Titan Cement

Sustainability strategy and accountability
Titan Cement discloses its process for identifying and prioritising its most relevant sustainability impacts as well as the outcome of this process, in relation to its sustainability strategy. The company reports consistently against all its set targets. 

Ecosystem conversion and restoration 
Titan Cement has reported its time-bound target to have quarry biodiversity management plans at 100% of their sites in high biodiversity value areas by 2025.  

No leading practices were identified in the social inclusion and community impact area.

Sustainability strategy and accountability
While the company discloses some sustainability targets, no evidence that the company has group wide targets on key sustainability topics for the most material parts of its value chain based on the SBTN Sectoral Materiality Tool could be found. The company has reported that as per their remuneration policy, a three-year CO₂ target that is compatible with the Group’s 2030 CO₂ targets is included in the performance objectives of the deferred compensation incentive for executive members of the Board and the members of the Executive Committee. However, no evidence of the company linking performance criteria in senior executives’ remuneration policies to targets and objectives which cover biodiversity or social issues could be found. The company does not disclose whether its highest governance body has expertise regarding nature-related topics. 

Stakeholder engagement
The company does not disclose an overview of the issues raised during its stakeholder engagement activities. The company does not disclose its process for engaging with stakeholder groups beyond its materiality assessment. 

Lobbying
While the company discloses some trade associations of which it is a member, this is not a complete list covering all geographies. The company does not disclose a clear and detailed framework for assessing alignment of its trade associations with nature-positive policies. The company does not report (potential) misalignment between the lobbying activities of its trade associations and nature-positive policies. 

Impact and dependencies assessment
The company discloses it has conducted site assessments which include biodiversity topics, in its owned operational sites. However, no evidence that the company has used a methodology which also assesses the impacts of its business model, could be found. The company does not disclose any assessment of its impacts on nature, including biodiversity, in its supply chain. The company does not disclose any assessment of its dependencies on nature within its own operations. The company does not disclose any assessment of dependencies on nature of its upstream business relationships. 

Key areas and species
The company does not disclose all the locations that are in or adjacent to areas important for biodiversity within its own operations. The company does not disclose the locations of its suppliers that are in or adjacent to areas important for biodiversity. The company discloses certain species that are found at Zlatna Panega plant and its quarries. However, no evidence that the company discloses species existing in or adjacent to all its locations could be found.   The company does not disclose species populations existing in or adjacent to the locations of its suppliers. The company does not disclose the status according to national and international conservation lists of species identified in its own locations. 

Ecosystem conversion and restoration
The company does not disclose a commitment to ensure zero conversion. The company does not disclose activities to achieve conversion-free supply chains. The company does not disclose time-bound targets to achieve conversion-free supply chains. The company does not disclose a commitment to minimise ecosystem conversion. The company does not disclose activities to minimise ecosystem conversion. The company is committed to restoring ecosystems. The company discloses details and outcomes of ecosystem restoration projects in areas affected by its own operations or by its suppliers. 

Resource exploitation and circularity
The company does not disclose its inputs, including its material footprint. The company does not report quantitatively on its group-wide circularity performance. The company does not disclose activities to improve soil health or agrobiodiversity in its production or sourcing practices. The company does not disclose a target to improve soil health in its production or sourcing practices. 

Water
The company has reported an increase in its total water withdrawal (million m3) from 41.3 in 2020 to 43. 2 in 2021. The company does not disclose a time-bound target to reduce water withdrawal across its own operations. The company does not report how much water is withdrawn for its own operations in water-stressed areas. The company does not engage with suppliers to reduce water withdrawal. The company has reported an increase in its total water discharge (million m3) from 30.2 in 2020 to 31.9 in 2021. The company does not disclose its processes for managing and monitoring discharge water quality. The company does not regularly report on water pollution. The company does not disclose targets to reduce water pollution. The company does not disclose a commitment to respect the right to water. The company does not disclose its processes for implementing preventive and corrective action plans for identified specific risks to the right to water and sanitation in its own operations. 

Solid and air pollution
No evidence that the company is reducing the production of hazardous waste was found. No evidence that the company reduces plastic use and waste in its own operations was found. The company does not report on the amount of plastic waste generated and proportions directed from or to disposal. The company reports regularly on air quality parameters of emissions of harmful air pollutants. The company has reported its target to sustain and further improve strong performance in cement production-related specific dust, NOx and SOx emissions by 2025. However, no evidence of a baseline year and the quantitative reductions it commits to by 2025 could be found in the public domain.  

GHG emissions
The company is reducing its scope 1 and 2 greenhouse gas emissions. The company has a time-bound target to reduce its scope 1 and 2 emissions. The company reports progress against its scope 1 and 2 emissions target. No evidence that the company’s scope 1 and 2 emissions target is aligned with a 1.5-degree trajectory was found. No evidence that the company reduces its scope 3 emissions was found. The company does not disclose a time-bound target to reduce its scope 3 emissions.  The company does not report progress against its scope 3 emissions target. No evidence that the company’s scope 3 emissions target is aligned with a 1.5-degree trajectory was found. 

Invasive species
No evidence was found that the company identifies the activities that could lead to the introduction of invasive species in its own operations. No evidence was found that the company identifies the activities that could lead to the introduction of invasive species in its value chain. 

Safe, clean, healthy and sustainable environment
The company does not disclose a commitment to respecting local communities’ right to a safe, clean, healthy and sustainable environment. No evidence that the company tracks its actual or potential negative impacts on the health of local communities was found. The company is not committed to zero tolerance for acts of violence, threats, intimidation or judicial harassment committed against land and environmental rights defenders. 

Indigenous Peoples’ and land rights
The company does not disclose a commitment to respect Indigenous Peoples’ rights. The company does not disclose its processes for identifying and recognising the rights of Indigenous Peoples when activities in its own operations may impact their rights, nor does it describe how it obtains Indigenous Peoples’ free, prior and informed consent. The company does not disclose a commitment to respect ownership and use of land and natural resources and related legitimate tenure rights, as set out in the relevant part(s) of the VGGTs or the IFC Performance Standards. No evidence was found that the company requires its business relationships to have a process to identify legitimate tenure rightsholders, paying particular attention to vulnerable or marginalised tenure rightsholders, and to negotiate with them to provide adequate compensation. 

The company states that human rights are a material issue for employees and suppliers and local communities and integral part of the materiality assessment process. However, the company does not disclose the process to identify which human rights are at risk of being impacted by its own operations, in specific locations or through specific activities, as part of a materiality assessment. No evidence that the company describes its process for assessing its human rights risks and discloses what it considers to be its salient human rights issues was found.  No evidence was found that the company has a global system in place to act on, prevent or mitigate its salient human rights issues.  No evidence that the company provides an example of the conclusions reached and actions taken or to be taken on at least one of its salient human rights issues as a result of assessment processes was found.  While the company discloses the categories of stakeholders it engages with generally on sustainability issues, it is not clear if these stakeholders are those whose human rights have been or may be affected by its activities. No evidence that the company provides examples of its engagement with stakeholders whose human rights have been or may be affected by its activities was found. 

The company has a publicly available policy statement which shows it is committed to respecting the health and safety of workers.  The company has a publicly available policy statement which shows it expects its suppliers to commit to respecting the health and safety of their workers. No evidence that the company discloses a time-bound target for paying all workers a living wage or that it has achieved paying all workers a living wage was found. No evidence that the company describes how it determines a living wage for the regions where it operates was found. While the company states that all workers must work under fair labor conditions and standards, in terms of wages, it has an opportunity to disclose how it works to support the payment of a living wage by its suppliers. No evidence that the company discloses the proportion of its total direct operations workforce covered by collective bargaining agreements was found. While the company states that it requires its suppliers to respect employees’ right to freedom of association and the right to collective bargaining, it has an opportunity to describe how it works to support the practices of its suppliers in relation to those. 

No evidence that the company has a publicly available global tax strategy was found. The company indicates that it conducts risk assessment and due diligence of third parties who perform services for or on behalf of TITAN Group, however, the company does not disclose the process to identify its bribery and corruption risks and impacts in specific locations or activities covering its own operations. The company has a procurement policy in which it prohibits bribery and corruption. Further, it states that an employee or business associate who commits bribery while on duty may be subject to civil and criminal liability, in accordance with applicable laws as well as to termination of her/his employment, however, the company does not clearly define ”business associates” No evidence that the company has a publicly available policy statement or policy setting out its lobbying and political engagement approach was found. No evidence that the company has a publicly available policy statement that specifies that it does not make political contributions was found.