the coverage of UN Global Compact COP Ad-
vanced level criteria.
The Company has accurately referenced the
reported indicators of its Social Performance
in the GRI Content Index and reported each
in accordance with the relevant Technical
Indicator Protocol. Also the Report has met
the appropriate requirements of the GRI Fi-
nal Mining and Metals Sector Supplement.
The Report indicates clearly the Company’s
performance against its social impacts as
well as the used approaches to manage
them systematically within the appropriate
boundary of the Report as stated in page
(7). The information and the qualitative
statements reported in the section of So-
cial Footprint and its measurement method
are supported adequately by internal doc-
umentation and are available to any Stake-
holders group if asked.
Additionally, we consider that the medium
and long-term Social Performance targets
add value to the Report since include the
Human Rights and Corruption aspects re-
lated to Company’s significant Suppliers and
Contractors for the first time.
According to our work (checking the cor-
porate mechanisms i.e., gathering, analysis,
consolidation and quality control of in-
formation) we found that the data that has
been calculated and the related measure-
ment techniques, in sections of Health &
Safety, Employment and Equal Opportu-
nities, are adequately described and we did
not face any difficulty to identify the orig-
inal source of this information. The infor-
mation is supported by SAP (business soft-
ware system), Human Resources records,
and monthly spreadsheet reporting for
SAP entities.
During the interviews with the members of
CSR teams, responsible for the verification
of the provided data sources and calcula-
tion methods, we notice that each Sub-
sidiary collects and reports Social Per-
formance data using specific worksheets
provided by the Corporate Centre. Check-
ing, on a sample basis at the Subsidiary lev-
el, this process, in some cases such as em-
ployee categories and social expenditures,
the data did not correspond exactly with the
information maintained within corporate
database. These inconsistencies were sub-
sequently corrected by the reporting team
in Corporate Centre.
In relation with Health & Safety informa-
tion, we found that the Report covers con-
tractor data in a rate of 80% instead of
100%. This discussed and solved with the
CSR team, while happened due to misun-
derstanding of contractor’s definition work-
ing on
site to whom the subsidiary is liable
for the general safety of the working en-
Finally, we support Company’s initiative to
establish a new Self
Assessment Process, in
areas of Human Rights and Anti
Evaluating this process we found that the
results were identifiable and traceable,
and the responsible personnel were able to
reliably demonstrate the related data ori-
gin and interpretation.
Recommendations for improvement
Based on the findings of this assurance en-
gagement and without to affect our conclu-
sions on the Report, we have made the fol-
lowing recommendations:
Concerning Stakeholder Inclusiveness, more
effort should be made to the groups of Sup-
pliers and Corporate customers. More-
over, during the Dialogue Forums, more em-
phasis should be given in the topics of Pro-
tection of Human Rights and Corruption.
Stakeholders input could still be considered
in more depth as part of Company’s Sus-
tainability Strategy, at subsidiaries level.
The Company should examine the level of
interest in its Sustainability Report of var-
ious Stakeholder groups in the countries
where operates. We believe that, future Re-
ports will benefit from more detailed dis-
closure of inclusiveness and responsiveness
with the Company's Stakeholder groups in
its abroad operations.
The Company’s subsidiaries are involved in
the communities they operate. In our opin-
ion, they could participate more actively in
programs or work projects that provide vol-
unteer time. This would allow the Compa-
ny, communicating these impacts directly,
to improve, in terms of quality, its overall
Social Performance.
The Company should consider tying to re-
muneration its major Social Performance
targets such as Health & Safety.
The Company should consider revising its
Professional Code of Conduct. Future re-
ports would benefit from further disclosure
of specific efforts being taken to ensure ef-
fective dissemination and understanding of
the Code of Conduct.
In order to further strengthen Social Per-
formance, it is suggested the semi
review for some major KPI’s to increase the
reliability of the relevant information and
to give more emphasis on CSR management
within the Company’s subsidiaries.
Future Reports should describe in more de-
tails how sustainability topics relate to sup-
chain topics. We believe that the Com-
pany, with the appropriate promotion of its
“Suppliers Code of Conduct”, would have
the opportunity to communicate its strate-
gic objectives more effectively to its sig-
nificant suppliers and work with them to
identify mutual opportunities to improve en-
vironmental and social sustainability per-
formance across the supply chain and report
performance against those objectives.
The Company should provide further train-
ing to its employees, at subsidiaries level,
responsible for CSR data gathering and also
should initiate an adaptation of its systems
to be able to collect data in accordance
with new requirements of the GRI G4.
Statement of Independence
MEDA states its independence and impar-
tiality with regards to this assurance en-
gagement. In 2013, MEDA did not work with
MYTILINEOS Holdings or any of its sub-
sidiaries and stakeholders on any engagements
which could compromise the independence or
impartiality of our findings or recommenda-
tions. MEDA confirms that is not aware of any
other engagement or issue that could impair
our objectivity in relation to this assurance en-
gagement. Moreover, MEDA was not in-
volved in the preparation of any text or data
provided in the Report, with the exception of
this Assurance Statement.
Athina Galanis
Managing Director
MEDA Communication S.A.
Agiou Isidorou Str. 1
Athens Greece
Tel. 2103610309
10th of JULY 2014, Athens, Greece
1...,55,56,57,58,59,60,61,62,63,64 66,67,68
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