Agility's
Global Reporting Initiative (GRI) Index
2023

Name of organization has reported in accordance with the GRI

Standards for the period [reporting period start and end dates.

Agility has reported in accordance with the GRI Standards for the period 01 January – 31 December, 2023.

GRI 1: Foundation 2021

GRI 1: Foundation 2021.

Titles of the applicable GRI Sector Standards.

Agility is a multi-business operator and investor.

In accordance with the GRI list of sectors and the GRI sector program, Agility’s main sectoral focus is:

• Trading, distribution and logistics.
• Transportation infrastructure.
• Asset management.

• Real Estate Management & Development – Diversified Real Estate Activities.
• Transportation – Airport Services.
• Energy – Oil & Gas Storage & Transportation.
• Financials – Multi-sector holdings.

a. Legal name.

Agility Public Warehousing Company K.S.C.P.

b. Nature of ownership and legal form.

Publicly listed company on the Kuwait stock exchange and the Dubai Financial Market.

c. Location of headquarters.

Kuwait.

d. Countries of operation.

Agility and its controlled businesses operate in more than 65 countries across six continents. We have significant operations in the Middle East and Africa, although the largest numbers of our employees are based in Western Europe, North America, and Australia.

a. List all its entities included in its sustainability reporting.

b. If the organization has audited consolidated financial statements or financial information filed on public record, specify the differences between the list of entities included in its financial reporting and the list included in its sustainability reporting.

In our sustainability reporting, we focus on the companies considered material relative to our identified material sustainability issues, with a heavy emphasis on social and environmental impact.

c. If the organization consists of multiple entities, explain the approach used for consolidating the information, including:

Our sustainability reporting includes consolidated information from the in-scope Agility businesses. Consolidated data and information from those entities are included here.

i. whether the approach involves adjustments to information for minority interests;

Agility does not report on the impact from controlled businesses or business in which a minority interest is held. Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share.

ii. how the approach takes into account mergers, acquisitions, and disposal of entities or parts of entities;

Agility acquired Menzies Aviation in August 2022, and reports in accordance with its ownership.

iii. whether and how the approach differs across the disclosures in this Standard and across material topics.

Where possible, the same reporting standards are applied across the in-scope businesses. All data have been gathered from Agility’s controlled businesses, covering the full year unless otherwise stated, with relevant scope defined in each case. Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share. We currently report scope 1 and 2 carbon emissions for more than 95% of the company based on headcount. We currently report Scope 3 carbon emissions for 86.8% of the company based on headcount.

a-i. The reporting period for its sustainability reporting.

Data in the Agility Sustainability Report FY23 covers the years 2022 – 2023.

a-ii. The frequency of its sustainability reporting.

Agility annually reports sustainability information in a disclosure table and/or a full report.

b-i. The reporting period for its financial reporting.

Agility annually reports its financial performance in accordance with Kuwait Stock Market regulations, typically in late spring of each year.

b-ii. If it does not align with the period for its sustainability reporting, explain the reason for this.

Sustainability information is annually reported, usually within one to two months following the publication of the annual report, due to the time required to collect and verify sustainability data from across the controlled businesses.

c. Report the publication date of the report or reported information;

14 June, 2024.

d. Specify the contact point for questions about the report or reported information.

We welcome your feedback and questions. To contact Agility’s sustainability team, please email us at [email protected].

a. Restatements.

There have been no restatements of information following the publication of Agility’s 2023 Sustainability Report in May 2024.

i. the reasons for the restatements;

See above.

ii. the effect of the restatements.

See above.

a. Describe policy and practice for seeking external assurance, including whether and how the highest governance body and senior executives are involved.

a. Report the sector(s) in which it is active.

Sectors in which Agility is active based on the GRI Sector Program include: Trading, distribution and logistics; Transportation infrastructure; Asset management; Construction; Real estate; Commercial services.

Please refer to GRI Foundation disclosures (Statement of use) for more information about Agility’s material commercial activities and the industries in which those activities are undertaken.

Agility is also a member of FTSE4Good, which relies upon the Industry Classification Benchmark (ICB) system to indicate rated company sectors, sub and micro-sectors. In 2021 (pre-sale of GIL), FTSE4Good indicated Agility engages in the following sub and micro-sectors:

2777 – Transportation Services (Industrial Transportation);

8633 – Real Estate Holding & Development (Real Estate Investment & Services);

8633EBD – Real Estate Investment Trusts involved in construction;

2791 – Business Support Services (Support Services); and

2791CS – Business Support Services: Companies providing Cleaning Services

• Real Estate Management & Development – Diversified Real Estate Activities.
• Transportation – Airport Services.
• Energy – Oil & Gas Storage & Transportation.
• Financials – Multi-sector holdings.

GRI Sector Program – revised list of prioritised sectors

b. Describe its value chain, including:

Due to its diverse commercial and investment portfolio, Agility’s value chain touches many industries and geographies. The value chains include construction, downstream petroleum industry supply chain, aviation support services, life support & food services, commercial real estate management, customs technology and support services, commercial recycling, and investments.

i. the organization’s activities, products, services, and markets served;

Agility is a multi-business operator and long-term investor with a diversified cross-sectoral strategy, targeting high growth and returns through active portfolio management. Agility’s controlled companies provide supply chain services, aviation services and customs digitization, digital logistics, commercial recycling, construction and other services in 65+ countries across six continents.

ii. the organization’s supply chain;

Due to its diverse commercial and investment portfolio, Agility’s supply chain touches many industries and geographies. The supply chain include:

• construction and related materials;
• downstream petroleum industry supply chain services, including transportation, storage and distribution of bulk fuel products;
• aviation support services, including a wide array of airport and passenger support;
• life support & institutional food services, including procurement, distribution, preparation and serving of commercial foods as well as base construction and life-support supply chains that may include engineering, construction, utilities, energy, telecom and other infrastructure supply chains;
• commercial real estate management supply chain;
• customs technology and support services;
• and commercial recycling, including collection, processing and transportation of recycled metals and plastics.

iii. the entities downstream from the organization and their activities.

• Agility Logistics Parks — one of the largest private owners and developers of Grade A warehousing and light industrial parks in the Middle East, Africa and South Asia.
• Tristar — a fully integrated energy logistics business serving the downstream oil and gas industry and international organizations.
• Menzies Aviation — provides ground services such as ramp and baggage handling, de-icing aircraft and passenger services, air cargo services such as cargo handling, special and time-critical cargo, and freighter handling, and fueling services such as inter-plane fueling and fuel storage and hydrant management.
• UPAC — a leading commercial real estate and facilities management company with a specialization in Build Operate Transfer (BOT) initiatives.
• GCC Services — provides remote life support, institutional food services, and construction services.
• Global Clearinghouse Systems & Inspection and Services (GCS & ICS) — provide customs digitization and technology solutions, as well as customs and inspection services.
• Metal Recycling Company — provides metals and plastics recycling services, and other companies.

Agility Sustainability Report FY23, pages 9-10

c. Report other relevant business relationships.

Agility has relevant relationships with its investments partners. Agility holds minority stakes in both listed and non-listed companies, in both established sectors and technological ventures. Its most material investment is in DSV, a global transport and logistics company.

Agility Sustainability Report FY23, pages 9-10

d. Describe significant changes in 2-6-a, 2-6-b, and 2-6-c compared to the previous reporting period.

In 2022, Agility had significant changes from the prior reporting period due to the acquisition of Menzies Aviation. There were no significant changes to Agility’s business model in 2023. In May 2024, Agility listed a new subsidiary, Agility Global PLC, on the Abu Dhabi Securities Exchange. Agility Global, controlled and 51%-owned by Agility, manages our international assets and operations, including Menzies Aviation, Tristar, Agility Logistics Parks (outside of Kuwait), our approximately 9% stake in DSV, and several other controlled businesses.

Agility Sustainability Report FY23, page 7

a. Report the total number of employees, and a breakdown of this total by gender and by region.

Agility’s total 2023, permanent employee headcount for in-scope businesses is 48,823, excluding contract workers.

Agility Sustainability Report FY23, page 6

b-i. permanent employees, and a breakdown by gender and by region;

Reported in our Sustainability Report – see sources and below:

Region                              Employees                Female                 Male

Americas                                   14,488                    4,050                  10,438

Asia Pacific                                5,062                      1,915                    3,147

Europe                                       10,170                    3,560                   6,610

Middle East and Africa           22,951                   3,903                    19,048

Total                                          52,671                    13,428                  39,243

Agility Sustainability Report FY23, page 19

b-ii. temporary employees, and a breakdown by gender and by region

5,183 total contract workers (1,186 female; 3,997 male). 71.0% of contract workers are in the Menzies organization.

b-iii. non-guaranteed hours employees, and a breakdown by gender and by region;

Omitted: information unavailable / incomplete.

b-iv. full-time employees, and a breakdown by gender and by region;

b-v. part-time employees, and a breakdown by gender and by region;

We have 7,681 part-time employees, including 3,298 female (42.9%) and 4,383 male (57.1%).

c. Describe the methodologies and assumptions used to compile the data, including whether the numbers are reported:

i. in head count, full-time equivalent (FTE), or using another methodology;

Numbers reported include FTE and temporary workers in full-time roles.

ii. at the end of the reporting period, as an average across the reporting period, or using another methodology;

Numbers are compiled at the end of the reporting period.

d. Report contextual information necessary to understand the data reported under 2-7-a and 2-7-b.

The majority of workers are full time, permanent employees.

e. Describe significant fluctuations in the number of employees during the reporting period and between reporting periods.

Due to seasonality there are some fluctuations in the total number of employees within the reporting period. Such fluctuations are not significant relative to the full workforce, but they may have an impact on the number of temporary/contract workers at certain times in any given reporting period.

a. Report the total number of workers who are not employees and whose work is controlled by the organization and describe:

5,183 contract workers.

i. the most common types of worker and their contractual relationship with the organization;

71.0% of contract workers are working in airport services.

ii. the type of work they perform.

Most of the work performed by contract workers is related to passenger services.

b. Describe the methodologies and assumptions used to compile the data, including whether the number of workers who are not employees is reported:

The business units provide answers to worker population surveys, including information about numbers of contract workers and gender.

i. in head count, full-time equivalent (FTE), or using another methodology;

Full-time equivalent.

ii. at the end of the reporting period, as an average across the reporting period, or using another methodology.

Numbers are compiled at the end of the reporting period.

c. Describe significant fluctuations in the number of workers who are not employees during the reporting period and between reporting periods.

Due to seasonality there are some fluctuations in the total number of employees within the reporting period. Such fluctuations are not significant relative to the full workforce, but they may have an impact on the number of temporary/contract workers at certain times in any given reporting period.

a. Describe its governance structure, including committees of the highest governance body.

Agility’s governance structure consists of the Board of Directors and five committees that support the Board in performing its duties.

The Board of Directors consists of seven members with a majority of non-executive members and independent members.

The Board of Directors has formed committees in accordance with the rules and regulations of the Corporate Governance policy set by the Capital Markets Authority.  The Board Committees are:

• Audit Committee
• Risk Management Committee
• Nominations and Remuneration Committee
• Sustainability Committee
• Investment Committee

Governance website: Corporate Governance | Agility

b. List the committees of the highest governance body that are responsible for decision making on and overseeing the management of the organization’s impacts on the economy, environment, and people.

Part of the Board‘s responsibilities is to establish Board committees in order to enable it to perform its duties effectively and in line with the company’s needs and working conditions. The Board of Directors has formed committees in accordance with the rules and regulations of the Corporate Governance policy set by the Capital Markets Authority. The Board Committees are:

● Audit Committee

● Risk Management Committee

● Nominations and Remuneration Committee

● Sustainability Committee

● Investment Committee

c. Describe the composition of the highest governance body and its committees by:

i. executive and non-executive members;

The Board of Directors consists of seven members, including two Agility executive, and five non-executive and independent members.

ii. independence;

The Board of Directors consists of seven members with a majority of non-executive members and independent members.

iii. tenure of members on the governance body;

The board members are elected by the shareholders during the General Assembly meeting. Each board member serves a three year term.

iv. number of other significant positions and commitments held by each member, and the nature of the commitments;

Omission: Information unavailable

Governance website: Corporate Governance | Agility

v. gender;

The board chair is female; all other board members are male.

vi. under-represented social groups;

The board chair is female.

vii. competencies relevant to the impacts of the organization;

Agility has a balanced Board structure with diverse backgrounds, expertise and qualified skills to positively impact the Company’s performance and enhance its financial position and market share taking into account the nature and size of its business structure.

viii. stakeholder representation.

Shareholding organizations are represented on the board, including a representative from Kuwait’s Public Institution for Social Security, the investment arm of the Kuwait governments social security fund.

a. Describe the nomination and selection processes for the highest governance body and its committees.

After the Board is elected, the Board members meet to appoint the Chair and Vice-Chair, and also to elect members to the various Board committees.

b. Describe the criteria used for nominating and selecting highest governance body members, including whether and how the following are taken into consideration:

i. views of stakeholders (including shareholders);

All shareholders have the right to attend the General Assembly Meeting, where shareholder input is received. Shareholders are given the opportunity to raise their concerns during the Meeting; and shareholders also have the right to vote as per the number of shares they own for all the items on the agenda, including Board membership elections. A decision is only passed if it gets a majority of votes. As noted above, Board members are elected following shareholder votes at the General Assembly Meeting.

ii. diversity;

Agility assesses board diversity primarily on the basis of gender.

iii. independence;

As per the latest regulatory requirements, at least 20% of the Board must be independent. Independent Board members are elected as “independent” during the general assembly meeting and sign an undertaking to comply with the requirements of the independency during their term. For Agility, during 2022 elections the shareholders elected two out of the seven Board members as independent, in compliance with the latest regulation that was effective in 2022.

iv. competencies relevant to the impacts of the organization.

The responsibilities of the Board Nomination and Remuneration Committee include determining the required and appropriate skills for the Board of Directors and reviewing those requirements on an annual basis.

Agility has a balanced Board structure with diverse backgrounds, expertise and qualified skills to positively impact the Company’s performance and enhance its financial position and market share taking into account the nature and size of its business structure.

The Board of Directors works continuously to assert and encourage corporate value creation in the short, medium, and long term through developing processes and procedures to achieve company’s strategic objectives and improve levels of employees’ performance, and stimulating them to work continually to contribute to Company’s performance.

a. Report whether the chair of the highest governance body is also a senior executive in the organization.

Henadi Al-Saleh, Chairperson, is also an executive officer of the organization.

b. If the chair is also a senior executive, explain their function within the organization’s management, the reasons for this arrangement, and how conflicts of interest are prevented and mitigated.

Henadi Al-Saleh is the Chairperson of Agility’s Board of Directors.

Al-Saleh oversees the company’s corporate governance program while safeguarding the interests of investors and stakeholders. She also leads the company’s technology ventures team, which partners with start-ups and entrepreneurs that are reshaping the supply chain.

Agility has a publicly available Code of Ethics and Conduct, which addresses conflict of interest. All Board members and employees are required to strictly follow the Code and its conflict of interest requirements.

A copy of the publicly available Agility Code of Conduct may be found here.

a. Describe the role of the highest governance body and of senior executives in developing, approving, and updating the organization’s purpose, value or mission statements, strategies, policies, and goals related to sustainable development.

The roles and responsibilities of the Board of Directors include:

• Approving the company’s strategies, goals, plans and policies, including those related to sustainability.
• Ensuring company’s compliance with policies and procedures that are in line with internal applicable rules and regulations.
• Establishing effective communication channels that allow the company’s shareholders to view the various aspects of the company’s activities and any material developments on a continuous and periodic basis.
• Establishing a corporate governance framework and monitoring its effectiveness.
• Establishing committees (including the Sustainability Committee) that follow a charter specifying the term, structure and responsibilities of each and how the Board of Directors monitors and evaluates its performance.
• Ensuring the effectiveness and adequacy of internal control systems and that the company has appropriate control systems to measure and manage risks periodically.

The roles and responsibilities of the board Sustainability Committee include:

• Review Agility’s significant strategies, performance, activities and policies regarding sustainability and provide recommendations to the Board.
• Monitor the Company’s relationships with external stakeholders regarding significant ethics & compliance, health & safety, labor practices, environmental performance, community engagement, and charitable activities matters.
• Advise the Board and the management on strategies that affect and enhance the Company’s role and reputation among its stakeholders.

The roles and responsibilities of the Executive Management include executing company’s strategic plans (including for sustainability), as well as ensuring adequacy and efficiency of the strategic frameworks established by the Board of Directors.

b.  Describe the role of the highest governance body in overseeing the organization’s due diligence and other processes to identify and manage the organization’s impacts on the economy, environment, and people, including:

The Board Audit and Sustainability Committees are charged with overseeing the organization’s due diligence and other processes to identify and manage the organization’s impacts on the economy, environment, and people.

i. whether and how the highest governance body engages with stakeholders to support these processes;

The roles and responsibilities of the Board Sustainability Committee include:

• Reviewing Agility’s significant strategies, performance, activities and policies regarding sustainability and providing recommendations to the Board.
• Monitoring the Company’s relationships with external stakeholders regarding significant ethics & compliance, health & safety, labor practices, environmental performance, community engagement, and charitable activities matters.
• Advising the Board and the management on strategies that affect and enhance the Company’s role and reputation among its stakeholders.

The Board Sustainability Committee meets regularly with the Company’s Sustainability Program executive leadership wherein stakeholder input received by the Sustainability team is provided to the Committee members. The Board members are also present at the General Assembly Meeting where shareholder feedback is solicited and received.

ii. how the highest governance body considers the outcomes of these processes.

The Board approves all polices and procedures that are part of the corporate governance framework the company follows. The Board, through the Audit Committee, is responsible to evaluate the effectiveness of the internal policies and systems. To do this, the Audit Committee uses internal and external audit resources to assess process outcomes and provide recommendations to the Board based on outcome assessments.

c. Describe the role of the highest governance body in reviewing the effectiveness of the organization’s processes as described in 2-12-b, and report the frequency of this review.

The Board Audit Committee completes an annual internal control review which is carried by a third party. This internal control review is executed to ensure the effectiveness of internal processes. Additionally, every three years the Board completes a quality assurance review (QAR) for the internal audit department to ensure the department’s audit program is meeting Board requirements.

In addition to the regular internal audit reviews and assessments, the company also appoints an independent party to complete an annual internal control review (ICR). This internal control review is executed to ensure the effectiveness of internal processes. Additionally, every three years the company completes a quality assurance review (QAR) for the internal audit department to ensure the department’s audit program is meeting Board requirements.

Additionally, the Board Sustainability Committee meets at least once annually (and usually twice) to assess progress. During these meetings, the sustainability team presents quantitative and qualitative performance information to the Committee in order for the Committee to review the effectiveness of the organization’s sustainability related processes described in 2-12-b. Where necessary, the Committee is provided with performance and strategy information in the periods between meetings.

a. Describe how the highest governance body delegates responsibility for managing the organization’s impacts on the economy, environment, and people, including:

The board Sustainability Committee, as well as the Management Board of the company, delegates authority related to sustainability topics. In Agility, the Chief Marketing Officer’s organization (including VP Sustainability) is responsible for executing the sustainability strategy in the company.

i. whether it has appointed any senior executives with responsibility for the management of impacts;

Sustainability is one of the portfolios led by the company’s Group Chief Marketing Officer, and is spearheaded day-to-day by the Vice President of Sustainability. By design, much of the operational execution of the sustainability strategy falls to the business, but is governed by the Corporate Sustainability Team. The CMO reports directly to Agility’s Chief Executive, and the CMO and VP Sustainability report to the Sustainability Committee of the Board of Directors on at least an annual basis, but typically this meeting occurs twice annually.

ii.  whether it has delegated responsibility for the management of impacts to other employees.

At the board Sustainability Committee and CEO’s direction, in 2021 Agility formed a Sustainability Council composed of representatives from all material and some non-material businesses. The Council is delegated responsibility to implement Agility’s sustainability program on a business unit level basis. The Council started reporting progress on a quarterly basis in 2023.

b.  Describe the process and frequency for senior executives or other employees to report back to the highest governance body on the  management of the organization’s impacts on the economy, environment, and people.

The Sustainability team reports in person to the board Sustainability Committee, which must meet at least once a year (but typically the Committee meets semi-annually). During the reporting session, Committee members are provided with quantitative and qualitative performance information based on Committee reviewed and approved programs and initiatives.

a. Report whether the highest governance body is responsible for reviewing and approving the reported information, including the organization’s material topics, and if so, describe the process for reviewing and approving the information.

The Agility Group CEO is a member of the board Sustainability Committee, and reviews and approves the sustainability report prior to publication.

b. If the highest governance body is not responsible for reviewing and approving the reported information, including the organization’s material topics, explain the reason for this.

Agility’s Board of Directors has not reviewed the 2023 report prior to publication, but has regularly reviewed the ESG progress updates that are summarized in this report.

a. Describe the processes for the highest governance body to ensure that conflicts of interest are prevented and mitigated.

The Conflict of Interest policy is an integral part of the Company’s compliance to the principles of integrity and fairness in dealing with stakeholders and sets out the disclosure mechanisms and procedures for dealing with conflicts of interest.

The policy verifies that all the decisions taken by the Board of Directors are in the best interest of the company and that the Board is appropriately dealing with expected and potential conflict of interest. The policy also articulates the roles of the Board of Directors, Executive Management, the internal audit department, and the company’s general assembly in the case of a conflict of interest.

Additionally, Agility has a publicly available Code of Ethics and Conduct, which addresses conflict of interest. All Board members and employees are required to strictly follow the Code and its conflict of interest requirements.

A copy of the publicly available Agility Code of Conduct may be found here.

b. Report whether conflicts of interest are disclosed to stakeholders, including, at a minimum, conflicts of interest relating to:

Agility adopts a conflict of interest policy that includes and addresses stakeholder disclosure. Also as per the regulatory requirements, board members are also required to disclose to the shareholders during the general assembly meeting any transaction or agreement they have personal interest in.

i. cross-board membership;

Issues related to cross board membership are governed by Kuwait commercial law, with which Agility fully complies.

Additionally, the conflict of interest policy requires disclosure of cross-board membership, and it includes the implementation of appropriate controls to identify and manage cross-board memberships.

ii. cross-shareholding with suppliers and other stakeholders;

The conflict of interest policy is in compliance with governing Kuwait commercial law, with which Agility fully complies. The policy requires disclosure of cross-shareholding with suppliers and other stakeholders, and it includes the implementation of appropriate controls to identify and manage external business interests.

iii. existence of controlling shareholders;

The conflict of interest policy requires disclosure of the existence of controlling shareholders, in compliance with Kuwait commercial law. Additionally, shareholders who own more than 5% of the company’s capital must be publicly disclosed on the Kuwait stock market website.

iv. related parties, their relationships, transactions, and outstanding balances.

The conflict of interest policy requires disclosure of the existence of related parties, their relationships, transactions, and outstanding balances. The related party transactions (RPT) policy defines what is considered a RPT and the approval mechanism. In accordance with the RPT policy, all RPTs should be presented to the risk committee and then to the board for approval. In addition, all RPTs are presented to the shareholders during the General Assembly Meeting and are reflected in the company’s financials.

a. Describe whether and how critical concerns are communicated to the highest governance body.

To communicate critical concerns to the Board, employees can use the anonymous reporting phone or email capability, which would route the Board-level concerns to the Board via the company’s Compliance and Investor Relations departments.

Shareholders can raise concerns during the General Assembly Meetings, or they may contact the Investor Relations team. Board level concerns would be communicated to the Board via the Investor Relations department. Other stakeholders can contact Agility via the company’s “contact us” website feature. Such board-level concerns would then be routed to the Board via the Investor Relations department. The Sustainability team communicates with the Board of Directors twice a year as part of the sustainability committee, including sharing any critical concerns that may require the Board’s attention.

Concerns notifications via the Agility Ethics public web page:  Ethics & Compliance | Agility Sustainability; Contact Us at the Agility public website:  https://www.agility.com/en/contact-us/

b. Report the total number and the nature of critical concerns that were communicated to the highest governance body during the reporting period.

No critical concerns were communicated to the highest governance body during the reporting period.

a. Report measures taken to advance the collective knowledge, skills, and experience of the highest governance body on sustainable development.

Agility has a balanced board structure with diverse backgrounds, expertise and qualified skills to positively impact the company’s performance and enhance its financial position and market share, taking into account the nature and size of the business.

a. Describe the processes for evaluating the performance of the highest governance body in overseeing the management of the organization’s impacts on the economy, environment, and people.

As per the Board of Directors’ charter, an annual self-assessment exercise has to be done by Board and committee members to evaluate the performance of the Board and the committees during the year. The evaluation is based on certain financial and non-financial set of performance measurement indicators tied to the achievement of strategic goals of the company.

b. Report whether the evaluations are independent or not, and the frequency of the evaluations.

The evaluations are completed annually. The evaluations are not independent.

c. Describe actions taken in response to the evaluations, including changes to the composition of the highest governance body and organizational practices.

The purpose of the evaluations is to identify gaps to address any performance issues. No significant issues were identified during the reporting period.

a. Describe the remuneration policies for members of the highest governance body and senior executives, including:

Agility has a Nomination and Remuneration Committee which sets a clear remuneration policy for Board members and Executive Management, alongside determining the required and appropriate skills for the Board of Directors and reviewing those requirements on an annual basis.

Board remuneration is recommended by the Board Nomination and Remuneration Committee and approved by the shareholders during the general assembly meeting, and as stipulated by the Articles of Associations of the company, Board remuneration should not exceed 10% of the company’s net profits after deducting depreciation and reserves.

i. fixed pay and variable pay;

The remuneration policy addresses fixed pay and variable pay.

ii. sign-on bonuses or recruitment incentive payments;

The basis for any Board or Executive member bonus or incentive is the compensation policy approved by the Board. The HR department is the owner of this policy and any change or update to this policy is presented to the board for approval.

iii. termination payments;

The basis for any Board or Executive member bonus or incentive is the compensation policy approved by the Board. The HR department is the owner of this policy and any change or update to this policy is presented to the board for approval.

The board remuneration payments is governed by the shareholders’ approval. The remuneration committee proposes the amounts to be paid to the board members and its nature based on the approved compensation policy, this recommendation is presented to the board and then to the shareholders during the Annual General Assembly Meeting for approval. The total board remunerations should be compliant with the Kuwait commercial law and not exceed 10% of the company’s net profits after deducting depreciation and reserves. Any deviation from the approved policy should be reported in the corporate governance report presented to the shareholders.

iv. clawbacks;

The remuneration policy does not address clawbacks.

v. retirement benefits.

Board benefits are governed by shareholder approval and the requirement to ensure Board remuneration is not more than 10% of the company’s net profits after deducting depreciation and reserves.

Board members are not provided retirement benefits.

Executive retirement benefits are governed by HR policy.

b. Describe how the remuneration policies for members of the highest governance body and senior executives relate to their objectives and performance in relation to the management of the organization’s impacts on the economy,  environment, and people.

The Board of Directors and Senior Executives are remunerated based on their objectives and performance related to all aspects of business performance and company goals.

a. Describe the process for designing its remuneration policies and for determining remuneration, including:

Agility has a Nomination and Remuneration Committee which sets a clear remuneration policy for Board members and Executive Management, alongside determining the required and appropriate skills for the Board of Directors and reviewing those requirements on an annual basis.

i. whether independent highest governance body members or an independent remuneration committee oversees the process for determining remuneration; policies and proposals, if applicable;

Nomination and Remuneration Committee includes one executive, one non-executive and one independent board member. The Committee is responsible for setting a clear remuneration policy for Board members and Executive Management.

ii. how the views of stakeholders (including shareholders) regarding remuneration are sought and taken into consideration;

The views of stakeholders (including shareholders) regarding remuneration are welcomed by the Nomination and Remuneration Committee. Agility maintains communications channels for stakeholder (including shareholder) input, and relevant reported concerns are directed to the board and its committees via the Investor Relations team. Additionally, the board meets publicly with shareholders annually. During these meetings shareholders may voice concerns including issues related to remuneration. Concerns are recorded and considered by the board and its committees during and after the public meeting.

iii. whether remuneration consultants are involved in determining remuneration and, if so, whether they are independent of the organization, its highest governance body and senior executives.

Board member and Executive compensation is not determined by or with consultant input.

b. Report the results of votes of stakeholders (including shareholders) on remuneration.

Board remuneration and compensation report is a standard item on the General Assembly Meeting agenda. The compensation report which is part of the corporate governance report is presented to the shareholders during the meeting. The shareholders vote on the compensation report and the board remuneration and the votes are recorded. The results of the full General Assembly Meeting votes and related information are publicly shared on the stock exchanges the company is listed on.

Agility profile on Dubai Stock Exchange website

Agility profile on Kuwait Stock Exchange website

a. Report the ratio of the annual total compensation for the organization’s highest-paid individual to the median annual total compensation for all employees (excluding the highest-paid individual).

Omitted: confidentiality constraints.

b. Report the ratio of the percentage increase in annual total compensation for the organization’s highest-paid individual to the median percentage increase in annual total compensation for all employees (excluding the highest-paid individual).

Omitted: confidentiality constraints.

c. Report contextual information necessary to understand the data and how the data has been compiled.

Omitted: confidentiality constraints.

a. Report a statement from the highest governance body or most senior executive of the organization about the relevance of sustainable development to the organization and its strategy for contributing to sustainable development.

Agility’s Board Vice Chair, Sustainability Committee member and Company CEO regularly publishes a statement regarding sustainability and sustainable development, and how these topics are integrated into the company’s strategy. These statements are published at least annually as part of Agility’s sustainability report. In some cases the CEO also publishes similar public statements.

Agility Sustainability Report FY23, page 3

a. Describe its policy commitments for responsible business conduct, including:

Agility maintains a portfolio of responsible business policies, including those addressing issues related to fair labor; business ethics; environment, health & safety; and supplier conduct.

Code of Business Ethics & Conduct

Global Human Rights Policy and Modern Slavery Statement

Supplier Fair Labor Code

Supplier Code of Conduct

i. the authoritative intergovernmental instruments that the commitments reference;

In our Code of Business Ethics & Conduct and our environmental policies we refer to all applicable laws and regulations. Where ethics are concerned, we specifically state that “Agility is genuinely committed to complying with all applicable laws and regulations…” Our fair labor policies are based on common anti-modern slavery regulations (including those in the UK, EU, Australia and US), ILO, Global Compact and similar international frameworks.

ii. whether the commitments stipulate conducting due diligence;

We are working on integrating due diligence into our policy commitments.

iii. whether the commitments stipulate applying the precautionary principle;

Global Human Rights Policy and Modern Slavery Statement

Supplier Fair Labor Code

Supplier Code of Conduct

iv. whether the commitments stipulate respecting human rights;

Our responsible business policies place human rights at the forefront of managed issues, and they require commitments to respect human rights of employees, contracted workers and other stakeholders.

Global Human Rights Policy and Modern Slavery Statement

Supplier Fair Labor Code

Supplier Code of Conduct

b. Describe its specific policy commitment to respect human rights, including:

Our policy commitments are that we will annually assess at emerging market operations for human rights policy compliance, train all employees on our human rights polices, and that all in-scope, large sites with >50 workers in emerging markets must undergo an audit every three years — by 2025.

i. the internationally recognized human rights that the commitment covers;

Our human rights policies address health and safety, child labor, forced labor, recruiting fees, identification documentation management, hours and wages, harassment and discrimination, freedom of association, and stakeholder engagement.

Global Human Rights Policy and Modern Slavery Statement

ii. the categories of stakeholders, including at-risk or vulnerable groups, that the organization gives particular attention to in the commitment;

Our responsible business policies focus on migrant workers, minorities, gender, children, and disenfranchised communities in which we may operate.

c. provide links to the policy commitments if publicly available, or, if the policy commitments are not publicly available, explain the reason for this;

See sources.

Code of Business Ethics & Conduct

Global Human Rights Policy and Modern Slavery Statement

Supplier Fair Labor Code

Supplier Code of Conduct

d. report the level at which each of the policy commitments was approved within the organization, including whether this is the most senior level;

Each of our responsible business policies are approved at the highest level of the company, by the Vice Chair and CEO.

e. report the extent to which the policy commitments apply to the organization’s activities and to its business relationships;

The responsible business policies are comprehensive in scope and they apply to all Agility entities.

f. describe how the policy commitments are communicated to workers, business partners, and other relevant parties.

Agility communicates its policies and requirements to all employees via email, intranet, website, in-person trainings and meetings and other media as may be required. Policy requirements are provided to suppliers during the qualification process. Responsible business policies are publicly available on Agility’s website.

a. Describe how it embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships, including:

Our policy commitments are embedded and managed via our Sustainability, Ethics, H&S, HR and other similar programs.

i. how it allocates responsibility to implement the commitments across different levels within the organization;

Responsible business policy implementation responsibilities are delegated to functions within each business units, in addition to governance responsibility delegated to the Corporate Sustainability Team.

Agility is in a period of transition. For the years 2022-2024, the Corporate Sustainability team will provide Group-wide responsible business policy governance as well as implementation support. In 2025, each business unit will be managing policies without corporate assistance, and the Corporate Sustainability function will remain focused on policy and program governance.

ii. how it integrates the commitments into organizational strategies, perational policies, and operational procedures;

Agility integrates its responsible business commitments into organizational strategies by defining policy and program requirements to manage identified material issues.

These include the development and maintenance of operational policies such as human rights policies and codes (including supplier codes), environmental, safety and health policies and ethics policies. Each of the responsible business policies are reinforced by process and procedural controls such as annual assessments, progress reporting and policy revisions and updates.

iii. how it implements its commitments with and through its business relationships;

Agility aims to implement its responsible business commitments in its business relationships.

We strengthened our sustainable procurement efforts in 2023, embedding sustainability requirements into supplier contracts managed by the Corporate procurement team. 100% of Menzies Aviation, Tristar and GCC Services suppliers have signed the Fair Labor and Ethics Codes of Conduct or have otherwise agreed to operate within the respective code requirements. Starting in 2024, 100% of new supplier contracts will include our sustainable procurement requirements — this includes all procurements for Agility Corporate, ALP, GCS, MRC, and the Shipa companies. Each of our businesses are working to gain a more transparent picture of their supply chains, alongside working with suppliers to progress environmental and social performance. Human rights remain our priority, and we will work with labor providers to ensure they understand our fair labor and human rights requirements.

Agility Sustainability Report FY23, pages 17 and 55

iv. training that the organization provides on implementing the commitments.

Agility provides online training on ethics and compliance policies, as well as health and safety and human rights policies. Additionally, employees are trained in-person on human rights and safety.

Agility Sustainability Report FY23, pages 18, 54 and 55

a. Describe its commitments to provide for or cooperate in the remediation of negative impacts that the organization identifies it has caused or contributed to.

Omitted: information unavailable / incomplete.

b. Describe its approach to identify and address grievances, including the grievance mechanisms that the organization has established or participates in.

We encourage and expect employees to speak up about ethical concerns, supported by clear no retaliation guidelines and confidential grievance mechanisms.

Agility offers all stakeholders a number of ways in which to raise ethics concerns, including the option to do so anonymously. These include:

• A form via the Agility website, that gets sent directly to our ethics team. All information is treated confidentially.
• Via a third-party vendor’s online tool or phone hotline. Users of the hotline can request an interpreter for more than 200 different languages.

Agility Sustainability Report FY23, page 16

Ethics and compliance web page

c. Describe other processes by which the organization provides for or cooperates in the remediation of negative impacts that it identifies it has caused or contributed to.

Omitted: information unavailable / incomplete.

d.  Describe how the stakeholders who are the intended users of the grievance mechanisms are involved in the design, review, operation, and improvement of these mechanisms.

Omitted: information unavailable / incomplete.

e. Describe how the organization tracks the effectiveness of the grievance mechanisms and other remediation processes, and report examples of their effectiveness, including stakeholder feedback.

Omitted: information unavailable / incomplete.

a. Describe the mechanisms for individuals to:

Agility Sustainability Report FY23, page 16

i. seek advice on implementing the organization’s policies and practices for responsible business conduct;

Agility offers all stakeholders a number of ways in which to raise ethics concerns, including the option to do so anonymously. These include:

• A form via the Agility website, that gets sent directly to our ethics team. All information is treated confidentially.
• Via a third-party vendor’s online tool or phone hotline. Users of the hotline can request an interpreter for more than 200 different languages.

 

Individuals (either external or internal) are also able to contact Agility at via the “contact us” feature on our website.

https://www.agility.com/en/contact-us/

Agility Sustainability Report FY23, page 16

Ethics and compliance web page

ii. raise concerns about the organization’s business conduct.

See above.

Agility Sustainability Report FY23, page 16

a. Report the total number of significant instances of non-compliance with laws and regulations during the reporting period, and a breakdown of this total by:

No significant instances of non-compliance with laws and regulations during the reporting period.

i. instances for which fines were incurred;

No significant instances of non-compliance with laws and regulations during the reporting period.

ii. instances for which non-monetary sanctions were incurred.

No significant instances of non-compliance with laws and regulations during the reporting period.

b. Report the total number and the monetary value of fines for instances of  noncompliance with laws and regulations that were paid during the reporting period, and a breakdown of this total by:

No significant instances of non-compliance with laws and regulations during the reporting period.

i. fines for instances of non-compliance with laws and regulations that occurred in the current reporting period;

No significant instances of non-compliance with laws and regulations during the reporting period.

ii. fines for instances of non-compliance with laws and regulations that occurred in previous reporting periods;

No significant instances of non-compliance with laws and regulations during the reporting period.

c. Describe the significant instances of non-compliance.

No significant instances of non-compliance with laws and regulations during the reporting period.

d. Describe how it has determined significant instances of non-compliance.

No significant instances of non-compliance with laws and regulations during the reporting period.

a. Report industry associations, other membership associations, and national or international advocacy organizations in which it participates in a significant role.

We believe multi-stakeholder engagement is essential to driving a more sustainable future for our business and our industry. In 2023, Agility engaged with a number of industry and global organizations to learn from others, collaborate on complex topics, and ultimately, multiply our contributions.

Agility is a strategic partner of the World Economic Forum (WEF) and a participant in several working groups dedicated to trade, sustainable logistics, zero emissions technology adoption in hard-to-abate sectors, humanitarian assistance and other topics, including the First Movers Coalition, the Good Work Alliance, the Logistics Emergency Team, the Refugee Employment Alliance, the International Business Council, and Leaders for a Sustainable MENA. In 2023, via the Menzies Aviation, Agility continued participating in the UN Sustainable Development Goal (SDG) Ambition Accelerator. Agility is also a signatory of the UN Global Compact, as are Tristar, GCC and UPAC.

Agility Sustainability Report FY23, pages 11-12, 19, 23, 30-31

a. Describe its approach to engaging with stakeholders, including:

1. Good faith, transparency and continued dialogue;
2. Pragmatic and effective integration of responsible priorities and stakeholder interests into the day-to-day business.
3. Taking leads and queues from vulnerable stakeholder groups and their advocates, including civil society, charities & NGOs, and other stakeholder groups.
    

Agility Sustainability Report FY23, page 15

i. the categories of stakeholders it engages with, and how they are identified;

Stakeholder categories include shareholders, customers, employees, community members, responsible business partnership members and communities, senior executives and the Board of Directors.

Agility materiality and stakeholder engagement web page

ii. the purpose of the stakeholder engagement;

Environmental, economic and humanitarian partnerships and multi-stakeholder engagement remain central to our sustainability strategy. Working with others enables us to learn and share our own experience, amplify our impact, and collaborate on solutions to complex global challenges.

iii. how the organization seeks to ensure meaningful engagement with stakeholders.

Agility seeks to ensure meaningful engagement with stakeholders by maintaining full transparency in stakeholder engagement, including issues identification, prioritization and performance measurement and reporting. Transparency is an important cornerstone of meaningful stakeholder engagement.

a. Report the percentage of total employees covered by collective bargaining agreements.

Omitted: information unavailable / incomplete. Agility notes that in most locations trade unions are not obliged to disclose their membership. In some Middle Eastern locations trade union activity is prohibited under local laws.

b. For employees not covered by collective bargaining agreements, report whether the organization determines their working conditions and terms of employment based oncollective bargaining agreements that cover its other employees or based on collective bargaining agreements from other organizations.

Agility determines working conditions and terms of employment based on local regulation, our responsible business policies, and market conditions.

a. Direct economic value generated and distributed (EVG&D) on an accruals basis.

All figures are in thousands of KWD.

i. Direct economic value generated, including:

1,368,955

revenues;

1,353,023

cash received as interest on financial loans;

2,536

dividends received from shareholdings;

10,976

cash received from sale of assets.

2,420

ii. Economic value distributed, including:

1,299,568

cash operating costs;

676,494

salaries & employee benefits;

454,749

payments to providers of capital;

150,287

payments to Government;

13,738

community investments;

4,300

KFAS;

913

NLST;

2,197

Zakat;

1,018

Agility donations.

172

iii. Economic value retained.

69,387

a. Risks and opportunities posed by climate change that have the potential to generate substantive changes in operations, revenue, or expenditure, including:

Agility identified the risks and opportunities for our business and our stakeholders associated with each of our material topics through our TCFD analysis in 2022. As the TCFD is now integrated into the International Sustainability Standards Board (ISSB) reporting framework, we no longer report against this framework at the group level. Our most emissions-material businesses lead their own climate reporting, including Menzies, Tristar, and GCC Services. Menzies published its second TCFD report in 2023, as part of its 2022 annual report.

Agility Sustainability Report FY23, pages 20, 28

i. a description of the risk or opportunity and its classification as either physical, regulatory, or other;

See above.

ii. a description of the impact associated with the risk or opportunity;

See above.

iii. the financial implications of the risk or opportunity before action is taken;

Omitted: information unavailable / incomplete.

iv. the methods used to manage the risk or opportunity;

v. the costs of actions taken to manage the risk or opportunity.

Omitted: information unavailable / incomplete.

a. If the plan’s liabilities are met by the organization’s general resources, the estimated value of those liabilities.

Omitted: not material.

b. If a separate fund exists to pay the plan’s pension liabilities:

Omitted: not material.

i. the extent to which the scheme’s liabilities are estimated to be covered by the assets that have been set aside to meet them;

Omitted: not material.

ii. the basis on which that estimate has been arrived at;

Omitted: not material.

iii. when that estimate was made.

Omitted: not material.

c. If a fund set up to pay the plan’s pension liabilities is not fully covered, explain the strategy, if any, adopted by the employer to work towards full coverage, and the timescale, if any, by which the employer hopes to achieve full coverage.

Omitted: not material.

d. Percentage of salary contributed by employee or employer.

Omitted: not material.

e. Level of participation in retirement plans, such as participation in mandatory or voluntary schemes, regional, or country-based schemes, or those with financial impact.

Omitted: not material.

a. Total monetary value of financial assistance received by the organization from any government during the reporting period, including:

Omitted: not material.

i. tax relief and tax credits;

Omitted: not material.

ii. subsidies;

Omitted: not material.

iii. investment grants, research and development grants, and other relevant types of grant;

Omitted: not material.

iv. awards;

Omitted: not material.

v. royalty holidays;

Omitted: not material.

vi. financial assistance from Export Credit Agencies (ECAs);

Omitted: not material.

vii. financial incentives;

Omitted: not material.

viii. other financial benefits received or receivable from any government for any operation.

Omitted: not material.

b. The information in 201-4-a by country.

Omitted: not material.

c. Whether, and the extent to which, any government is present in the shareholding structure.

Omitted: not material.

a. When a significant proportion of employees are compensated based on wages subject to minimum wage rules, report the relevant ratio of the entry level wage by gender at significant locations of operation to the minimum wage.

Omitted: information unavailable / incomplete. Agility complies fully with local labor laws regarding minimum wages.

b. When a significant proportion of other workers (excluding employees) performing the organization’s activities are compensated based on wages subject to minimum wage rules, describe the actions taken to determine whether these workers are paid above the minimum wage.

Omitted: information unavailable / incomplete. See above.

c. Whether a local minimum wage is absent or variable at significant locations of operation, by gender. In circumstances in which different minimums can be used as a reference, report which minimum wage is being used.

Omitted: information unavailable / incomplete. See above.

d. The definition used for ‘significant locations of operation’.

Omitted: information unavailable / incomplete. See above.

a. Percentage of senior management at significant locations of operation that are hired from the local community.

In 2023, Agility employees hailed from 120+ countries. The company takes pride in looking and feeling local in the countries in which it operates. Currently the Agility workforce reflects its global presence, with about 43.6% of employees working in the Middle East and Africa; 27.5% in the Americas, 19.3% in Europe, and 9.6% in Asia-Pacific. The majority of company leadership comes from the countries in which they work and manage Agility operations.

For Agility Logistics Parks in Africa and South Asia, >90% of staff are local to the Agility operation (Agility Ghana staff are 100% Ghanaian, Nigeria staff are 100% Nigerian, etc.). Additionally, construction and security contractors are encouraged to recruit workers locally from the villages and towns adjacent to the respective sites, in order to boost local employment and positive community relationships.

b. The definition used for ‘senior management’.

Senior management is defined as leading an entire company or corporate/company function, such as HR, Finance, Sustainability, etc.

c. The organization’s geographical definition of ‘local’.

Local is defined as country of origin or country of operation.

d. The definition used for ‘significant locations of operation’.

Sites with >50 workers, including employees and contract or temporary workers.

a. Extent of development of significant infrastructure investments and services supported.

Agility’s significant infrastructure is mostly attributable to Agility Logistics Parks (ALP), Tristar, and UPAC via the Reem Mall project. In 2023, in partnership with Al Farwaniya Property Developments, UPAC opened the $1.3 billion Reem Mall in Abu Dhabi. Agility Logistics Parks (ALP) is constructing a new logistics city project in Kuwait, which includes more than 1 million m2 of logistics park real estate. The company is also building a 576,760m2 logistics park for storage and distribution near Jeddah, Saudi Arabia, due to open in Q1 2025. ALP bring world-class logistics infrastructure to emerging markets, particularly critical when it comes to the storage of food, medications, technological devices, and other high-value, perishable, or temperature-sensitive items.

b. Current or expected impacts on communities and local economies, including positive and negative impacts where relevant.

Agility Sustainability Report FY23, pages 7, 36-38

c. Whether these investments and services are commercial, in-kind, or pro bono engagements.

Nearly 100% of 2023 infrastructure investments are commercial investments. Relative to the overall infrastructure investment and development program, a small number of investments were made to refurbish or outfit schools in Côte d’Ivoire and India.

Agility Sustainability Report FY23, pages 23, 25, 38

a. Examples of significant identified indirect economic impacts of the organization, including positive and negative impacts.

Our significant indirect impacts include the following:

1. We help to build the ecosystem for SMEs to to access knowledge and world-class supply chain services.
2. We employ people in emerging markets, with >43% of our headcount employees in the Middle East, Africa and Asia.
3. Our investment in high-quality warehousing and light-industrial infrastructure across the Middle East, South Asia and Africa raises the quality standards for the storage of goods and helps meet national competitiveness and development objects.
4. We are increasing our investments in responsible and ESG-focused technologies and companies.

Agility Sustainability Report FY23, pages 9-10, 19

b. Significance of the indirect economic impacts in the context of external benchmarks and stakeholder priorities, such as national and international standards, protocols, and policy agendas.

Distributed and generated economic values from our infrastructure, services and other investments significantly impact and correlate to UN Sustainable Development Goals, particularly: 1 – no poverty; 4 – quality education; 5 – gender equality; 7 – affordable & clean energy; 8 – decent work and economic growth; 9 – industry, innovation and infrastructure; 13 – climate action; and 17 – partnership for the goals.

Agility Sustainability Report FY23, page 14

a. Percentage of the procurement budget used for significant locations of operation that is spent on suppliers local to that operation (such as percentage of products and services purchased locally).

Omitted: information unavailable / incomplete.

b. The organization’s geographical definition of ‘local’.

Not applicable (not reported).

c. The definition used for ‘significant locations of operation’.

Not applicable (not reported).

a. Total number and percentage of operations assessed for risks related to corruption.

In 2019-2020, Agility performed a global risk assessment using an external consultant specializing in these issues. The 2019-2020 assessment covered all material countries of operations. The recommended action items relating to this assessment were implemented by Agility’s Compliance Department in 2020-2021.

b. Significant risks related to corruption identified through the risk assessment.

Based on prior corruption risk assessments, the following risks have been identified as material to Agility. These risks are assumed to still be relevant.

1. Dealing with third parties
2. Dealing with government officials
3. Facilitating payments
4. Gifts and entertainment
5. Cash transactions
6. Obtaining licenses and permits

Agility has an in-house compliance function that provides regular training regarding these and similar topics; and which supervises all compliance-related matters, including reporting and investigations.

a. Total number and percentage of governance body members that the organization’s anti-corruption policies and procedures have been communicated to, broken down by region.

100% of Agility Board of Directors and Corporate Executives annually receive communications and/or training regarding Agility’s anti-corruption policies and procedures. In the material Agility businesses, more than three quarters of all the companies’ executives annually receive communications and/or training on Agility’s and/or other relevant anti-corruption policies and procedures.

b. Total number and percentage of employees that the organization’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region.

Agility has implemented a robust ethics and compliance communications and training program, which includes mandatory, online and in-person courses addressing broad compliance subjects — including general ethics, anti-corruption, confidential information and human rights.

In conjunction with mandatory online training, communications reinforcing key aspects of company policy, risk areas, and practical considerations are provided to all employees and additional manager-focused resources are made available to help drive understanding. 78% of eligible employees completed ethics and anti-corruption training courses over the last three years. This training includes content on whistleblowing and non-retaliation, global anti-corruption, international sanctions, and Code of Conduct and Business Ethics.

Agility Sustainability Report FY23, pages 16, 54

c. Total number and percentage of business partners that the organization’s anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region.

Agility Sustainability Report FY23, pages 17, 55

c. Describe if the organization’s anti-corruption policies and procedures have been communicated to any other persons or organizations.

Agility’s anti-corruption policies and procedures are publicly available online for any other persons or organizations to reference.

Agility ethics and compliance webpage

d. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region.

See 205-2 a, above.

e. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region.

See 205-2 a, above.

a. Total number and nature of confirmed incidents of corruption.

Omitted: confidentiality constraints.

b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.

Omitted: confidentiality constraints.

c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.

Omitted: confidentiality constraints.

d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.

No public legal cases regarding corruption were brought against Agility or its employees during the reporting period.

a. Number of legal actions pending or completed during the reporting period regarding anti-competitive behavior and violations of anti-trust and monopoly legislation in which the organization has been identified as a participant.

No legal actions were pending or completed during the reporting period regarding anti-competitive behavior and violations of anti-trust and monopoly legislation in which Agility has been identified as a participant.

b. Main outcomes of completed legal actions, including any decisions or judgements.

Omitted: not applicable (see above).

i. whether the organization has a tax strategy and, if so, a link to this strategy if publicly available;

Agility’s Tax Principles & Strategy:

Our code of conduct sets out what is expected of everyone at Agility and the approach to tax aligns with those principals. The approach to compliance and tax planning, governance, transparency and risk management are driven by the following principles:

• Compliance and tax planning. Agility supports efforts to increase public trust in tax systems. It is committed to observing all applicable laws, rules, regulations and reporting and disclosure requirements, wherever there is a requirement to do so as a result of our business presence and transactions.
• Governance. Agility adheres to relevant tax laws, and it seeks to minimize the risk of uncertainty or disputes. The company works collaboratively wherever possible with governments and fiscal authorities to resolve disputes and to achieve early agreement and certainty.
• Transparency. Agility seeks to build and sustain relationships with governments and fiscal authorities in the countries where it operates, and the company believes that those relationships should be constructive and based on mutual respect.
• Risk Management. Agility pays the tax that it owes under the existing laws and ensures that the company pays tax only once on its profits.

ii. the governance body or executive-level position within the organization that formally reviews and approves the tax strategy, and the frequency of this review;

The Corporate Tax Department (Agility Tax) is headed by the Group Head of Tax and is supported by the Tax Director. The Group Head of Tax owns and implements the approach to tax which is approved by the Group Treasurer. The Group Head of Tax is also responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently around the world, and that the global tax team has the skills and experience to implement the approach appropriately.

iii. the approach to regulatory  compliance;

Agility’s tax process and approach to regulatory compliance are based on key objectives including efficient tax planning, effective tax risk management, establishing strong tax control environments/tax governance, and proactive resolution of all issues raised by the tax authorities related to Agility Corporate office — as well as assistance to respective business units that may have significant impact on business decisions.

iv. how the approach to tax is linked to the business and sustainable development strategies of the organization.

a. A description of the tax governance and control framework, including:

Agility’s tax governance, control, and risk management:

i. the governance body or executive-level position within the organization accountable for compliance with the tax strategy;

ii. how the approach to tax is embedded within the organization;

Agility Tax follows the company’s risk management system as part of its internal control processes.

iii. the approach to tax risks, including how risks are identified, managed, and monitored;

The team identifies, assesses and manages tax risks and accounts for them appropriately. It implements risk management measures including controls over compliance processes and monitor their effectiveness.

iv. how compliance with the tax governance and control framework is evaluated.

The team reports on a periodic basis to the group financial risk committee on how tax risks are managed, monitored and assured and on improvements that are being made. In this way the group financial risk committee provides governance and oversight of tax risks. Strong technical tax positions are formulated after in-depth research of information available to us through the company’s tax research and compliance vendors, government taxing authority literature, expert tax partner’s guidance and knowledge of the tax professionals.

b. A description of the mechanisms to raise concerns about the organization’s business conduct and the organization’s integrity in relation to tax.

Agility maintains a toll free hotline and email account for any stakeholder to report concerns or grievances, including those related to tax issues.

c. A description of the assurance process for disclosures on tax including, if applicable, a link or reference to the external assurance report(s) or assurance statement(s).

Tax disclosures are included in the annual financial report, which is assured per Kuwait Stock Market compliance regulations.

a. A description of the approach to stakeholder engagement and management of stakeholder concerns related to tax, including:

Agility Tax seek an open dialogue with our shareholders, relevant tax authorities, customers and various Agility business group. Any new changes to be made to the tax strategy and any planning due to changes in the tax laws shall be identified, analyzed, and reviewed by the Corporate Tax Department for the entire Agility Group and in coordination with Legal, Corporate Secretarial Departments and respective country-tax representatives of Agility.

i. the approach to engagement with tax authorities;

Depending on the region, complexity, and materiality of the restructuring required as per the new changes in the tax law, the Group Head of Tax may consider the use of tax consulting firms or in-house team to review and recommend changes to the tax structuring, strategy and plan.

ii. the approach to public policy advocacy on tax;

Agility Tax also actively participates in the Tax Executive Institute, which is the preeminent association of in-house tax professionals to help identify tax law trends in good time and to be able to react to them. Agility Tax supports the principles of greater transparency by ensuring compliance with country-by-country reporting as part of the OECD’s Base Erosion and Profit Shifting project exchange of country-by-country reporting data between taxing authorities, and EU’s Mandatory Disclosure Regime.

iii.  the processes for collecting and considering the views and concerns of stakeholders, including external stakeholders.

Agility receives feedback from shareholders and other stakeholders via its “contact us” feature on the Agility website. Any reported concerns are managed according to a time-bound and performance measured basis. Additionally, shareholders are able to report concerns or information during the annual shareholders meeting. All reports are recorded and distributed to the appropriate authority or department in the company, including the tax department when applicable.

a. All tax jurisdictions where the entities included in the organization’s audited consolidated financial statements, or in the financial information filed on public record, are resident for tax purposes.

Agility reports its tax position as part of its IFRS annual reporting.

b. For each tax jurisdiction reported in Disclosure 207-4-a:

See above.

i. Names of the resident entities;

See above.

ii. Primary activities of the organization;

See above.

iii. Number of employees, and the basis of calculation of this number;

See above.

iv. Revenues from third-party sales;

See above.

v. Revenues from intra-group transactions with other tax jurisdictions;

See above.

vi. Profit/loss before tax;

See above.

vii. Tangible assets other than cash and cash equivalents;

See above.

viii. Corporate income tax paid on a cash basis;

See above.

ix. Corporate income tax accrued on profit/loss;

See above.

x. Reasons for the difference between corporate income tax accrued on profit/loss and the tax due if the statutory tax rate is applied to profit/loss before tax.

See above.

c. The time period covered by the information reported in Disclosure 207-4.

See above.

a. Describe the process it has followed to determine its material topics, including:

Agility Sustainability Report FY23, page 15

i. how it has identified actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights, across its activities and business relationships;

Agility has identified actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights, across its activities and business relationships through its materiality assessments (including stakeholder interviews and questionnaires), engagement in relevant partnerships, and regular engagement of its management teams in functions such as HR, Health & Safety, Environment, Strategy, IT and Sustainability. Agility’s 2022-2023 materiality assessment was informed by interviews with key internal stakeholders and external partners, alongside a survey across our corporate business and controlled businesses.

Agility Sustainability Report FY23, page 15

ii. how it has prioritized the impacts for reporting based on their significance.

Material issues are prioritized based on a matrix with X axis relating to impact on Agility’s business and performance, and Y axis relating to impact of Agility services on people and planet. Identified material issues with the greatest importance and impact are rated as the issues of highest priority.

1. Actively manage.
2. Incorporate into business strategy.
3. Engage with stakeholders and actively monitor.
4. Monitor issues evolution.
    

Agility Sustainability Report FY23, page 15

b. Specify the stakeholders and experts whose views have informed the process of determining its material topics.

In its materiality assessments, Agility relies on stakeholders including members of the board, senior company executives, employees, customers, community and industry partnership stakeholders, and its sustainability program team.

Agility Sustainability Report FY23, page 15

a. List its material topics.

Agility’s material topics are identified in its materiality matrix. See sources.

Agility Sustainability Report FY23, page 15

b. Report changes to the list of material topics compared to the previous reporting period.

The FY23 material issues remained the same as in FY22.

For each material topic reported under Disclosure 3-2, the organization shall:

See our Sustainability Report FY23 for our materiality matrix and more detail on the management approach to our material topics.

Agility Sustainability Report FY23

a. describe the actual and potential, negative and positive impacts on the economy, environment, and people, including impacts on their human rights;

Please see our materiality matrix and Sustainability Report FY23 for more detail, alongside responses to individual GRI indicators below.

Agility Sustainability Report FY23, including materiality matrix on page 15.

b. report whether the organization is involved with the negative impacts through its activities or as a result of its business relationships, and describe the activities or business relationships;

Agility is involved with the negative impacts of a number of material issues through its activities or as a result of its business relationships, including human rights/fair labor, health & safety, road safety, climate change, diversity, energy transition, and material waste.

c. describe its policies or commitments regarding the material topic;

Please see our Sustainability Report FY23 for more information on our policies or commitments regarding each material topic.

Agility Sustainability Report FY23

d. describe actions taken to manage the topic and related impacts, including:

Agility has established goals around most material issues.

Agility Sustainability Report FY23

i. actions to prevent or mitigate potential negative impacts;

Agility addresses negative impacts through policy, program implementation and transparent KPI-based reporting against established goals.

ii. actions to address actual negative impacts, including actions to provide for or cooperate in their remediation;

Generally speaking, Agility follows a plan-do-act-check process to address negative impacts. In planning activities, the company assesses the materiality of issues and potential impacts from the business, followed by establishing goals, KPI’s and reporting criteria.

Once developed, program implementation follows and impact is measured and reported. When reporting or operational goals are not being met, interventions are immediately implemented to improve reporting and goal performance. Similarly, at the end of an annual or other periodic reporting cycle, the company assesses progress against goals, and uses the information to improve performance. This process is most visibly illustrated in our fair labor program. See GRI indicators below and sources for more information on our management of material topics.

iii. actions to manage actual and potential positive impacts;

See above.

e. report the following information about tracking the effectiveness of the actions taken:

See above.

i. processes used to track the effectiveness of the actions;

See above.

ii. goals, targets, and indicators used to evaluate progress;

See above.

iii. the effectiveness of the actions, including progress toward the goals and targets;

See above.

iv. lessons learned and how these have been incorporated into the organization’s operational policies and procedures;

Agility has been developing and structurally managing responsible business policies and programs for more than 17 years. We have learned that stakeholder dialogue, good faith and transparency are critical to program success.

Seeking program performance feedback from constituent stakeholders like employees and charity partners is critical to the establishment of accurate and realistically achievable goals. Strong process controls and performance measurement and reporting are also critical to success. Lastly, we recognize that responsible business is a dynamic journey, and the team must be prepared to adjust materiality, goals, KPIs and program management in order to successfully manage negative impacts.

f. describe how engagement with stakeholders has informed the actions taken (3-3-d) and how it has informed whether the actions have been effective (3-3-e).

See above.

a. Total weight or volume of materials that are used to produce and package the organization’s primary products and services during the reporting period, by:

Omitted: not material – most of our businesses operate in the services sector and do not consume high weights or volumes of materials.

i. non-renewable materials used;

Omitted: not material – most of our businesses operate in the services sector and do not consume high weights or volumes of materials.

ii. renewable materials used.

Omitted: not material – most of our businesses operate in the services sector and do not consume high weights or volumes of materials.

a. Percentage of recycled input materials used to manufacture the organization’s primary products and services.

Omitted: not material – most of our businesses operate in the services sector and do not consume high weights or volumes of materials.

a. Percentage of reclaimed products and their packaging materials for each product category

Omitted: not material – most of our businesses operate in the services sector.

b. How the data for this disclosure have been collected.

Omitted: not material – most of our businesses operate in the services sector.

a. Total fuel consumption within the organization from non-renewable sources, in joules or multiples, and including fuel types used.

Diesel (liters)

55,362,451.13

Diesel (megajoules)

2,119,828,253.92

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gas LPG – Liquefied Petroleum Gas (kWh)

6,382,013.65

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gas LPG (megajoules)

22,975,249.16

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gasoline (liters)

10,617,213.12

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gasoline (megajoules)

355,804,046.09

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gas – Natural gas (CNG/LNG) (kWh)

57,079,100.64

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Gas – Natural gas (CNG/LNG) megajoules

205,484,762.32

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Marine Gas Oil/Low Sulphur Fuel consumption (tons)

86,096.00

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Marine Gas Oil/Low Sulphur Fuel megajoules

3,868,536,931.68

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Kerosene consumption (liters)

None reported

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

Kerosene (megajoules)

None reported

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

b. Total fuel consumption within the organization from renewable sources, in joules or multiples, and including fuel types used.

Omitted: information unavailable / incomplete.

c. In joules, watt-hours or multiples, the total:

i. electricity consumption (kWh);

56,923,269.24

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

i. electricity consumption (megajoules);

204,923,769.25

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

ii. heating consumption;

Omitted: not applicable.

iii. cooling consumption;

Omitted: not applicable.

iv. steam consumption.

Omitted: not applicable.

d. In joules, watt-hours or multiples, the total:

Omitted: not applicable.

i. electricity sold;

Omitted: not applicable.

ii. heating sold;

Omitted: not applicable.

iii. cooling sold;

Omitted: not applicable.

iv. steam sold.

Omitted: not applicable.

e. Total energy consumption within the organization, in megajoules.

6,777,553,012.42

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

f. Standards, methodologies, assumptions, and/or calculation tools used.

To convert liters and kWh consumption to megajoules, Agility uses the US Energy Information Agency online energy conversion calculators.

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

g. Source of the conversion factors used.

To convert liters and kWh consumption to megajoules, Agility uses the US Energy Information Agency online energy conversion calculators.

U.S. Energy Information Administration energy conversion calculator: Energy conversion calculators – U.S. Energy Information Administration (EIA)

a. Energy consumption outside of the organization, in joules or multiples.

Omitted: information unavailable / incomplete. We currently report Scope 3 carbon emissions for 86.8% of the company based on headcount. All reported Scope 3 emissions are from upstream emissions related to electricity and fuel consumption. Reporting entities include ALP, GCC, Menzies, Shipa companies, Tristar, and UPAC.

b. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: not applicable.

c. Source of the conversion factors used.

Omitted: not applicable.

a. Energy intensity ratio for the organization (megajoules/economic value generated)

4.8 MJ/KWD direct economic value generated.

This figure includes only scopes 1 & 2 energy consumption. Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share.

Business unit reporting, please see disclosure 201-1 and 302-1 for details.

b. Organization-specific metric (the denominator) chosen to calculate the ratio.

Energy intensity ratio = megajoules/direct economic value generated in KWD (or 6,572,629,243 MJ/1,368,955,000 KWD total economic value generated.)

Business unit reporting, please see disclosure 201-1 and 302-1 for details.

c. Types of energy included in the intensity ratio; whether fuel, electricity, heating, cooling, steam, or all.

Electricity and fuel including diesel, MGO, gasoline, CNG/LNG, kerosene and LPG.

Business unit reporting, please see disclosure 302-1 for details.

d. Whether the ratio uses energy consumption within the organization, outside of it, or both.

Within the organization only.

Business unit reporting, please see disclosure 302-1 for details.

a. Amount of reductions in energy consumption achieved as a direct result of conservation and efficiency initiatives, in joules or multiples.

Omitted: information unavailable / incomplete. Agility’s energy consumption baseline changed significantly following the sale of GIL and the acquisition of Menzies. We will complete a full emissions baseline in 2025 once the full integration of Menzies is completed and after Tristar and Menzies have completed multiple Scope 3 reporting cycles.

Agility is committed to reducing the carbon footprint of our own operations and working with partners across our value chain to reduce our collective impact on climate change.

Our controlled businesses are focusing on improving their environmental performance. Most are still in early phases of their journey, largely concentrating on improving data collection and reporting systems.

b. Types of energy included in the reductions; whether fuel, electricity, heating, cooling,steam, or all.

Omitted: information unavailable / incomplete. See above.

c. Basis for calculating reductions in energy consumption, such as base year or baseline, including the rationale for choosing it.

Omitted: information unavailable / incomplete. See above.

d. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: information unavailable / incomplete. See above.

a. Reductions in energy requirements of sold products and services achieved during the reporting period, in joules or multiples.

Omitted: not applicable.

b. Basis for calculating reductions in energy consumption, such as base year or baseline, including the rationale for choosing it.

Omitted: not applicable.

c. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: not applicable.

a. A description of how the organization interacts with water, including how and where water is withdrawn, consumed, and discharged, and the water-related impacts the organization has caused or contributed to, or that are directly linked to its operations, products, or services by its business relationships (e.g., impacts caused by runoff).

Omitted: information unavailable / incomplete.
 
Water management is a material issue at Group level, as well as being relevant to different degrees for each of our controlled businesses, as determined in our 2022-2023 materiality assessment.
 
Agility’s operations largely withdraw, consume and discharge water at their respective operating locations. We estimate that most water originates from municipal supplies, including delivered water. In some locations in Africa and India water may be withdrawn from wells.
 
Agility is not a water intensive company, with the exception of GCC Services, which provides remote life support and institutional food services, both of which are water intensive. Generally, water consumption is low and we believe discharge impact is low, with the exception of GCC Services, which manages water discharge in strict conformance to health, safety and environmental requirements of its institutional customers and within its environmental policy framework.

b. A description of the approach used to identify water-related impacts, including the scope of assessments, their timeframe, and any tools or methodologies used.

Our Groupwide water data management systems are in early stages and we will provide further update as we make progress. We are reporting our water consumption for the first time in 2023, excluding data from Menzies Aviation, which does not yet report this.

c. A description of how water-related impacts are addressed, including how the organization works with stakeholders to steward water as a shared resource, and how it engages with suppliers or customers with significant water-related impacts.

Agility complies with local laws and environmental regulations where water-related impacts are concerned.

d. An explanation of the process for setting any water-related goals and targets that are part of the organization’s approach to managing water and effluents, and how they relate to public policy and the local context of each area with water stress.

Our 2022-2023 materiality assessment determined water management as a material issue. Our Groupwide water data management systems are in early stages and we will provide further update as we make progress.

a. A description of any minimum standards set for the quality of effluent discharge, and how these minimum standards were determined, including:

Omitted: see 303-1.

i. how standards for facilities operating in locations with no local discharge requirements were determined;

Omitted: see 303-1.

ii. any internally developed water quality standards or guidelines;

Omitted: see 303-1.

iii. any sector-specific standards considered;

Omitted: see 303-1.

iv. whether the profile of the receiving waterbody was considered.

Omitted: see 303-1.

a. Total water withdrawal from all areas in megaliters, and a breakdown of this total by the following sources, if applicable:

Omitted: see 303-1.

i. Surface water;

Omitted: see 303-1.

ii. Groundwater;

Omitted: see 303-1.

iii. Seawater;

Omitted: see 303-1.

iv. Produced water;

Omitted: see 303-1.

v. Third-party water.

Omitted: see 303-1.

b. Total water withdrawal from all areas with water stress in megaliters, and a breakdown of this total by the following sources, if applicable:

Omitted: see 303-1.

i. Surface water;

Omitted: see 303-1.

ii. Groundwater;

Omitted: see 303-1.

iii. Seawater;

Omitted: see 303-1.

iv. Produced water;

Omitted: see 303-1.

v. Third-party water, and a breakdown of this total by the withdrawal sources listed in i-iv.

Omitted: see 303-1.

c. A breakdown of total water withdrawal from each of the sources listed in Disclosures 303-3-a and 303-3-b in megaliters by the following categories:

Omitted: see 303-1.

i. Freshwater (≤1,000 mg/L Total Dissolved Solids);

Omitted: see 303-1.

ii. Other water (>1,000 mg/L Total Dissolved Solids).

Omitted: see 303-1.

d. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used.

Omitted: see 303-1.

a. Total water discharge to all areas in megaliters, and a breakdown of this total by the following types of destination, if applicable:

Omitted: see 303-1.

i. Surface water;

Omitted: see 303-1.

ii. Groundwater;

Omitted: see 303-1.

iii. Seawater;

Omitted: see 303-1.

iv. Third-party water, and the volume of this total sent for use to other organizations, if applicable.

Omitted: see 303-1.

b. A breakdown of total water discharge to all areas in megaliters by the following categories:

Omitted: see 303-1.

i. Freshwater (≤1,000 mg/L Total Dissolved Solids);

Omitted: see 303-1.

ii. Other water (>1,000 mg/L Total Dissolved Solids).

Omitted: see 303-1.

c. Total water discharge to all areas with water stress in megaliters, and a breakdown of this total by the following categories:

Omitted: see 303-1.

i. Freshwater (≤1,000 mg/L Total Dissolved Solids);

Omitted: see 303-1.

ii. Other water (>1,000 mg/L Total Dissolved Solids).

Omitted: see 303-1.

d. Priority substances of concern for which discharges are treated, including:

Omitted: see 303-1.

i. how priority substances of concern were defined, and any international standard, authoritative list, or criteria used;

Omitted: see 303-1.

ii. the approach for setting discharge limits for priority substances of concern;

Omitted: see 303-1.

iii. number of incidents of non-compliance with discharge limits.

Omitted: see 303-1.

e. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used.

Omitted: see 303-1.

a. Total water consumption from all areas in megaliters.

247.423

b. Total water consumption from all areas with water stress in megaliters.

Omitted: see 303-1.

c. Change in water storage in megaliters, if water storage has been identified as having a significant water-related impact.

Omitted: see 303-1.

d. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used, including whether the information is calculated, estimated, modeled, or sourced from direct measurements, and the approach taken for this, such as the use of any sector-specific factors.

This does not include data from Menzies Aviation, which does not yet report water consumption. Our Groupwide water data management systems are in early stages and we will provide further update as we make progress.

a. For each operational site owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas, the following information:

Omitted: not currently material.

i. Geographic location;

See above.

ii. Subsurface and underground land that may be owned, leased, or managed by the organization;

See above.

iii. Position in relation to the protected area (in the area, adjacent to, or containing portions of the protected area) or the high biodiversity value area outside protected areas;

See above.

iv. Type of operation (office, manufacturing or production, or extractive);

See above.

v. Size of operational site in km2 (or another unit, if appropriate);

See above.

vi. Biodiversity value characterized by the attribute of the protected area or area of
high biodiversity value outside the protected area (terrestrial, freshwater, or
maritime ecosystem);

See above.

vii. Biodiversity value characterized by listing of protected status (such as IUCN Protected Area Management Categories, Ramsar Convention, national legislation).

See above.

a. Nature of significant direct and indirect impacts on biodiversity with reference to one or more of the following:

Omitted: not currently material.

i. Construction or use of manufacturing plants, mines, and transport infrastructure;

See above.

ii. Pollution (introduction of substances that do not naturally occur in the habitat from point and non-point sources);

See above.

iii. Introduction of invasive species, pests, and pathogens;

See above.

iv. Reduction of species;

See above.

v. Habitat conversion;

See above.

vi. Changes in ecological processes outside the natural range of variation (such as salinity or changes in groundwater level).

See above.

b. Significant direct and indirect positive and negative impacts with reference to the following:

See above.

i. Species affected;

See above.

ii. Extent of areas impacted;

See above.

iii. Duration of impacts;

See above.

iv. Reversibility or irreversibility of the impacts.

See above.

a. Size and location of all habitat areas protected or restored, and whether the success of the restoration measure was or is approved by independent external professionals.

Omitted: not currently material.

b. Whether partnerships exist with third parties to protect or restore habitat areas distinct from where the organization has overseen and implemented restoration or protection measures.

See above.

c. Status of each area based on its condition at the close of the reporting period.

See above.

d. Standards, methodologies, and assumptions used.

See above.

a. Total number of IUCN Red List species and national conservation list species with habitats in areas affected by the operations of the organization, by level of extinction risk:

Omitted: not currently material.

i. Critically endangered

See above.

ii. Endangered

See above.

iii. Vulnerable

See above.

iv. Near threatened

See above.

v. Least concern

See above.

a. Gross direct (Scope 1) GHG emissions in metric tons of CO2 equivalent.

188,250.98

Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share. We currently report Scope 1 and 2 carbon emissions for more than 95% of the company based on headcount. Reporting entities include Tristar, Menzies, ALP, GCC Services, UPAC and MRC. GCS and the Shipa Companies partially report due to limited data availability. AES does not report due to unavailability of data. We use headcount as a proxy for operational impact because this typically correlates to the size of operations.

Agility Sustainability Report FY23, pages 21, 53, 55

b. Gases included in the calculation; whether CO2 , CH4 , N2O, HFCs, PFCs, SF6 , NF3 , or all.

CO2e

c. Biogenic CO2 emissions in metric tons of CO2 equivalent.

Omitted: information unavailable / incomplete.

d. Base year for the calculation, if applicable, including:

We will complete a full emissions baseline in 2025 once the full integration of Menzies is completed and after Tristar and Menzies have completed multiple Scope 3 reporting cycles.

Agility Sustainability Report FY23, pages 21, 53

i. the rationale for choosing it;

See above.

ii. emissions in the base year;

See above.

iii. the context for any significant changes in emissions that triggered recalculations of base year emissions.

See above.

e. Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source.

2021 IEA & Defra factors

International Energy Agency website: IEA – International Energy Agency

f. Consolidation approach for emissions; whether equity share, financial control, or operational control.

Operational control

Agility Sustainability Report FY23, pages 21, 53

g. Standards, methodologies, assumptions, and/or calculation tools used.

Where CO2 data are reported, Agility relies on the conversion factors from the IEA 2021 Greenhouse Gas Emissions and UK Defra.

a. Gross location-based energy indirect (Scope 2) GHG emissions in metric tons of CO2 equivalent.

21,127.83

Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share. We currently report Scope 1 and 2 carbon emissions for more than 95% of the company based on headcount. Reporting entities include Tristar, Menzies, ALP, GCC Services, UPAC and MRC. GCS and the Shipa Companies partially report due to limited data availability. AES does not report due to unavailability of data. We use headcount as a proxy for operational impact because this typically correlates to the size of operations.

Agility Sustainability Report FY23, pages 21, 53, 55

b. If applicable, gross market-based energy indirect (Scope 2) GHG emissions in metric tons of CO2 equivalent.

Omitted: not applicable.

c. If available, the gases included in the calculation; whether CO , CH , N O, HFCs, PFCs, SF , NF , or all.

CO2e

d. Base year for the calculation, if applicable, including:

We will complete a full emissions baseline in 2025 once the full integration of Menzies is completed and after Tristar and Menzies have completed multiple Scope 3 reporting cycles.

Agility Sustainability Report FY23, pages 21, 53

i. the rationale for choosing it;

See above.

ii. emissions in the base year;

See above.

iii. the context for any significant changes in emissions that triggered recalculations of base year emissions.

See above.

e. Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source.

2021 IEA factors & UK Defra factors

International Energy Agency website: IEA – International Energy Agency

f. Consolidation approach for emissions; whether equity share, financial control, or operational control.

Operational control

Agility Sustainability Report FY23, pages 21, 53

g. Standards, methodologies, assumptions, and/or calculation tools used.

Where CO2 data are reported, Agility relies on the conversion factors from the IEA 2021 Greenhouse Gas Emissions from Energy database and UK Defra.

a. Gross other indirect (Scope 3) GHG emissions in metric tons of CO2 equivalent.

3,629,347.22

We currently report Scope 3 carbon emissions for 86.8% of the company based on headcount. Scope 3 emissions reported by the controlled businesses may include emissions from purchased goods and services, capital goods, fuel and energy related (upstream emissions related to electricity and fuel consumption, etc.), waste generated in operations, upstream transportation and distribution, business travel, employee commuting, upstream and downstream leased assets, downstream transportation and distribution and use of sold products. Reporting entities include ALP, GCC, Menzies, Shipa companies, Tristar, and UPAC.

See Agility’s Sustainability Report FY23, pages 21 and 55 for available Scope 3 emissions data.

Agility Sustainability Report FY23, pages 21, 53, 55

b. If available, the gases included in the calculation; whether CO , CH , N O, HFCs, PFCs, SF , NF , or all.

Omitted: information unavailable / incomplete. See above.

c. Biogenic CO2 emissions in metric tons of CO2equivalent.

Omitted: information unavailable / incomplete. See above.

d. Other indirect (Scope 3) GHG emissions categories and activities included in the calculation.

Omitted: information unavailable / incomplete. See above.

e. Base year for the calculation, if applicable, including:

Omitted: information unavailable / incomplete. See above.

i. the rationale for choosing it;

Omitted: information unavailable / incomplete. See above.

ii. emissions in the base year;

Omitted: information unavailable / incomplete. See above.

iii. the context for any significant changes in emissions that triggered recalculations of base year emissions.

Omitted: information unavailable / incomplete. See above.

f. Source of the emission factors and the global warming potential (GWP) rates used, or a reference to the GWP source.

Omitted: information unavailable / incomplete. See above.

g. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: information unavailable / incomplete. See above.

a. GHG emissions intensity ratio for the organization.

0.155

This intensity ratio includes scopes 1 & 2 information from all reporting organizations, plus full scope 3 information from 86.8% of the company based on headcount. All reported Scope 3 emissions are from upstream emissions related to electricity and fuel consumption. Reporting entities include ALP, GCC, Menzies, Shipa companies, Tristar, and UPAC.

Reported gross GHG emissions include 100% of all reported subsidiary emissions, including Tristar’s emissions, which had previously been reported at 65.12%, proportional to Agility’s ownership share.

b. Organization-specific metric (the denominator) chosen to calculate the ratio.

c. Types of GHG emissions included in the intensity ratio; whether direct (Scope 1), energy indirect (Scope 2), and/or other indirect (Scope 3).

Scopes 1 & 2 only.

d. Gases included in the calculation; whether CO2 , CH4 , N2O, HFCs, PFCs, SF6 , NF3 , or all.

CO2

a. GHG emissions reduced as a direct result of reduction initiatives, in metric tons of CO2 equivalent.

Scopes 1 and 3 emissions increased, mostly due to changes in reporting, but also business growth. In 2022 we reported only five months of Menzies emissions because Menzies was owned by Agility for five months in 2022, and we reported 65.12% of Tristar emissions. In 2023 we are reporting the full 12 months of Menzies emissions and 100% of Tristar emissions to align with Tristar’s consolidated financial reporting.
Scope 2 emissions decreased due to operational efficiency improvements, as well as changes to the business.

b. Gases included in the calculation; whether CO2 , CH4 , N2O, HFCs, PFCs, SF6 , NF3 , or all.

CO2e

c. Base year or baseline, including the rationale for choosing it.

d. Scopes in which reductions took place; whether direct (Scope 1), energy indirect (Scope 2), and/or other indirect (Scope 3).

e. Standards, methodologies, assumptions, and/or calculation tools used.

IEA and UK Defra standards and methodology, as applicable.

a. Production, imports, and exports of ODS in metric tons of CFC-11 (trichlorofluoromethane) equivalent.

Omitted: information unavailable / incomplete.

b. Substances included in the calculation.

Omitted: information unavailable / incomplete.

c. Source of the emission factors used.

Omitted: information unavailable / incomplete.

d. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: information unavailable / incomplete.

a. Significant air emissions, in kilograms or multiples, for each of the following:

Omitted: information unavailable / incomplete.

i. NOx;

Omitted: information unavailable / incomplete.

ii. SOx;

Omitted: information unavailable / incomplete.

iii. Persistent organic pollutants (POP);

Omitted: information unavailable / incomplete.

iv. Volatile organic compounds (VOC);

Omitted: information unavailable / incomplete.

v. Hazardous air pollutants (HAP);

Omitted: information unavailable / incomplete.

vi. Particulate matter (PM);

Omitted: information unavailable / incomplete.

vii. Other standard categories of air emissions identified in relevant regulations.

Omitted: information unavailable / incomplete.

b. Source of the emission factors used.

Omitted: information unavailable / incomplete.

c. Standards, methodologies, assumptions, and/or calculation tools used.

Omitted: information unavailable / incomplete.

a. For the organization’s significant actual and potential waste-related impacts, a description of:

The creation and management of waste is material to Agility at a group level and relevant to varying degrees for our controlled businesses. We are working to strengthen data systems to capture our groupwide waste data, which are currently in early stages.

i. the inputs, activities, and outputs that lead or could lead to these impacts;

Waste management is the core of MRC’s business, including safe medical waste disposal and plastics and scrap metal recycling. Reduction of food waste is relevant to GCC Services; likewise, cargo waste for Menzies.

ii. whether these impacts relate to waste generated in the organization’s own activities or to waste generated upstream or downstream in its value chain.

Omitted: information unavailable / incomplete.

a. Actions, including circularity measures, taken to prevent waste generation in the organization’s own activities and upstream and downstream in its value chain, and to manage significant impacts from waste generated.

Omitted: information unavailable / incomplete. The creation and management of waste is material to Agility at a group level and relevant to varying degrees for our controlled businesses. We are working to strengthen data systems to capture our groupwide waste data, which are currently in early stages.

b. If the waste generated by the organization in its own activities is managed by a third party, a description of the processes used to determine whether the third party manages the waste in line with contractual or legislative obligations.

Omitted: information unavailable / incomplete. See above.

c. The processes used to collect and monitor waste-related data.

Omitted: information unavailable / incomplete. See above.

a. Total weight of waste generated in metric tons, and a breakdown of this total by composition of the waste.

Omitted: information unavailable / incomplete. The creation and management of waste is material to Agility at a group level and relevant to varying degrees for our controlled businesses. We are working to strengthen data systems to capture our groupwide waste data, which are currently in early stages.

b. Contextual information necessary to understand the data and how the data has been compiled.

Omitted: information unavailable / incomplete. See above.

a. Total weight of waste diverted from disposal in metric tons, and a breakdown of this total by composition of the waste.

Omitted: information unavailable / incomplete. The creation and management of waste is material to Agility at a group level and relevant to varying degrees for our controlled businesses. We are working to strengthen data systems to capture our groupwide waste data, which are currently in early stages.

b. Total weight of hazardous waste diverted from disposal in metric tons, and a breakdown of this total by the following recovery operations:

Omitted: information unavailable / incomplete. See above.

i. Preparation for reuse;

Omitted: information unavailable / incomplete. See above.

ii. Recycling;

Omitted: information unavailable / incomplete. See above.

iii. Other recovery operations.

Omitted: information unavailable / incomplete. See above.

c. Total weight of non-hazardous waste diverted from disposal in metric tons, and a breakdown of this total by the following recovery operations:

Omitted: information unavailable / incomplete. See above.

i. Preparation for reuse;

Omitted: information unavailable / incomplete. See above.

ii. Recycling;

Omitted: information unavailable / incomplete. See above.

iii. Other recovery operations.

Omitted: information unavailable / incomplete. See above.

d. For each recovery operation listed in Disclosures 306-4-b and 306-4-c, a breakdown of the total weight in metric tons of hazardous waste and of non-hazardous waste diverted from disposal:

Omitted: information unavailable / incomplete. See above.

i. onsite;

Omitted: information unavailable / incomplete. See above.

ii. offsite.

Omitted: information unavailable / incomplete. See above.

e. Contextual information necessary to understand the data and how the data has been compiled.

Omitted: information unavailable / incomplete. See above.

a. Total weight of waste directed to disposal in metric tons, and a breakdown of this total by composition of the waste.

Omitted: information unavailable / incomplete. The creation and management of waste is a material issue of concern for Agility, and Groupwide waste and water data management systems are in early stages. We aim to have a better idea of scope and initial data in 2023.

b. Total weight of hazardous waste directed to disposal in metric tons, and a breakdown of this total by the following disposal operations:

Omitted: information unavailable / incomplete. See above.

i. Incineration (with energy recovery);

Omitted: information unavailable / incomplete. See above.

ii. Incineration (without energy recovery);

Omitted: information unavailable / incomplete. See above.

iii. Landfilling;

Omitted: information unavailable / incomplete. See above.

iv. Other disposal operations.

Omitted: information unavailable / incomplete. See above.

c. Total weight of non-hazardous waste directed to disposal in metric tons, and a breakdown of this total by the following disposal operations:

Omitted: information unavailable / incomplete. See above.

i. Incineration (with energy recovery);

Omitted: information unavailable / incomplete. See above.

ii. Incineration (without energy recovery);

Omitted: information unavailable / incomplete. See above.

iii. Landfilling;

Omitted: information unavailable / incomplete. See above.

iv. Other disposal operations.

Omitted: information unavailable / incomplete. See above.

d. For each disposal operation listed in Disclosures 306-5-b and 306-5-c, a breakdown of the total weight in metric tons of hazardous waste and of non-hazardous waste directed to disposal:

Omitted: information unavailable / incomplete. See above.

i. onsite;

Omitted: information unavailable / incomplete. See above.

ii. offsite.

Omitted: information unavailable / incomplete. See above.

e. Contextual information necessary to understand the data and how the data has been compiled.

Omitted: information unavailable / incomplete. See above.

a. Percentage of new suppliers that were screened using environmental criteria.

Agility Quality, Environment, Health, Safety & Security Policy

Agility Sustainability Report FY23, page 17

a. Number of suppliers assessed for environmental impacts.

Omitted: information unavailable / incomplete. See 308-1.

b. Number of suppliers identified as having significant actual and potential negative environmental impacts.

Omitted: information unavailable / incomplete. See 308-1.

c. Significant actual and potential negative environmental impacts identified in the supply chain.

Omitted: information unavailable / incomplete. See 308-1.

d. Percentage of suppliers identified as having significant actual and potential negative environmental impacts with which improvements were agreed upon as a result of assessment.

Omitted: information unavailable / incomplete. See 308-1.

e. Percentage of suppliers identified as having significant actual and potential negative environmental impacts with which relationships were terminated as a result of assessment, and why.

Omitted: information unavailable / incomplete. See 308-1.

a. Total number and rate of new employee hires during the reporting period, by age group, gender and region.

In 2023, Agility and its companies hired 20,071 new employees, of which 14,118 (70.34%) were male and 5,953 (29.66%) were female.

b. Total number and rate of employee turnover during the reporting period, by age group, gender and region.

a. Benefits which are standard for full-time employees of the organization but are not provided to temporary or part-time employees, by significant locations of operation. These include, as a minimum:

All of Agility’s full time employees receive full social and labor protections as per local law and regulation. Part-time and temporary employees receive benefits as required by local law, which may not be equal to those provided to full-time employees.

i. life insurance;

Agility’s full time employees receive health insurance or health care benefits per individual company policy, and as per local law and regulation. See note above regarding part time employees and reporting by country.

ii. health care;

Agility’s full time employees receive disability and invalidity coverage per individual company policy, and as per local law and regulation. See note above regarding part time employees and reporting by country.

iii. disability and invalidity coverage;

Agility’s full time employees receive life insurance benefits per individual company policy, and as per local law and regulation. See note above regarding part time employees and reporting by country.

iv. parental leave;

Parental leave entitlement is not globally tracked, including by gender. All employees are provided parental leave based on local regulatory and/or policy requirements, which vary by location. However, as part of our obligations under our UN Women’s Empowerment Principles commitments, we track and report the number of employees that took parental leave — including by gender — and we estimate post-leave employee retention and turnover rates.

v. retirement provision;

Agility’s full time employees receive retirement provision benefits per individual company policy, and as per local law and regulation. See note above regarding part time employees and reporting by country.

vi. stock ownership;

Agility does not provide stock ownership as part of its benefits to employees. See note above regarding part time employees and reporting by country.

vii. others.

Agility’s full time employees receive paid vacation and sick leave benefits per individual company policy, and as per local law and regulation. See note above regarding part time employees and reporting by country.

b. The definition used for ‘significant locations of operation’.

Sites with >50 workers, including employees and contract or temporary workers.

a. Total number of employees that were entitled to parental leave, by gender.

Parental leave entitlement is not globally tracked, including by gender. All employees are provided parental leave based on local regulatory and/or policy requirements, which vary by location.

b. Total number of employees that took parental leave, by gender.

c. Total number of employees that returned to work in the reporting period after parental leave ended, by gender.

Omitted: information unavailable / incomplete.

d. Total number of employees that returned to work after parental leave ended that were still employed 12 months after their return to work, by gender.

Omitted: information unavailable / incomplete.

e. Return to work and retention rates of employees that took parental leave, by gender.

Omitted: information unavailable / incomplete.

a. Minimum number of weeks’ notice typically provided to employees and their representatives prior to the implementation of significant operational changes that could substantially affect them.

Agility follows local laws regarding notice periods for operational changes.

Agility Human Rights Policy: Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020

b. For organizations with collective bargaining agreements, report whether the notice period and provisions for consultation and negotiation are specified in collective agreements.

Notice period and provisions for consultation and negotiation are specified in collective agreements as may be determined by collective bargaining resolutions.

Agility Human Rights Policy: Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020

a. A statement of whether an occupational health and safety management system has been implemented, including whether:

The wellbeing of our people is always a priority. Following the acquisition of Menzies Aviation, Agility recognizes that it does not have a single, integrated health & safety management system across all companies. Each company operates its own health & safety system in accordance with its own unique requirements and appropriate industry standards. These systems cover 100% of all company operations.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities. We are working to strengthen and optimize health and safety data systems and assess the health and safety landscape across our remaining controlled business units. We are currently working to build an integrated health and safety program with common global metrics across all our businesses. In 2023 we delegated responsibilities to a health & safety director and convened a health & safety council that meets quarterly. We are updating our policy and framework in 2024.

Agility Sustainability Report FY23, pages 18, 54

i. the system has been implemented because of legal requirements and, if so, a list of the requirements;

Agility companies’ health and safety systems have been implemented to respond to operational and legal requirements. The legal requirements for our operations vary widely depending on the geography of operations.

ii.  the system has been implemented based on recognized risk management and/or management system standards/guidelines and, if so, a list of the standards/guidelines.

Currently, various Agility companies like Menzies Aviation, GCC Services, Tristar, UPAC, MRC and ALP are ISO 45001/18001 or equivalent standard certified. Together, ISO certified health and safety management systems or their equivalents cover 92% of Agility’s overall total headcount.

Agility Sustainability Report FY23, page 54

b. A description of the scope of workers, activities, and workplaces covered by the occupational health and safety management system, and an explanation of whether and, if so, why any workers, activities, or workplaces are not covered.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

Agility Sustainability Report FY23, pages 18, 54

The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by  the organization:

a. A description of the processes used to identify work-related hazards and assess risks on a routine and non-routine basis, and to apply the hierarchy of controls in order to eliminate hazards and minimize risks, including:

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting. For example, all of Tristar’s road safety incidents are reported, recorded and followed up by a meeting with all those involved the next day. Action is taken immediately following the incident, lessons learnt are captured and employees are trained daily through Tool Box sessions.

Agility Sustainability Report FY23, pages 18, 27, 33, 40, 54

i. how the organization ensures the quality of these processes, including the competency of persons who carry them out;

See above.

ii. how the results of these processes are used to evaluate and continually improve the occupational health and safety management system.

See above.

b. A description of the processes for workers to report work-related hazards and hazardous situations, and an explanation of how workers are protected against reprisals.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

c. A description of the policies and processes for workers to remove themselves from work situations that they believe could cause injury or ill health, and an explanation of  how workers are protected against reprisals.

Our largest businesses all have a managed health and safety program, including processes to protect complainants.

d. A description of the processes used to investigate work-related incidents, including the processes to identify hazards and assess risks relating to the incidents, to  determine corrective actions using the hierarchy of controls, and to determine improvements needed in the occupational health and safety management system.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

a. A description of the occupational health services’ functions that contribute to the identification and elimination of hazards and minimization of risks, and an explanation of how the organization ensures the quality of these services and facilitates workers’ access to them.

1.3.1 How the organization maintains the confidentiality of workers’ personal health related information;

Agility’s data protection policies clarify that the collection and use of personal data is kept confidential, and must have a clear purpose associated with it. Systems that Agility uses to collect data have completed the required impact assessments to ensure all employee data is kept safe and secure. All data collection adheres to local regulations regarding data privacy.

Agility human rights policy Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020 and human rights webpage Human Rights | Agility Sustainability

1.3.2 How the organization ensures that workers’ personal health-related information and their participation in any occupational health services is not used for any favorable or unfavorable treatment of workers.

Agility is committed to providing a work environment that is free from all types of harassment and discrimination. Agility’s policy is to not discriminate on the basis of race, color, religion, gender, age, nationality, sexual preference, disability, or any other factors prohibited by applicable laws, including health-related reasons.

Additionally, Agility’s data protection policies clarify that the collection and use of personal data is kept confidential, and must have a clear purpose associated with it. Systems that Agility uses to collect data have completed the required impact assessments to ensure all employee data is kept safe and secure. All data collection adheres to local regulations regarding data privacy.

Agility human rights policy Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020 and human rights webpage Human Rights | Agility Sustainability

The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by  the organization:

a. A description of the processes for worker participation and consultation in the development, implementation, and evaluation of the occupational health and safety management system, and for providing access to and communicating relevant information on occupational health and safety to workers.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

We are currently working to build an integrated health and safety program with common global metrics across all our businesses. In 2023 we delegated responsibilities to a health & safety director and convened a health & safety council that meets quarterly. We are updating our policy and framework in 2024.

Agility Sustainability Report FY23, pages 18, 54

b. Where formal joint management-worker health and safety committees exist, a description of their responsibilities, meeting frequency, decision-making authority, and whether and, if so, why any workers are not represented by these committees.

See 403-4 a.

1.4 The reporting organization should report whether and, if so, which occupational health and safety topics are covered in local or global formal agreements with trade unions.

See 403-4 a.

The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by  the organization:

a. A description of any occupational health and safety training provided to workers, including generic training as well as training on specific work-related hazards, hazardous activities, or hazardous situations.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

We are currently working to build an integrated health and safety program with common global metrics across all our businesses. In 2023 we delegated responsibilities to a health & safety director and convened a health & safety council that meets quarterly. We are updating our policy and framework in 2024.

Agility Sustainability Report FY23, pages 18, 54

The reporting organization shall report the following information for employees and for workers who are not employees but whose work and/or workplace is controlled by the organization:

a. An explanation of how the organization facilitates workers’ access to non-occupational medical and healthcare services, and the scope of access provided.

Our largest businesses all have a managed health and safety program, including hazard and risk identification and reporting, incident investigation and corrective actions management, protection for complainants, worker engagement and training, and delegated health and safety roles and responsibilities.

We are currently working to build an integrated health and safety program with common global metrics across all our businesses. In 2023 we delegated responsibilities to a health & safety director and convened a health & safety council that meets quarterly. We are updating our policy and framework in 2024.

Agility Sustainability Report FY23, pages 18, 54

b. A description of any voluntary health promotion services and programs offered to workers to address major non-work-related health risks, including the specific health  risks addressed, and how the organization facilitates workers’ access to these services and programs.

See 403-6 a.

1.5.1 How the organization maintains the confidentiality of workers’ personal healthrelated information;

Agility’s data protection policies clarify that the collection and use of personal data is kept confidential, and must have a clear purpose associated with it. Systems that Agility uses to collect data have completed the required impact assessments to ensure all employee data is kept safe and secure. All data collection adheres to local regulations regarding data privacy.

Agility Code of Ethics and Conduct, page 18, https://sustainability.agility.com/wp-content/uploads/2020/10/Agility-Code-of-Ethics-1.pdf.

1.5.2 How the organization ensures that workers’ personal health-related information and their participation in any services or programs is not used for any favorable or unfavorable treatment of workers.

Agility’s data protection policies clarify that the collection and use of personal data is kept confidential, and must have a clear purpose associated with it. Systems that Agility uses to collect data have completed the required impact assessments to ensure all employee data is kept safe and secure. All data collection adheres to local regulations regarding data privacy. Additionally, Agility has a strict anti-discrimination policy that prevents the company from discriminating against persons on the basis of health or related issues.

Agility Code of Ethics and Conduct, page 18, https://sustainability.agility.com/wp-content/uploads/2020/10/Agility-Code-of-Ethics-1.pdf; and Agility’s Human Rights Policy (Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020)

a. A description of the organization’s approach to preventing or mitigating significant negative occupational health and safety impacts that are directly linked to its operations, products, or services by its business relationships, and the related hazards and risks.

Agility companies independently manage supplier relationships. Health and safety is integrated into the Agility Corporate procurement process during requests for information, requests for proposals, award notifications, and contracts. The Corporate procurement team services Agility Corporate, ALP, Shipa companies, and others.
 
We strengthened our sustainable procurement efforts in 2023, embedding sustainability requirements into supplier contracts managed by the Corporate procurement team. Any supplier awarded Agility Corporate’s business must abide by these requirements, including minimum standards on health and safety. We now require all potential and current suppliers to comply with the Agility Quality, Environment, Health, Safety & Security Policy throughout the tendering, award, and contracting phases.
 
Starting in 2024, 100% of new supplier contracts will include our sustainable procurement requirements — this includes all procurements for Agility Corporate, ALP, GCS, MRC, and the Shipa companies.

Agility Group Quality, Environment, Health, Safety & Security Policy

a. If the organization has implemented an occupational health and safety management system based on legal requirements and/or recognized standards/guidelines:

Agility companies’ health and safety systems have been implemented to respond to operational and legal requirements. The legal requirements for our operations vary widely depending on the geography of operations.

i. the number and percentage of all employees and workers who are not employees but whose work and/or workplace is controlled by the organization, who are covered by such a system;

Agility Sustainability Report FY23, page 54

ii. the number and percentage of all employees and workers who are not employees but whose work and/or workplace is controlled by the organization, who are covered by such a system that has been internally audited;

Agility Sustainability Report FY23, page 54

iii. the number and percentage of all employees and workers who are not employees but whose work and/or workplace is controlled by the organization, who are covered by such a system that has been audited or certified by an external party.

92.8% of Agility operations by headcount.

Agility Sustainability Report FY23, page 54

b. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded.

No workers have been excluded from this disclosure.

c. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used.

The figures are based on a sum of employee headcount working in OHSAS 18001 and/or ISO 45001 or equivalent certified sites / total employee headcount.

a. For all employees:

i. The number and rate of fatalities as a result of work-related injury;

Zero.

Agility Sustainability Report FY23, page 54

ii. The number and rate of high-consequence work-related injuries (excluding fatalities);

The rate of high consequence injuries is 0.187. This does not include ALP or Shipa Delivery. More than 85% of employees are working in companies with HCIR of less than 0.01.

Agility Sustainability Report FY23, page 54

iii. The number and rate of recordable work-related injuries;

Agility Sustainability Report FY23, page 54

iv. The main types of work-related injury;

Omitted: information unavailable/incomplete.

Agility Sustainability Report FY23, page 54

v. The number of hours worked.

Omitted: information unavailable / incomplete.

Agility Sustainability Report FY23, page 54

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:

Omitted: information unavailable / incomplete.

i. The number and rate of fatalities as a result of work-related injury;

Omitted: information unavailable / incomplete.

ii. The number and rate of high-consequence work-related injuries (excluding fatalities);

Omitted: information unavailable / incomplete.

iii. The number and rate of recordable work-related injuries;

Omitted: information unavailable / incomplete.

iv. The main types of work-related injury;

Omitted: information unavailable / incomplete.

v. The number of hours worked.

Omitted: information unavailable / incomplete.

c. The work-related hazards that pose a risk of high-consequence injury, including:

Omitted: information unavailable / incomplete.

i. how these hazards have been determined;

Omitted: information unavailable / incomplete.

ii. which of these hazards have caused or contributed to high-consequence injuries during the reporting period;

Omitted: information unavailable / incomplete.

iii. actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls.

Omitted: information unavailable / incomplete.

d. Any actions taken or underway to eliminate other work-related hazards and minimize risks using the hierarchy of controls.

Omitted: information unavailable / incomplete.

e. Whether the rates have been calculated based on 200,000 or 1,000,000 hours worked.

Omitted: information unavailable / incomplete.

f. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded.

No workers were excluded.

g. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used.

We are currently working to build an integrated health and safety program with common global metrics across all our businesses. In 2023 we delegated responsibilities to a health & safety director and convened a health & safety council that meets quarterly. We are updating our policy and framework in 2024.

a. For all employees:

i. The number of fatalities as a result of work-related ill health;

Zero.

Agility Sustainability Report FY23, page 54

ii. The number of cases of recordable work-related ill health;

Omitted: information unavailable / incomplete. Health and safety is a priority across our subsidiaries and each company uses its own reporting processes to track H&S performance and progress against established standards, goals, targets and KPIs.

Agility Sustainability Report FY23, page 54

iii. The main types of work-related ill health.

Omitted: information unavailable / incomplete. See above.

b. For all workers who are not employees but whose work and/or workplace is controlled by the organization:

Omitted: information unavailable / incomplete. See above.

i. The number of fatalities as a result of work-related ill health;

Omitted: information unavailable / incomplete. See above.

ii. The number of cases of recordable work-related ill health;

Omitted: information unavailable / incomplete. See above.

iii. The main types of work-related ill health.

Omitted: information unavailable / incomplete. See above.

c. The work-related hazards that pose a risk of ill health, including:

Omitted: information unavailable / incomplete. Each Agility business identifies work-related hazards that pose a risk of ill-health. However, Agility currently lacks capability to summarily report on the ill-health risks identified by its controlled businesses operating in many sectors. Health and safety is a priority across our subsidiaries and each company uses its own reporting processes to track H&S performance and progress against established standards, goals, targets and KPIs.

Agility Sustainability Report FY23, page 54

i. how these hazards have been determined;

Omitted: information unavailable / incomplete. See above.

ii. which of these hazards have caused or contributed to cases of ill health during the reporting period;

Omitted: information unavailable / incomplete. See above.

iii. actions taken or underway to eliminate these hazards and minimize risks using the hierarchy of controls.

Omitted: information unavailable / incomplete. See above.

d. Whether and, if so, why any workers have been excluded from this disclosure, including the types of worker excluded.

Omitted: information unavailable / incomplete. See above.

e. Any contextual information necessary to understand how the data have been compiled, such as any standards, methodologies, and assumptions used.

Omitted: information unavailable / incomplete. See above.

a. Average hours of training that the organization’s employees have undertaken during the reporting period, by:

Omitted: information unavailable / incomplete. Our largest organization by headcount (Menzies) reported a total of 1,910,973 training hours, and a training compliance rate of 97.37%.

i. gender;

Omitted: information unavailable / incomplete. See above.

ii. employee category.

Omitted: information unavailable / incomplete. See above.

a. Type and scope of programs implemented and assistance provided to upgrade employee skills.

Many of our business units work in rapidly changing or challenging environments. Equipping our people with up-to-date skills and knowledge is essential to enabling them to do their jobs effectively. As appropriate, each company provides structured training via online or in-person training, or on-the-job training.

We have developed online on-demand Fair Labor training courses that are accessible to any Agility company and employee. We also provide online ethics training to a number of Agility companies besides Menzies and Tristar. Both of these companies manage their own training programs that include in-person, online and on-the-job training programs.

Agility Sustainability Report FY23, page 55

b. Transition assistance programs provided to facilitate continued employability and the management of career endings resulting from retirement or termination of employment.

Omitted: information unavailable / incomplete.

a. Percentage of total employees by gender and by employee category who received a regular performance and career development review during the reporting period.

Omitted: information unavailable / incomplete.

a. Percentage of individuals within the organization’s governance bodies in each of the following diversity categories:

Percentage of individuals within the organization’s governance bodies in each of the following diversity categories:

i. Gender;

23% Female; 77% Male

ii. Age group: under 30 years old, 30-50 years old, over 50 years old;

Under 30: 26%.

30-50: 50%.

Over 50: 24%.

iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

Agility assesses diversity primarily on the basis of gender.

b. Percentage of employees per employee category in each of the following diversity categories:

i. Gender;

Agility Sustainability Report FY23, page 55

ii. Age group: under 30 years old, 30-50 years old, over 50 years old;

Under 30: 26.7%

30-39: 26.6%

40-49: 18.0%

50-59: 9.8%

60+: 2.9%

Undisclosed: 16.0%

iii. Other indicators of diversity where relevant (such as minority or vulnerable groups).

a. Ratio of the basic salary and remuneration of women to men for each employee category, by significant locations of operation.

Omitted: information unavailable / incomplete.

b. The definition used for ‘significant locations of operation’.

Sites with >50 workers, including employees and contract or temporary workers.

a. Total number of incidents of discrimination during the reporting period.

Omitted: confidentiality constraints.

b. Status of the incidents and actions taken with reference to the following:

i. Incident reviewed by the organization;

All reported incidents are reviewed and investigated.

ii. Remediation plans being implemented;

Omitted: confidentiality constraints.

iii. Remediation plans that have been implemented, with results reviewed through routine internal management review processes;

Omitted: confidentiality constraints.

iv. Incident no longer subject to action.

Omitted: confidentiality constraints.

a. Operations and suppliers in which workers’ rights to exercise freedom of association or collective bargaining may be violated or at significant risk either in terms of:

i. type of operation (such as manufacturing plant) and supplier;

Omitted: information unavailable / incomplete. In some of Agility’s key markets, there are significant legal restrictions on collective bargaining.

ii. countries or geographic areas with operations and suppliers considered at risk.

Omitted: information unavailable / incomplete. In some of Agility’s key markets, there are significant legal restrictions on collective bargaining.

b. Measures taken by the organization in the reporting period intended to support rights to exercise freedom of association and collective bargaining.

As part of its fair labor approach and roll-out to subsidiaries in support of its 2025 sustainability goals, Agility aims to encourage regular interaction and engagement between management and employees across all of its subsidiary businesses.

a. Operations and suppliers considered to have significant risk for incidents of:

i. child labor;

Agility has a zero tolerance policy for child labor. The company adheres to the minimum age provisions in applicable laws and regulations where it conducts business.

Agility website (Human Rights | Agility Sustainability and Human Rights Policy and Framework (Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020)

ii. young workers exposed to hazardous work.

Our policy is that young persons under the age of 18 should not be employed at night or in hazardous conditions.

Agility website (Human Rights | Agility Sustainability and Human Rights Policy and Framework (Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020)

b. Operations and suppliers considered to have significant risk for incidents of child labor either in terms of:

i. type of operation (such as manufacturing plant) and supplier;

Regular assessments indicate that child labor is not a significant risk in our operations.

Agility public website:

 Human Rights | Agility Sustainability

ii. countries or geographic areas with operations and suppliers considered at risk.

Regular assessments indicate that child labor is not a significant risk in our operations.

Agility uses US DOS and other sources to assess country-level human rights risks. Please see the US DOS annual human rights report for more information: 2021 Country Reports on Human Rights Practices – United States Department of State

c. Measures taken by the organization in the reporting period intended to contribute to the effective abolition of child labor.

Agility has a zero tolerance policy for child labor. The company adheres to the minimum age provisions in applicable laws and regulations where it conducts business; and the company also has a strong policy and program to safeguard against and prevent child labor.

Agility website (Human Rights | Agility Sustainability and Human Rights Policy and Framework (Agility-Human-Rights-Policy-with-Slavery-Statement-03July2020)

a. Operations and suppliers considered to have significant risk for incidents of forced or compulsory labor either in terms of:

i. type of operation (such as manufacturing plant) and supplier;

All emerging and pioneer market operations are at higher risk.

ii. countries or geographic areas with operations and suppliers considered at risk.

All emerging and pioneer market operations are at higher risk.

b. Measures taken by the organization in the reporting period intended to contribute to the  elimination of all forms of forced or compulsory labor.

Agility Sustainability Report FY23, pages 17, 19, 55

Agility Human Rights Policy

Agility Supplier Fair Labor Code of Conduct

a. Percentage of security personnel who have received formal training in the organization’s human rights policies or specific procedures and their application to security.

Omitted: information unavailable / incomplete.

b. Whether training requirements also apply to third-party organizations providing security personnel.

Omitted: information unavailable / incomplete.

2.1.1 calculate the percentage using the total number of security personnel, whether they are employees of the organization or employees of third-party organizations;

Omitted: information unavailable / incomplete.

2.1.2 state whether employees of third-party organizations are also included in the calculation.

Omitted: information unavailable / incomplete.

a. Total number of identified incidents of violations involving the rights of indigenous peoples during the reporting period.

Omitted: not material.

b. Status of the incidents and actions taken with reference to the following:

Omitted: not material.

i. Incident reviewed by the organization;

Omitted: not material.

ii. Remediation plans being implemented;

Omitted: not material.

iii. Remediation plans that have been implemented, with results reviewed through routine internal management review processes;

Omitted: not material.

iv. Incident no longer subject to action.

Omitted: not material.

a. Percentage of operations with implemented local community engagement, impact assessments, and/or development programs, including the use of:

Agility works to create a positive difference across the communities in which we operate, through our program of partnership and investment. We prioritize projects that advance youth education, employment, entrepreneurship and technology, with a focus on supporting refugees and improving gender equality. We also continue to provide humanitarian partners with expertise and donated services during major natural disasters, and to support our employees to give their time and skills to causes close to their hearts.
 
In 2023, Agility’s community investment impacts reached more than 185,500 people across the world, of whom we estimate 50% are female. Since 2014, Agility’s community investments have reached more than 2.3 million people. We are committed to supporting males and females equally through the initiatives we fund.

Agility Sustainability Report FY23, page 22-25

i. social impact assessments, including gender impact assessments, based on participatory processes;

Agility assesses local social and gender context as part of its community program and project approval process. The company engages with local stakeholders, including employees, NGOs and government organizations, in this process.

ii. environmental impact assessments and ongoing monitoring;

Agility companies operate in accordance with Agility’s global environment policy, which highlights compliance with local legislation, regulations and statutes.

iii. public disclosure of results of environmental and social impact assessments;

Agility annually and transparently reports about its social and environmental impact.

iv. local community development programs based on local communities’ needs;

Agility’s community program incorporates local stakeholder engagement to ensure any projects undertaken are based on local community needs.

v. stakeholder engagement plans based on stakeholder mapping;

Stakeholders are mapped prior and during community program initiation to ensure the correct stakeholders are providing input to solve community challenges.

vi. broad based local community consultation committees and processes that include vulnerable groups;

Based on community consultations, refugees and gender are two critically important issues addressed by the Agility community program. Both of these issues impact vulnerable groups, including women, girls and refugees. Agility is committed to supporting males and females equally through the initiatives we fund, including in the education and refugee partnerships supported.

Agility Sustainability Report FY23, page 23

vii. works councils, occupational health and safety committees and other worker representation bodies to deal with impacts;

Omitted: information unavailable / incomplete.

viii. formal local community grievance processes.

Any external stakeholder can contact Agility to raise concerns by using the online “contact us” feature on the Agility website. Reports are managed on a time-bound basis with strict requirements for responding to complainants.

a. Operations with significant actual and potential negative impacts on local communities, including:

Omitted: information unavailable / incomplete.

i. the location of the operations;

Omitted: information unavailable / incomplete.

ii. the significant actual and potential negative impacts of operations.

Omitted: information unavailable / incomplete.

a. Percentage of new suppliers that were screened using social criteria.

90.0% of new suppliers onboarded by central procurement have signed our Fair Labor & Ethics Codes of Conduct, including 100% of Menzies, Tristar and GCC Services’ new suppliers. In 2023, around 67% of our procurement for goods, services, or materials for Agility Corporate, ALP, GCS, MRC, and the Shipa companies was spent with suppliers that agreed to adhere to our new sustainable procurement requirements. 25% of this spend was with key suppliers, including vendors which provide major components such as steel, lighting, slab on grade, and dock levellers.

Sustainability is integrated into the Agility Corporate procurement process during requests for information, requests for proposals, award notifications, and contracts. The Corporate procurement team services Agility Corporate, ALP, Shipa companies, and others.

We strengthened our sustainable procurement efforts in 2023, embedding sustainability requirements into supplier contracts managed by the Corporate procurement team. Any supplier awarded Agility Corporate’s business must abide by these requirements, including minimum standards on topics such as business ethics, human rights, working hours and wages, health and safety, and compliance with environmental regulations. We now require all potential and current suppliers to comply with our Supplier Code of Conduct, Human Rights Policy, and Supplier Fair Labor Code of Conduct throughout the tendering, award, and contracting phases. Starting in 2024, 100% of new supplier contracts will include our sustainable procurement requirements — this includes all procurements for Agility Corporate, ALP, GCS, MRC, and the Shipa companies.

a. Total monetary value of financial and in-kind political contributions made directly and indirectly by the organization by country and recipient/beneficiary.

Agility has made no political contributions during the reporting period.

b. If applicable, how the monetary value of in-kind contributions was estimated.

Agility has made no political contributions during the reporting period.

a. Percentage of significant product and service categories for which health and safety impacts are assessed for improvement.

Omitted: information unavailable / incomplete.

a. Total number of incidents of non-compliance with regulations and/or voluntary codes concerning the health and safety impacts of products and services within the  reporting period, by:

No reported incidents.

i. incidents of non-compliance with regulations resulting in a fine or penalty;

No reported incidents.

ii. incidents of non-compliance with regulations resulting in a warning;

No reported incidents.

iii. incidents of non-compliance with voluntary codes.

No reported incidents.

b. If the organization has not identified any non-compliance with regulations and/or voluntary codes, a brief statement of this fact is sufficient.

Agility has not identified any non-compliance with regulations and/or voluntary codes.

a. Whether each of the following types of information is required by the organization’s procedures for product and service information and labeling:

Omitted: not material.

i. The sourcing of components of the product or service;

Omitted: not material.

ii. Content, particularly with regard to substances that might produce an environmental or social impact;

Omitted: not material.

iii. Safe use of the product or service;

Omitted: not material.

iv. Disposal of the product and environmental or social impacts;

Omitted: not material.

v. Other (explain).

Omitted: not material.

b. Percentage of significant product or service categories covered by and assessed for compliance with such procedures.

Omitted: not material.

a. Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labeling, by:

Omitted: not material.

i. incidents of non-compliance with regulations resulting in a fine or penalty;

Omitted: not material.

ii. incidents of non-compliance with regulations resulting in a warning;

Omitted: not material.

iii. incidents of non-compliance with voluntary codes.

Omitted: not material.

b. If the organization has not identified any non-compliance with regulations and/or voluntary codes, a brief statement of this fact is sufficient.

Agility has not identified any non-compliance with regulations and/or voluntary codes.

a. Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship, by:

Omitted: not material.

i. incidents of non-compliance with regulations resulting in a fine or penalty;

Omitted: not material.

ii. incidents of non-compliance with regulations resulting in a warning;

Omitted: not material.

iii. incidents of non-compliance with voluntary codes.

Omitted: not material.

b. If the organization has not identified any non-compliance with regulations and/or voluntary codes, a brief statement of this fact is sufficient.

Agility has not identified any non-compliance with regulations and/or voluntary codes.

a. Total number of substantiated complaints received concerning breaches of customer privacy, categorized by:

Agility does not publicly disclose this information. Our information security program aligns with industry standard frameworks and regular risk assessments are conducted leveraging such standards. Agility continuously assesses the threat landscape using various publicly available information and tools and manages such evolving risks through ongoing investments in our security program. Our risk assessment results are also used to drive continuous improvement in our cybersecurity posture.

i. complaints received from outside parties and substantiated by the organization;

See above.

ii. complaints from regulatory bodies.

See above.

b. Total number of identified leaks, thefts, or losses of customer data.

Omitted: confidentiality restraints.

c. If the organization has not identified any substantiated complaints, a brief statement of this fact is sufficient.

Omitted: confidentiality restraints.