LTP Annual Sustainability Performance Report 2021

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HOW WE ANCHOR SUSTAINABILITY

THE JOURNEY TOWARDS OUR 4 SUSTAINABILITY COMMITMENTS

2021 RESULTS

RISK AND COMPLIANCE

2022 TARGETS

RISK AND COMPLIANCE

In 2021, LTP Group conducted a business risk assessment which included compliance risks. Those risks are presented in the below table. For each risk we present the mitigation measures implemented across LTP Group during 2021 and the mitigation measures to be implemented in 2022.

Specific LTP Group compliance related policies and documents can be found on LTP website . Those documents will be revised and updated regularly.

IDENTIFIED COMPLIANCE RISK IN 2021

RISK DESCRIPTION

RISK MITIGATION – ALREADY IMPLEMENTED IN 2021

RISK MITIGATION – TO BE IMPLEMENTED IN 2022

• Whistleblowing mechanism • Local complaint system in every factories • Code of Conduct & Ethics presented to production partners and suppliers • Social third-party audits through certifications: see full list in the appendix of this report • Separate risk assessment based on the inherent risk identified with support of Corruption Perception index 1) • Whistleblowing mechanism • Ethical policy for all entities in LTP Group established and signed by all managers • General anticorruption and bribery policy incorporated in factory standard • Code of Conduct & Ethics presented to production partners and suppliers • Review of data in CRM • On-boarding training/ information on employee's rights • Materiality assessment conducted which resulted in circularity identified as a material topic. As such, it has been added in LTP Group 2022-2025 sustainability strategy

• Risk assessment with focus on social and environmental topics and according to OECD guidelines on supply chain due diligence • Establishment of a Sustainability supply chain due diligence policy

Lack of control mechanism to prevent, identify and address breach of human rights among our business partners upstream and/ or downstream in the supply chain

Breach of human rights and working conditions in the global supply chain

• Establishment of a specific anti-corruption and fraud policy • Training modules provided by LTP Group legal manager to all directors and critical functions: e.g. finance, purchase • Tailor-made procedures based on a risk approach

Lack of preventive measures and control mechanism to prevent, identify and address corruption bribery or fraud in the organisation

Risk of corruption, bribery and fraud

• Optimisation of solutions for documents and information storage

Breach of Data Privacy laws

Breach of data privacy and GDPR regulations

Risk of not leading innovative manufacturing solutions enabling circularity such as the ability to disassemble products or increasing use of materials which have recycled content, or which can be recycled

• See commitment Embrace Durability & Circularity under the section “ 2022 TARGETS ” of this report for all details on 2022 priority topics and targets

Lack of focus on circularity

LTP Group 2021 Sustainability performance report

Note: 1) In 2021 CPI, Ukraine ranked 122 out of 180; Belarus ranked 82 out of 180; Vietnam ranked 87 out of 180

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