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Materiality
                                      Assessment    Appendix 1:    Appendix 2:   Appendix 3:
            Climate  Green   Inclusive   and Stakeholder   GRI Content   Assurance   Glossary of
            Action  Innovation  Progress  Engagement  Index  Statement  Terms













                                                     TAX MANAGEMENT
              Apical's ABC policy refers to all types of
                                                     GRI 207-1, 207-2
              corrupt practices and key areas of risk that
              are likely to arise, including but not limited   Apical seeks to comply with the tax systems in
              to:                                    countries we operate in. We exercise reasonable steps
                                                     in determining and following the interpreted intent
           •  Active bribery                         of the respective tax legislatures. Our tax strategy is
                                                     comprehensive and aims to ensure we follow relevant
                                                     tax laws.
           •  Passive bribery
                                                     Our Tax Policy outlines our statement, method of
           •  Facilitation or grease payments
                                                     reporting on tax-related matters and tax strategy.
                                                     Apical ensures that all key tax positions, tax compliance
           •  Illicit enrichment
                                                     and tax-planning decisions are taken in compliance
                                                     with our Policy. Any initiatives that impact corporate
           •  Facilitation of tax evasion
                                                     structures and business models must be approved by
                                                     the  Business Group  President  or Managing Director
           •  Conflicts of interest
                                                     on the tax implications before a final decision is made.
                                                     To ensure compliance with tax regulations, we work
           •  Gifts and hospitality
                                                     with external tax consultants on matters of uncertainty
                                                     in relation to taxation.
           •  Political donations
                                                     We are committed to implementing a tax approach
           •  Interactions with public and government officials   that is linked to the business imperatives and
            and lobbying                             sustainability commitments of Apical.
           •  Misuse of position
                                                     FEEDBACK CHANNELS FOR STAKEHOLDERS
                                                     GRI 2-25, 2-26
          All employees receive ABC Policy training and are
          encouraged to raise concerns about suspected   Apical understands that the issues most critical
          misconduct  or  malpractice  to  either  the  relevant   to sustainability are determined by the diverse
          department  heads  or  in  accordance  with  our   perspectives of our stakeholders. We value their insights
                                                     and are committed to proactive and constructive
          Whistleblowing Policy.
                                                     engagement. This two-way dialogue involves actively
                                                     seeking feedback and sharing progress updates on our
          In 2023, there are no breaches of the Code of
          Conduct, including corruption, anti-competitive   sustainability programmes, intitiatives and grievances.
                                                     We believe open communication is crucial and we
          behaviour and violations of anti-trust  and monopoly   welcome the input of our key stakeholders as much as
          legislation.  There  are  no  significant  fines  and     we proactively seek to communicate with them.
          non-monetary sanctions for non-compliance with
          laws  and  regulations  in  the  environmental,  social     To  empower stakeholders to  raise  concerns and
          and economic area.                         questions, we provide clear avenues for feedback. Our
                                                     grievance mechanism allows them to communicate
                                                     potential or actual negative impacts associated
                                                     with Apical or our  suppliers’  practices.  Additionally,
                                                     a separate whistleblowing mechanism enables
                                                     stakeholders  to  raise  concerns  or  seek  clarification
                                                     about our business practices or those of our suppliers.

 36  SUSTAINABILITY REPORT 2023                                                APICAL GROUP  37
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