compliant | |
| 27 | Describes the program or procedures to prevent or minimize the potential negative impact of the products and / or services it offers; explains the actions of third parties to reduce greenhouse gas emissions. | Partially Compliant | Although there are steps towards this issue in Group companies, it is not described comprehensively in all Group companies. |
| 28 | Explains the actions taken to reduce its environmental impacts, the total number of projects and initiatives carried out, and the environmental benefits / revenues and cost savings they provide. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 29 | Reports the total energy consumption data (excluding raw materials) and explains the energy consumption as Scope-1 and Scope-2. | Fully Compliant | |
| 30 | Provides information on electricity, heat, steam and cooling generated and consumed in the reporting year. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 31 | Conducts studies on increasing the use of renewable energy, transition to zero or low carbon electricity and explains these studies. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 32 | Explains the renewable energy production and usage data. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 33 | Makes energy efficiency projects and explains the amount of energy consumption and emission reduction thanks to these studies. | Fully Compliant | |
| 34 | Reports the amount of water withdrawn, used, recycled and discharged from underground or above ground, its sources and procedures (Total water withdrawal by source, water resources affected by water withdrawal; percentage and total volume of recycled and reused water, etc.). | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 35 | Explains whether operations or activities are included in any carbon pricing system (Emission Trading System, Cap & Trade or Carbon Tax). | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 36 | Describes the carbon credit information accumulated or purchased during the reporting period. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 37 | Explains the details if carbon pricing is applied within the Company. | Fully Compliant | |
| 38 | Explains all mandatory and voluntary platforms where it discloses environmental information. | Fully Compliant | |
| C. | SOCIAL PRINCIPLES | | |
| C1. | Human Rights and Employee Rights | | |
| 39 | Forms a Human Rights and Employee Rights Policy with a commitment to fully comply with the Universal Declaration of Human Rights, ILO Conventions which Türkiye has confirmed and the legal framework and regulations governing the operation of corporate life in Türkiye. Discloses the policy in question and the roles and responsibilities associated with its implementation. | Partially Compliant | Although the issue of Human Rights is subject to many policies and processes, it is not determined as a separate policy in all Group companies. In the section number 7 "Our Responsibilities Against Society and Humanity" of the Sabancı Holding Business Ethics Rules, the protection of human rights is emphasized. |
| 40 | Provides equal opportunity in recruitment processes. Considering the supply and value chain effects, it includes fair labor, improvement of labor standards, women's employment and inclusion issues (such as women, men, religious belief, language, race, ethnic origin, age, disability, refugee, etc.) in its policies. | Fully Compliant | |
| 41 | Describes the measures taken along the value chain for the protection of groups sensitive to certain economic, environmental, social factors (low-income groups, women, etc.) or minority rights / equality of opportunity. | Fully Compliant | |
| 42 | It reports developments regarding discrimination, inequality, human rights violations, forced labor, and corrective practices. Explains the regulations against child labor. | Partially Compliant | Disclosed by some of the Group companies. Studies are carried out to ensure full harmonization throughout the Group. |
| 43 | Explains policies regarding investment in employees (training, development policies), compensation, vested benefits, right to unionize, work / life balance solutions and talent management. Determines dispute resolution processes by creating mechanisms for employee complaints and dispute resolution. It regularly explains the activities carried out to ensure employee satisfaction. | Fully Compliant | |
| 44 | It creates occupational health and safety policies and makes them public. Explains the precautions and accident statistics taken to prevent work accidents and health. | Fully Compliant | |
| 45 | It creates and publicly discloses personal data protection and data security policies. | Fully Compliant | |
| 46 | It creates an ethical policy (including work, work ethics, compliance processes, advertising and marketing ethics, open information, etc.) and discloses it to the public. | Fully Compliant | |
| 47 | Explains the work within the scope of social investment, social responsibility, financial inclusion and access to finance. | Fully Compliant | |
| 48 | Organizes information meetings and training programs for employees on ESG policies and practices. | Fully Compliant | |
| C2. | Stakeholders, International Standards and Initiatives | | |
| 49 | It carries out its activities in the field of sustainability by taking into account the needs and priorities of all stakeholders (employees, customers, suppliers and service providers, public institutions, shareholders, society and non-governmental organizations, etc.). | Fully Compliant | |
| 50 | It regulates and publicly discloses a customer satisfaction policy regarding the management and resolution of customer complaints. | Fully Compliant | It is not relevant for the Holding. It is published for the relevant companies within the Group. |
| 51 | Conducts stakeholder communication continuously and transparently; It explains which stakeholders, for what purpose, on what issue and how often it communicated, and the developments in sustainability activities. | Fully Compliant | |
| 52 | It publicly discloses the international reporting standards it has adopted (Carbon Disclosure Project (CDP), Global Reporting Initiative (GRI), International Integrated Reporting Council (IIRC), Sustainability Accounting Standards Board (SASB), Climate-Related Financial Disclosures Task Force (TCFD), etc.). | Fully Compliant | |
| 53 | Discloses the international organizations or principles (Equator Principles, United Nations Environment Program Finance Initiative (UNEP-FI), United Nations Global Principles (UNGC), United Nations Principles for Responsible Investment (UNPRI) etc.) which it is a signatory or member of, and international principles adopted (International Capital Market Association (ICMA) Green / Sustainable Bond Principles). | Fully Compliant | |
| 54 | It makes concrete efforts to be included in Borsa Istanbul Sustainability Index and international sustainability indices (Dow Jones Sustainability Index, FTSE4Good, MSCI ESG Indices, etc.). | Fully Compliant | |
| D. | CORPORATE GOVERNANCE PRINCIPLES | | |
| 55 | It makes maximum effort to comply with all Corporate Governance principles as well as the mandatory Corporate Governance principles within the scope of the Capital Markets Board Corporate Governance Communiqué numbered II-17.1. | Fully Compliant | |
| 56 | It takes into account the sustainability issue, the environmental impacts of its activities and the principles in this regard while determining its corporate management strategy. | Fully Compliant | |
| 57 | As stated in the Corporate Governance Principles, it takes the necessary measures to comply with the principles regarding the stakeholders and to strengthen the communication with the stakeholders. It applies to the opinions of stakeholders in determining the measures and strategies in the field of sustainability. | Fully Compliant | |
| 58 | It works on raising awareness on the issue of sustainability and its importance through social responsibility projects, awareness activities and trainings. | Fully Compliant | |
| 59 | It strives to become a member of international standards and initiatives on sustainability and to contribute to studies. | Fully Compliant | |
| 60 | Explains policies and programs for the fight against bribery and corruption and the principle of tax integrity. | Partially Compliant | There is an Anti-Bribery and Anti-Corruption Policy. However, no separate policy is published regarding the principle of honesty in terms of tax. Although there is no written policy, Sabancı Holding considers it a social duty to fulfill the tax duty completely and timely according to the principle of honesty. |