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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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SUSTAINABILITY
STATEMENT
FOR THE FISCAL YEAR
ENDED DECEMBER 31, 2024
Limassol, March 27
th
, 2025

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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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AGENDA
1 GENERAL INFORMATION .............................................................................................................. 3
1.1 ESRS 2 GENERAL DISCLOSURES ........................................................................................................................ 3
2 ENVIRONMENTAL INFORMATION .............................................................................................. 23
2.1 ESRS E1 CLIMATE CHANGE................................................................................................................................ 23
2.2 ESRS E2 POLLUTION ........................................................................................................................................... 29
2.3 ESRS E5 RESOURCE USE AND CIRCULAR ECONOMY ................................................................................... 30
2.4 EU TAXONOMY ..................................................................................................................................................... 31
3 SOCIAL INFORMATION ................................................................................................................ 39
3.1 S1 OWN WORKFORCE ......................................................................................................................................... 39
3.2 S2 WORKERS IN THE VALUE CHAIN .................................................................................................................. 46
3.3 S4 CONSUMERS AND END-USERS .................................................................................................................... 48
4 GOVERNANCE INFORMATION .................................................................................................... 51
4.1 G1 BUSINESS CONDUCT ..................................................................................................................................... 51

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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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1 GENERAL INFORMATION
1.1 ESRS 2 GENERAL DISCLOSURES
1.1.1 BP-1 – GENERAL BASIS FOR PREPARATION OF SUSTAINABILITY STATEMENTS
The sustainability statement (further on: ‘sustainability statement’, ‘statement’) has been prepared in accordance with the
ESRS standards, introduced by Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing
Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards. This
statement makes also disclosures under the provisions of Regulation (EU) 2020/852 of the European Parliament and of
the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment as well as other
taxonomy-related regulations. Despite ASBIS’ shares being listed in Warsaw, Poland, in terms of sustainability reporting,
ASBIS is subject to Cyprus Law and the Company is not obliged to report under ESRS standards as the CSRD Directive
has not been implemented in Cyprus by the end of 2024. ASBIS has voluntarily applied ESRS standards yet has not
undergo verification by external auditors and has kept the sustainability statement as a separate document.
This sustainability statement has been prepared in a consolidated form, taking into account all companies controlled by
ASBIS and consolidated using the full method. The scope of consolidation of the sustainability statement is the same as
for the audited financial statements. All undertakings consolidated using the full method (controlled by the Group) are
subject to sustainability reporting. All consolidation exclusions applied in this report are consistent with the scope of
consolidation exclusions applied in the financial statements.
The sustainability statement includes information on the material impacts, risks and opportunities not only of ASBIS
business model but also in upstream and downstream of its identified value chain. The value chain model was the basis
for preparation of double materiality assessment based on which the disclosures in this statement have been prepared.
ASBIS has not used the option to omit a specific piece of information corresponding to intellectual property, know-how or
the results of innovation. ASBIS has also not used the exemption from disclosure of impending developments or matters
in the course of negotiation, as provided for in articles 19a(3) and 29a(3) of Directive 2013/34/EU.
1.1.2 BP-2 – DISCLOSURES IN RELATION TO SPECIFIC CIRCUMSTANCES
Time horizons
For the purpose of preparation of this sustainability statements ASBIS has applied the time horizons as indicated in ESRS:
(a) short-term time horizon: the period adopted by ASBIS as the reporting period in its financial statements i.e. one year,
(b) medium-term time horizon: from the end of the short-term reporting period defined in (a) up to 5 years; and
(c) long-term time horizon: more than 5 years.
Value chain estimations
The measures in the statement include selected upstream and downstream value chain data estimated using indirect
sources, including benchmarking analysis, spend-based data and other proxies mostly for the purpose of Scope 3 GHG
estimates. These do not offer the same level of accuracy as direct data, yet ASBIS will continue to work on these estimates
over the upcoming quarters to improve their accuracy.
Sources of estimation and outcome uncertainty
ASBIS has used reasonable assumptions and estimates, including scenario analysis while preparing sustainability-related
information in the environmental part of the disclosures as well as in the double materiality assessment. ASBIS disclosed
usage of indirect data selected data points with description of data sources. Data and assumptions used in preparing the
sustainability statement are consistent to the extent possible with the corresponding financial data and assumptions used
in ASBIS’ financial statements. The Company underlines that forward-looking information may be more uncertain than
financial and directly obtained data.
Changes in preparation or presentation of sustainability information
There were minor changes and adjustments conducted to 2023 taxonomy and GHG emissions calculations.
Reporting errors in prior periods

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ASBIS has not found material reporting errors in prior periods.
The materiality assessment showed the materiality of ESRS E1, E5, S1, G1, partially E2, S2 and S4, thus, these topics
are reported. Information recognised in ESRS E3, E4 and ESRS S3 standards has been identified as immaterial in the
double materiality assessment.
1.1.3 GOV-1 – THE ROLE OF THE ADMINISTRATIVE, MANAGEMENT AND SUPERVISORY BODIES
ASBIS is governed by a Board of Directors (BoD) which consists of both executive directors (EDs) and non-executive
directors (NEDs), all managed by the CEO (Chief Executive Officer). The aim of executive directors is to set the strategy
of the Company and to manage the Company by supervising managers, assuring financing is available and managing risk.
The role of non-executive directors is to supervise the way the executive directors perform their duties, to scrutinize the
performance of the Board of Directors and constructively challenge its decisions.
Board of Directors composition and diversity
As of December 31, 2024, the Board of Directors had 8 directors out of which:
• 5 were executive and 3 were non-executive,
• 5 were male (62.5%) and 3 female (37.5%),
• 6 were between 30 and 50 years old (75.0%) and 2 were older than 50 years (25.0%),
• 7 have Cypriot nationality (87.5%) while 1 Ukrainian (12.5%).
Within the 5 executive directors there were:
• 3 male (60.0%) and 2 female (40.0%),
• 3 between 30 and 50 years old (60.0%) and 2 older than 50 years (40.0%) and
• 4 of Cypriot nationality (80.0%) and 1 of Ukrainian (20.0%).
Within the 3 non-executive directors there were:
• 2 male (66.7%) and 1 female (33.3%),
• all 3 between 30 and 50 years old,
• all 3 of Cypriot nationality and
• all 3 independent.
There have been no changes in the composition of the Board of Directors until the date of publication of this statement.
There is no representative of employees and other workers on the Board of Directors.
The Board of Directors is responsible for exercising oversight of the process of managing material impacts, risks and
opportunities. Selected Board of Directors members were participating in the double materiality assessment while the
whole process and its results were approved by the Board of Directors. The key person responsible both for impacts, risks
and opportunities assessment and sustainability is Constantinos Tziamalis.
Experience of Board of Directors members relevant to the sectors, products, geographic locations and
sustainability of the undertaking
Name of the director
IT distribution
sector
Geographical
regions
Sustainability
Financials
Legal
Siarhei Kostevitch
Yes
Yes
Yes
Yes
Marios Christou
Yes
Yes
Yes
Yes
Yes
Constantinos Tziamalis
Yes
Yes
Yes
Yes
Yes
Julia Prihodko
Yes
Yes
Yes
Hanna Kaplan
Yes
Yes
Tasos Panteli
Yes
Maria Petridou
Yes
Yes
Yes
Constantinos Petrides
Yes
Yes
The biographical details of the members of our Board of Directors are set out below:

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Siarhei Kostevitch (Chair and CEO, executive director)
Born in 1964, holds a master’s degree in radio engineering design from the Radio Engineering University of Minsk (1987).
Between 1987 and 1992, Siarhei worked as a member of the Research Center at the Radio Engineering University in
Minsk, where he published a series of articles on microelectronics design in local and worldwide specialist magazines. In
1990, Siarhei established a design and manufacturing business in Minsk, Belarus, and within 15 years has built it into the
leading computer component distributor in Eastern Europe and the Former Soviet Union. Siarhei is the Chair and the CEO
of the Group.
Marios Christou (executive director)
Born in 1968, holds a B.A., dual major in Accounting and Information Systems and Economics, from Queens College of
the City University of New York (C.U.N.Y.) (1992), and an M.B.A. in International Finance from St. John's University, New
York (1994). Marios is also a Certified Public Accountant (CPA) and a member of the American Institute of Certified Public
Accountants (AICPA). Marios worked with Deloitte & Touche Limassol, Cyprus, for four years, as an audit manager. Marios
then worked as a Financial Controller at Photos Photiades Breweries Ltd (part of the Carlsberg Group of companies) for
three years. Marios joined the Company in August 2001 and is the Chief Financial Officer.
Constantinos Tziamalis (deputy CEO, executive director)
Born in 1975, holds a B.Sc. in Banking and Financial Services (1998) and a Masters (M.Sc.) in Finance (1999) from the
University of Leicester. Constantinos Tziamalis worked at the private banking department of BNP Paribas in Cyprus and
then joined a brokerage house, Proteas Asset Management Limited, for 3 years as Investor Accounts Manager.
Constantinos joined the Company in January 2002 as Financial Project Manager. He was promoted to the position as
Corporate Credit Controller in 2003 & Investor Relations in March 2006 and became Director of Risk and Investor Relations
as of 23 April 2007. In January 2010 Constantinos has been also appointed as head of the FX Risk Management team. In
February 2022, he was nominated to the newly created position of Deputy CEO.
Julia Prihodko (executive director)
Born in 1982, holds a Masters (M.Sc.) in Psychology. Julia Prihodko started her career in a Ukrainian recruiting agency as
a Recruiting Manager and worked for 9 years in insurance industry as Human Resources Manager and Head of Human
Resources Department. Julia joined the Company in May 2015 as Human Relation Manager of ASBIS Ukraine. She was
promoted to the position of Chief Human Relations Officer in February 2019. On the 7 May 2021, Julia Prihodko was
appointed to the Board of Directors as an Executive Director.
Hanna Kaplan (executive director)
Holds a bachelor’s degree in economics, and she is a Certified Accountant qualified in 2020. Hanna served as finance
manager and chief accountant in various companies before she moved to ASBIS back in 2002. Ever since, Hanna has
evolved into one of the key persons in the Finance department of ASBIS Group. Due to her extensive experience and
skills, Hanna was the leader of the project of automating the Group’s consolidation, being the key liaison with Finance and
IT departments. She also participated in the Group’s listing efforts back in 2007 and concluded with big success the online
reporting system based on our own proprietary software IT4profit. Hanna Kaplan has been working with ASBIS for more
than 20 years and she is one of the cornerstones of the Accounting and Financial reporting of the whole Group. She will
continue to lead all projects of finance/IT integration and the automation of the reporting systems of the Group.
Tasos Panteli (non-executive director, independent)
Joined the Group in 2019. Tasos started his professional career at Nicos Chr. Anastasiades & Partners (Advocates – Legal
Consultants), holding the position of Advocate in 2001. Since 2005, Tasos has been working at Andreas M. Sofocleous &
Co LLC (Advocates – Legal Consultants) as Advocate (Advocate - Partner since 2010). He received a Bachelor of Laws
(LLB) from the Queen Mary and Westfield College (1999), a Postgraduate Diploma in Legal Skills from the City University
London, Inns of Court School of Law (2000). In the same year, he completed the Bar Vocational Course at the City
University London, Inns of Court School of Law and was Called to the Bar. In 2001 he received a Master of Laws (LLM)
from King’s College London. In 2002 he was admitted to the Cyprus Bar Association. He is a member of the Board of
Directors of Cyprus Hydrocarbons Company (CHC) Ltd, a member of the Cyprus Bar Association and a member of the
Honourable Society of Lincoln’s Inn (Barrister at Law).
Maria Petridou (non-executive director, independent)
Joined the Group in 2021. She started her professional career at KPMG Metaxas, Loizides, Syrimis (Limassol, Cyprus),
holding the position of Audit Supervisor (1998-2002). In 2002, Mrs. Maria Petridou joined EFG EUROBANK SA (Athens,

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Greece) as an Assistant Manager in the Finance and Control Department. Between the years 2006 and 2007, she worked
for KOMMUNALKREDIT INTERNATIONAL BANK LTD (Limassol, Cyprus) as a Manager in the Accounting Department.
In 2008, she held the position of Finance Lead, in the SOX Compliance Office of MF GLOBAL LIMITED (London, UK).
Between the years 2011 and 2012 she worked for Versatile Apparel Ltd (London, UK), holding the position of Finance
Director. In 2013, she joined AMF Horwath DSP (Limassol, Cyprus) as the Head of the Fund Administration Services
department. Since 2016 she has been engaged in accounting and financial services projects as a consultant. Between the
years 2018 and 2021, she held the position of Chief Accountant at Agri Europe Cyprus Limited. Maria Petridou received a
Bachelor of Arts in accounting and financial management (1998) and was awarded an Upper Second-Class Honours
degree from the UNIVERSITY OF ESSEX (Colchester, England). She is a member of the Institute of Chartered
Accountants in England and Wales (ICAEW).
Constantinos Petrides (non-executive director, independent)
Started his professional career in 2000 at the Cypriot Banks Association and as a representative of the Association in the
European Banking Federation and the National Euro Changeover Committee. In April 2006, he was employed at the
European Commission in Brussels, where until September 2011 he worked as an economist in the Directorate-General
for Agriculture and the Directorate-General for Competition. While working for the European Commission, he was a
negotiator of trade liberalization agreements between the EU and third countries and dealt with issues of state aid in the
field of transport. Since March 2013 to May 2017, he was the Deputy Minister to the President of the Republic of Cyprus.
After that, he served as Minister of Interior (May 2017 - December 2019). From December 2019 to March 2023, he held
the office of Minister of Finance of the Republic of Cyprus. Constantinos Petrides studied economics at the University of
Nottingham and then obtained a master's degree in the economics of political change in Europe from the London School
of Economics and Political Sciences.
As a result, all the key aspects identified by Board of Directors in terms of sectors and key needed competences are
represented at Board of Directors level.
The day-to-day management of impacts, risks and opportunities is distributed among the business owners of each area.
As part of their day-to-day job responsibilities, managers monitor their areas and the immediate business environment,
and if there is a significant change in the situation, this is escalated to the appropriate director i.e. to the Board of Directors’
level. The policy in this regard is only partially formalized as due to ongoing changes in ASBIS’ operations the Company
is testing different approaches to including ESG elated areas in the process and, once best practice has been created,
these will be formalised in a written policy. The deputy-CEO, Constantinos Tziamalis, is responsible for the sustainability
of area in the Group.
Within the framework ASBIS’ Audit Committee functions as a body overseeing the financial reporting process in the Group.
The Audit Committee consists of the three non-executive and one executive director (the CFO, an attending member) and
is chaired by Maria Petridou. The Committee meets at least twice a year. It is responsible for ensuring that the Group’s
financial performance is properly monitored, controlled and reported. It also meets the auditors and reviews reports from
the auditors relating to accounts and internal control systems. The Audit Committee meets at least once a year with the
auditors.
1.1.4 GOV-2 – INFORMATION PROVIDED TO AND SUSTAINABILITY MATTERS ADDRESSED BY
UNDERTAKING’S ADMINISTRATIVE, MANAGEMENT AND SUPERVISORY BODIES
The Board of Directors including its two committees – the Audit and the Remuneration Committee, are informed about
material impacts, risks and opportunities. The executive directors are informed about key topics by managers as part of
their daily activities and assess their materiality as well as appropriate actions to be taken. Non-executive directors are
also informed about material impacts, risks and opportunities in frames of Board of Directors meetings and the committees
that they chair. The Board of Directors not only takes the due diligence to assess these material impacts, risks and
opportunities but also actions taken in those areas and policies to be and already implemented. The metrics and targets
set depend on the area of material impacts, risks and opportunities – these are different in terms of business conduct,
social and environmental topics. In case metrics and targets are set, these are monitored by Board of Directors.
Special attention is given by the Board of Directors to risk management. The process of identifying and assessing the risks
within the ASBIS Group is a multi-layer process. At the local level, this is done by the local management through their
extensive knowledge of the markets coupled with independent analysis of how each country is assessing the risks. Each
country is utilizing all possible tools (research, macroeconomic analyses, etc.) and identifies the areas of risks. The
environmental/climate measurements are currently available for each country of our operations and are easily accessible
for us to evaluate. At the group level, the risk identification is an ongoing daily process which is followed by the Corporate
risk management team situated in our HQ in Cyprus.

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The most important impacts, risks and opportunities discussed by Board of Directors are:
• assessment of business impacts: assessment of the Group’s various business impacts, i.e. market trends,
competitiveness, technological innovation, geographical presence and changes in consumer preferences,
• analysis of environmental, social and governance impacts: analysis of the social, environmental and governance
to understand what impacts may be relevant to ASBIS,
• operational risk management: identification, assessment and management of operational risk associated with
day-to-day operations of the company,
• strategic/long-term risk management: identification, assessment and management of risks that are associated
with the Group’s long-term strategy,
• ethical and legal risks: analysis of risks related to ethical and legal aspects in order to avoid consequences that
may negatively affect the company’s reputation,
• financial aspects of decisions: analysis of impacts of financial decisions on the company’s performance and its
financial stability.
1.1.5 GOV-3 – INTEGRATION OF SUSTAINABILITY-RELATED PERFORMANCE IN INCENTIVE
SCHEMES
The Remuneration Committee encompasses the three non-executive and an executive director (the CEO, an attending
member) and is chaired by Tasos Panteli. It sets and reviews the scale and structure of the executive directors’
remuneration packages, including share options and terms of their service contracts. The remuneration and the terms and
conditions of the non-executive directors are determined by the directors with due regard to the interests of the
shareholders and the performance of the Group. The Committee also makes recommendations to the Board concerning
the allocation of share options and/or treasury shares to directors, managers and employees.
According to Articles of Association, remuneration of the directors will be determined in general meetings on the
recommendation of the Remuneration Committee. Any director performing special or extraordinary services in the conduct
of the Company’s business or in discharge of his duties as director, or who travels or resides abroad in discharge of his
duties as director may be paid such extra remuneration as determined by the directors, upon recommendation by the
Remuneration Committee. Executive directors are also entitled to receive a bonus every quarter depending upon quarterly
results. The bonus consists of a certain amount or percentage which is agreed and described in each director’s service
agreements or contracts, as applicable, however, directors only receive such a bonus to the extent profit meets certain
pre-set budgetary figures.
In 2020 in line with EU requirements, ASBIS’ general meeting approved the remuneration policy for the Board of Directors.
The first statement on remuneration was presented to the AGM in 2021, while the one for 2024 will be presented to the
AGM in 2025. Remuneration of the directors is included in the Annual Report as well as in the Statement on Board of
Directors remuneration. Overall:
• there are both fixed and variable payments (the latter dependent on completion of specific tasks set at the
beginning of the quarter),
• there are recruitment incentives in the form of relocation bonuses (case-by-case basis),
• termination payments exist as per local regulation,
• there are no clawbacks,
• there are provident fund contributions from both the company and the employee.
Executive directors are also entitled to receive a bonus every quarter depending upon quarterly results. The bonus consists
of a certain amount or percentage which is agreed and described in each Director’s service agreements or contracts, as
applicable, however, Directors only receive such a bonus to the extent profit meets certain pre-set budgetary figures.
Executive members of the Board of Directors are entitled to a car, phone, and medical insurance. During 2024, there were
no significant changes in the Company’s remuneration policy. There were also no ESG-related targets in executive
directors’ compensation.
1.1.6 GOV 4 – STATEMENT ON DUE DILIGENCE
Core elements of due diligence
Sections in sustainability statement
a) Embedding due diligence in governance, strategy and business model
GOV, SBM, S1
b) Engaging with affected stakeholders in all key steps of the due diligence
SBM, S1, S2, S4, Taxonomy

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Core elements of due diligence
Sections in sustainability statement
c) Identifying and assessing adverse impacts
IRO-1, SBM-3
d) Taking actions to address those adverse impacts
E1, S1, S2, S4
e) Tracking the effectiveness of these efforts and communicating
E1, S1, S2, S4
1.1.7 GOV 5 – RISK MANAGEMENT AND INTERNAL CONTROLS OVER SUSTAINABILITY
REPORTING
The risk management process is a daily process within the ASBIS Group. Our major risks contain, among other described
in the annual report, credit risk, FX risk, transactional risk, political risk and environmental/climate risk. On top, material
risks identified within the double materiality assessment include, among others, risks related to own workforce and
management of relations with suppliers. Having identified the risks, the relevant team will undertake all efforts to manage
them. In case of credit risk and FX risk (financial risks) we undertake insurance and hedging. In case of transactional risk,
we follow all international standards and techniques which are widely provided by external experts. As far as the climate
risk management is concerned, this is done based on each country’s strategy towards the climate awareness programs
and the individual actions required by the Company.
During the recent years, climate-related risk and its management has become an integrated part of our risk management
processes and it entails all relevant check points that have been requested by authorities and/or the relevant environmental
ombudsman in each country. Now, at every Board of Directors meeting there is a discussion on environmental issues and
all directors are fully aware of what actions are needed to be undertaken by the Company. Constantinos Tziamalis, deputy
CEO, is among other, responsible for climate change and environmental protection.
In terms of internal controls, sustainability matters are overseen by a designated director, supported by a team responsible
for data collection, risk assessment, and reporting. Internal controls include structured data collection and alignment with
ESRS requirements to ensure reporting accuracy. Activities undertaken include regular legal consultations and internal
policy updates to ensure adherence to sustainability reporting standards as well as implementation of automated tracking
systems and cross-functional review processes.
1.1.8 SBM-1 – STRATEGY, BUSINESS MODEL AND VALUE CHAIN
Business model
ASBISc Enterprises Plc is a leading Value Add Distributor, developer and provider of ICT, IoT products, solutions, and
services to the markets of Europe, the Middle East, and Africa (EMEA) with local operations in Central and Eastern Europe,
the Baltic republics, the former Soviet Union, the Middle East and North Africa, combining a broad geographical reach with
a wide range of products distributed on a "one-stop-shop" basis. Our focus is on the following countries: Kazakhstan,
Ukraine, Slovakia, Poland, Czech Republic, Romania, Croatia, Slovenia, Bulgaria, Serbia, Hungary, Middle East countries
(i.e., United Arab Emirates, Qatar and other Gulf states), Latvia and South Africa.
The Group distributes IT components (to assemblers, system integrators, local brands and retail) as well as A-branded
finished products like desktop PCs, laptops, servers, and networking to SMB and retail. Our IT product portfolio
encompasses a wide range of IT components, blocks and peripherals, and mobile IT systems. We currently purchase most
of our products from leading international manufacturers, including Apple, Logitech, Intel, Advanced Micro Devices
("AMD"), Seagate, Western Digital, Samsung, Microsoft, Toshiba, Dell, Acer, Lenovo and Hitachi. In addition, a part of our
revenues is comprised of sales of IT and other CE products under our private labels: Prestigio, Prestigio Solutions, Canyon,
AENO, AROS and LORGAR.
ASBISc commenced business in 1990 in Belarus and in 1995 we incorporated our holding Company in Cyprus and moved
our headquarters to Limassol. The Company’s registered and principal administrative office is at 1, Iapetou Street, 4101,
Agios Athanasios, Limassol, Cyprus. Our Cypriot headquarters support, through two master distribution centres (located
in Prague and Dubai) and two supplementary in Tbilisi and Johannesburg, our network of 31 warehouses. This network
supplies products to the Group's in-country operations and directly to its customers in approximately 60 countries.
ASBIS’ shares are listed on the Warsaw Stock Exchange and are present in key indices: WIG140, WIG-ESG, mWIG40TR,
WIGdiv, mWIG40, WIG, CEEplus.

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Group’s structure
As at December 31, 2024 the Group’s structure looked the following:

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Group’s capitals
What we put into the Group
How we process capitals
What we give back
daily operations, including taking
decisions what to order and in what
quantities
_
amendments and upgrades
to product offering, discussions with
suppliers
_
hiring and retaining
of employees
_
creating financial statements,
discussions with investors and banks,
paying taxes and social charges
_
back-office maintenance
Financing capital
equity, generated cash as well as bank loans and factoring
arrangements
Manufacturing capital
the production capacities of our suppliers and partners, our
distribution centres & warehouses and inventory
Intellectual capital
the brands and IPs that we possess
Human capital
our employees working in subsidiaries in EMEA countries,
their know-how and engagement
Social capital
strong reputation that ASBIS possesses among its customers
and suppliers, our relations and impact on local societies
Natural capital
natural resources that are used to manufacture products that
we distribute
Financing capital
generation of cash flows that can be reinvested into the
Company or paid out as dividends
Manufacturing capital
supporting suppliers and the manufacturers they engage,
supporting private label production in China and our DCs
Intellectual capital
development of possessed brands, especially private labels
Human capital
development of employees, trainings, internal promotions,
new opportunities
Social capital
strengthening our relations with suppliers, customers and
local societies
Natural capital
recycling initiatives introduced
ASBIS business can also be looked at from the perspective of six capitals that the Group possesses and processes in day-to-day operations.

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Financial capital: The financial capital of ASBIS consists of equity, generated cash as well as bank loans and factoring
arrangements. These allow us to operate on a daily basis. ASBIS financial capital is supported by our history of flexibility
and adapting to changing external surroundings which has once again been proven by ASBIS developing new markets to
make up for the closed Russian operations. ASBIS followed all required sanctions on Russia as well as Belarus, while
continued to operate on the Ukrainian market which was the second largest. Financial capital affects all other capitals as
due to its generation we can remunerate our employees (human capital), develop our intellectual capital and support our
social capital.
Manufacturing capital: ASBIS manufacturing capital consists of production capacities of our suppliers and partners, our
distribution centres and warehouses due to which we can distribute goods sold to our customers as well as inventory on
hand. Our Cyprus HQs as well as regional offices add to our manufacturing capital. Our manufacturing capital supports
our financial capital as thanks to it we can conduct our operations. It also helps our human capital by allowing our
employees to work in proper conditions. As such it supports development of intellectual capital and social capital (by
strengthening relations with local communities).
Human capital: Our employees form the human capital that powers our organization. Thanks to their commitment we can
run our operations, develop our intellectual, social and financial capital. ASBIS’ future depends on employees’ know-how,
engagement, flexibility and ability to cope with everyday situations. We operate in some 60 countries and our employees
are located in over 30 countries, in which we hold subsidiaries. Countries we operate fall in different regions with different
cultures and religions. Only some 11% of our employees work for the parent company, with the balance working for
subsidiaries. In 2024, we employed on average 2,779 people, up 4% YoY.
Intellectual capital: Over the 30+ years of ASBIS’ operations we have developed a sizeable portion of intellectual capital.
The two most important elements are the IT4Profit platform and our private labels which support our financial and social
capital.
Social capital: ASBIS’ social capital consists of our strong reputation among our customers, suppliers, investors as well
as our relations and impacts on local societies. Our strong reputation is a consequence of doing what is right ethically and
legally, on all markets we operate. We are guided by the 10 Principles described in our Code of Conduct (key elements
are presented in G1-1 section).
Natural capital: In ASBIS’ value chain natural capital is transformed from natural resources used to produce IT appliances
by ASBIS suppliers to products that ASBIS distributes. In its operations ASBIS aims to minimize its impact on environment
and climate and takes climate risks and opportunities into its plans.
Value chain
ASBIS value chain starts with extraction of minerals needed for production of electronics sold e.g. aluminium, cobalt,
copper, gold, lithium, tin, tungsten, silicon, carbon as well as plastic and iron from which components are created. These
are sourced by OEMs (original equipment manufacturers), private labels producers and other producers manufacturing
electronics and hardware such as smartphones, CPUs, PCs, laptops, HDDs and peripherals.
While choosing its offer, ASBIS analyses market trends, evaluates potential demand and looks for profit opportunities.
Based on our analysis, we later on select products and product groups that will be distributed and sold. Product offering is
adjusted according to market changes and the profit it generates. Then the Company creates a strategy to develop certain
product groups and customer demands.
Placing an order depends on the supplier; it can be done via our supplier’s on-line system or by email. We operate a
system of centralized purchasing through our headquarters in Limassol, Cyprus, however we also possess a purchasing
office in China. Country managers communicate expected sales levels and targets, analyzed by product lines and
suppliers, to our product line managers who then identify purchasing requirements for the forthcoming three weeks and in
turn forward this information to the vice president of product marketing who verifies, and upon agreement, consolidates
the information. Information is then presented to management, holding weekly meetings to review and approve
requirements.
Shipping of electronics and hardware from OEMs, private labels producers and other producers to ASBIS takes place
mostly via marine transportation. Suppliers deliver goods to our two master distribution centers (Prague and Dubai) and
two regional distribution centers (Tbilisi and Johannesburg). We strive to keep our stock, including stock in transit, for our
main product lines at a level of four weeks of sales, and to cover four to five weeks of revenues for other product lines to
ensure adequate supply, while reducing the length of time over which we hold our inventory at our warehouses.
Having purchased the goods, we act as a non-exclusive distributor. We are responsible for promoting, marketing,
advertising, selling, and providing training and after-sales support for each supplier's products in the respective markets.
A monitoring mechanism is established by the suppliers to ensure that minimum sales targets are met, pursuant to which
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
12
we are responsible for providing our suppliers with various reports, including weekly inventory reports and monthly point
of sales reports. The aim of ASBIS is to be one of the top distributors for every supplier to get most of the supplier`s
support.
We order large volumes of products to benefit from economies of scale and resell these at competitive prices to our
customers. We have no reliance on any single customer. Our biggest customer was only responsible for some 4.2% of
total revenues in 2024 (6.6% in 2023). Our active customers (c. 20,000 in 2024, stable YoY) can place orders via our IT
platform which is called IT4Profit and by telephone call or email. It allows not only electronic trading with customers but
also data exchange between the parent company and its subsidiaries. In all regions we co-operate both with large
enterprises and mid-size companies. In all regions we are looking for well-established companies with proven products
and business models. Our clients are in vast majority corporates. These include a broad range of corporate clients: system
integrators, resellers (including value added resellers, SMB resellers), retail companies, PC assemblers, service centers
and telecom companies.
Once a customer files the order, we have to deliver it. We operate through 31 warehouses. Customer orders are mainly
served through the supply of local offices, and in the event that local inventory levels are insufficient, additional inventory
is drawn from one of the distribution centers. Each local office operates its own logistics function and is responsible for
direct shipments to its customers. Our headquarters monitor and assess the performance of each local logistics center by
using several key performance indicators, including transit time of incoming shipments, order fulfilment, (such as pick, pack
and ship time and the percentage of orders shipped to commitment by date and time), on-time delivery, transport, cost per
kilogram shipped and cycle count performance.
At the end of 2024 we ran 34 Apple stores in 7 FSU countries (33 stores in 2023) and 6 Bang & Olufsen stores with a total
of 4,499 m2 floorspace, providing us with a direct exposure to our customers.
ASBIS’ value chain ends with the end of life of products and goods distributed. These could be topped up or recycled (at
least partially) yet could also end up on landfill.
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ASBIS’ identified value chain:
UPSTREAM DOWNSTREAM ASBIS
Extraction of
minerals needed
for production of
electronics (e.g.
aluminium, cobalt,
copper, gold,
lithium, tin,
tungsten, silicon,
carbon as well as
plastic and iron)
and sourcing of
components.
Key locations:
Americas, Asia,
EMEA, Australia
Manufacturing
of electronics and
hardware e.g.
smartphones,
CPUs, PCs,
laptops, HDDs,
peripherals include
OEMs (original
equipment
manufacturers),
private labels
producers, other
producers.
Key locations:
production mostly
Asia, also EMEA and
US
Sale
of IT components
of OEMs and
private labels from
ASBIS distribution
centres,
warehouses and
retail stores
financed from own
equity and
financing
institutions.
Key locations:
EMEA
Distribution
from ASBIS to
vendors, business
customers and
stores via ships,
airplanes and
trucks.
Key locations:
EMEA
Shipping
of electronics and
hardware from
OEMs, private
labels producers,
other producers to
ASBIS mostly via
marine
transportation.
Key locations:
from Asia to EMEA
Purchasing
conducted on-line
or off-line via
vendors, business
customers and for
ASBIS’ retail
stores.
Usage and end of
life treatment of
products
distributed via
recycling,
refurbishment,
reuse or landfill.
Key locations:
EMEA
Key locations:
EMEA
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Strategy
Our business strategy remains the same over the years. ASBIS intends to grow its business and increase its profitability,
mainly by improving its operating efficiency in the distribution of IT components and by increasing sales of its private label
products. This is to be achieved by:
• increasing or retaining sales and market share in the CEE region, selected FSU countries and the Middle East
and Africa,
• enhancing product portfolio (smartphones, IT components, VAD) and improving gross profit margin,
• further optimizing our private label business,
• controlling our cost structure, enhancing operating efficiency and automated processes, including our online sales
channels,
• engaging in alternative investments and new technologies.
We will continue to implement the strategy as well as conduct any necessary tactical changes resulting from short- and
medium-term changes on the IT distribution market.
ASBIS focuses on supporting attainment of the United Nations Sustainable Development Goals for 2015-2030, among
others:
• SDG 5 Gender Equality: we have a diverse Board of Directors in terms of gender, experience and age as well as
diverse employees, representing different regions and cultures,
• SDG 8 Decent Work and Economic Growth: we have subsidiaries in 34 countries and operate in some 60
countries; we offer our employees fair wages and permanent employment contracts,
• SDG 9 Industry Innovation and Infrastructure: we introduce innovative solutions into our portfolio and acquire new
ideas; we help our customers in emerging markets upgrade their IT infrastructure to more environmentally sound
one,
• SDG 12 Responsible Consumption and Production: we engage in waste reduction initiatives, support responsible
purchases by our customer and expand the Breezy initiative for trading in used appliances,
• SDG 13 Climate Action: we broaden our eco-friendly product offering, we measure our carbon footprint, we
introduced a policy that all new corporate cars must be hybrid.
1.1.9 SBM-2 – INTERESTS AND VIEWS OF STAKEHOLDERS
Stakeholders’ analysis has been updated and approved by the Board of Directors for the purpose of Non-financial report
for 2023. These have been re-considered and their accuracy re-confirmed by the Board of Directors for the purposes of
sustainability statement for 2024. Stakeholders’ analysis was the first step of double-materiality assessment conducted in
line with the European Sustainability Reporting Standards.
Stakeholder mapping showed seven material stakeholder groups. Material stakeholder groups have been assessed based
on their relation to the Company, impact on the Company, Company’s impact on them as well as methods and frequency
of contact. As a result, the seven groups of stakeholders were identified: capital market participants (analysts and investors)
and financial institutions (banks, insurers, factoring companies), suppliers and service providers, customers, employees
and Board of Directors, governing and public institutions, local communities and media and public opinion. Details with
methods of engagement are presented in the table below.
Stakeholder group
Description
Method of engagement
Capital market
participants and
financial
institutions
A varied group of stakeholders. Capital market participants
include: analysts issuing recommendations for ASBIS,
institutional investors (mutual funds and pension funds, Polish
and international ones) and individual investors. Financial
institutions include insurers, banks as well as factoring
companies.
- preparation of financial and non-financial
reports as well as current reports,
- participation in one-on-one meetings,
group meetings, conference calls and
videoconferences with investors, analysts
and financing institutions,
- running the investor relations internet portal
Suppliers and
service providers
Suppliers are companies from which we source goods that we
resell later. We co-operate with suppliers who produce for us
our private label products as well as with suppliers from which
we obtain third party goods, e.g. OEM (original equipment
manufacturers). Scale of our suppliers differs. Service
providers include, among others, logistics operators that
transport the goods from our distribution centers to our
customers.
- maintaining long-term relations based on
trust, respect and understanding of needs,
- daily operational contact via emails and
telephones,
- face-to-face meetings when necessary
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Stakeholder group
Description
Method of engagement
Customers
We have both corporate and individual customers, vendors
and resellers, large retail networks and enterprises to which
we deliver our products. Individual customers are people who
ultimately use the products that we sell, both our private labels
as well as the third-party hardware and software. Also, people
coming directly into our Apple Premium Reseller and
Bang&Olufsen stores are also our customers.
- maintaining long-term relations based on
trust, respect and understanding of needs,
- daily operational contact via emails and
telephones with large vendors and large
business customers,
- face-to-face meetings when necessary,
with representatives of large vendors and
large business customers,
- contact with retail customers in stores
Employees and
Board of
Directors
Internal stakeholders. Employees are a diverse group, as
ASBIS’ operations are conducted in 4 regions of the EMEA
markets. On top, the Group’s employees have different
functions, ranging from administration and finance to logistics
and management, marketing and sales. Board of Directors is
the key body responsible for management and supervision of
ASBIS’ operations.
- Board of Directors, especially the executive
directors, is in daily contact with key
employees and is focused on providing the
best possible conditions to employees,
- open dialog run by managers, regular
performance monitoring, culture of
constructive feedback,
- development possibilities and market
remuneration supplemented by perks
Governing and
public institutions
These include not only institutions based in Cyprus, where the
headquarters are located, but in each of the countries present
and especially in Poland (in Warsaw), where ASBIS’ shares
are listed.
- payment of all due taxes and social
charges,
- providing all necessary reports and
explanations, transparent and outgoing
approach
Local
communities
Local communities for ASBIS are located in venues where
ASBIS has a material presence via its offices or/and
distribution centres and warehouses. We treat families of our
employees as our local community stakeholders.
- caring for families of our employees as our
local stakeholders,
- engaging in local societies lives, e.g. via
dedicated actions (different in each country),
- donating money to charities and engaging
in initiatives that are important to locals
Media and public
opinion
Local and international business and industry media in
countries, in which we operate. Collective opinion on ASBIS
and its presence in IT distribution sector.
- group and one-on-one meetings with press
and media representatives after quarterly
reports publications and on-demand,
- distribution of press releases,
- running webpage and social media
accounts
1.1.10 SBM-3 – MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH
STRATEGY AND BUSINESS MODEL
Within the double materiality assessment conducted in line with ESRS, the Company has identified, and the Board of
Directors has approved for the purposes of Non-financial Report for 2023 29 material topics. These, according to the Board
of Directors, remain up to date and have been used as the basis for preparation of this sustainability statement. The
material topics identified are strongly linked to ASBIS business model and its upstream and downstream. Below we present
the list of material identified topics based on impacts, risks and opportunities as well as their links to ASBIS value chain.
Material topic
Impact materiality
Financial materiality
Area of impact
1
Climate change adaptation (E1)
YES
YES
Upstream, business model,
downstream
2
Climate change mitigation (E1)
YES
YES
Upstream, business model,
downstream
3
Energy consumed (E1)
YES
NO
Business model
4
Air pollution (E2)
YES
NO
Upstream, downstream
5
Microplastics (E2)
YES
NO
Upstream, business model,
downstream
6
Circular economy (E5)
YES
YES
Business model, downstream
7
Working conditions (own workforce) (S1)
YES
YES
Business model
8
Security of employment (own workforce)
(S1)
YES
NO
Business model
9
Adequate wages (own workforce) (S1)
YES
YES
Business model
10
Social dialogue (own workforce) (S1)
YES
NO
Business model
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Material topic
Impact materiality
Financial materiality
Area of impact
11
Work life balance (own workforce) (S1)
YES
NO
Business model
12
Health and safety (own workforce) (S1)
YES
NO
Business model
13
Equal treatment and opportunities (own
workforce) (S1)
YES
YES
Business model
14
Gender equality and equal pay (own
workforce) (S1)
YES
YES
Business model
15
Workforce training and development
(own workforce) (S1)
YES
NO
Business model
16
Measures against violence and
harassment in the workplace (own
workforce) (S1)
YES
NO
Business model
17
Diversity (own workforce) (S1)
YES
YES
Business model
18
Working conditions (workforce in the
value chain) (S2)
NO
YES
Upstream
19
Child labour (workforce in the value
chain) (S2)
NO
YES
Upstream
20
Forced labour (workforce in the value
chain) (S2)
NO
YES
Upstream
21
Information related impacts for
consumers and end-users (S4)
YES
NO
Downstream
22
Consumers and end-users access to
(quality) information (S4)
YES
NO
Downstream
23
Health and safety of consumers and end-
users (S4)
NO
YES
Downstream
24
Business conduct (G1)
YES
NO
Business model
25
Corporate culture (G1)
YES
NO
Business model
26
Protection of whistle-blowers (G1)
YES
NO
Business model
27
Management of relationships with
suppliers, including payment practices
(G1)
YES
YES
Upstream, business model
28
Corruption and bribery (G1)
YES
NO
Upstream, business model
29
Data security (G1) (entity specific)
NO
YES
Business model
ASBIS’ Board of Directors takes these material topics into account while managing and overseeing the management of
ASBIS’ operations.
1.1.11 IRO-1 – DESCRIPTION OF THE PROCESS TO IDENTIFY AND ASSESS MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
Double materiality assessment was conducted on the Group level (taking all subsidiaries into account) in several steps
which involved: 1) internal stakeholders’ engagement to narrow down the list of material impacts and their type and severity,
2) financial materiality assessment and 3) external stakeholder engagement in the form of panel and survey. Board of
Directors has been engaged in all the steps and approved the first double materiality assessment. A list of material topics,
material based on impact, risks or opportunities, is presented in SBM-3. ASBIS plans to continue to upgrade its
methodology of double materiality assessment to assure all material topics are mapped and represented via appropriate
indicators.
Each impact, risk and opportunity has been judged in terms of ASBIS’ value chain, i.e. upstream, business model and
downstream. Also, the assessment has taken place for 3 dimensions i.e. environment, social and governance in line with
the list of potentially material topics as indicated in ESRS 1 AR16. Also, for each topic, assessment has been made for
short-, medium- and long-term in line with the timeframes indicated in ESRS.
In terms of impacts, for each AR16 topic it has been assessed whether the impact is an actual or potential one. In terms
of actual topics, the assessment went on to estimate whether the impact is a negative or positive one. Another step
encompassed aspects of severity of actual impacts from 0 to 5 (0 meaning least, 5 meaning most): 1) scale of impact, 2)
range of impact and 3) for negative impact irreversibility of the impact. For potential impacts, on top of severity (scale and
range) and probability of impact has been assessed. Impact assessment has been conducted internally among a group of
selected employees, from different geographies and departments. As a result, the number of potentially material topics
has been narrowed down.
Financial materiality assessment has been oriented on assessment of risks and opportunities. The list of topics assessed
from the point of view of financial materiality composed of several aspects: 1) topics indicated by internal stakeholders as
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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material in terms of impacts, 2) list of risks and opportunities identified by internal stakeholders, 3) list of material risks and
opportunities as discussed during the external stakeholder panel, 4) list of potentially material topics as identified by the
Board of Directors, and 5) list of financially material topics from SASB, under which the Company has reporting non-
financially over the past years. Similarly, as in terms of impacts, the assessment has been conducted in three time-
horizons: short-, medium- and long-term. For each topic both risk and opportunity level has been assessed by multiplying
the estimated severity and likelihood (each from 0 to 5) took place and assessed based on its estimated impact on ASBIS’
net income. The bottom-line has been chosen as: 1) it is part of the Company’s annual guidance, and 2) it is the basis for
dividend, regularly paid by ASBIS.
On top, the obtained list of potentially material impacts, risks and opportunities has been cross-checked by engaging
external stakeholders. These have taken place via: 1) external stakeholder hybrid panel and 2) external stakeholder survey.
Deputy-CEO has been presented and participated in all key elements of the double materiality assessment. As a result of
these, the Board of Directors has approved a list of 29 material topics based on which the Sustainability Statement has
been prepared.
1.1.12 IRO-2 – DISCLOSURE REQUIREMENTS IN ESRS COVERED BY THE UNDERTAKING’S
SUSTAINABILITY STATEMENT
Disclosure number
Disclosure name
Note number
ESRS 2 General disclosures
BP-1
General basis for preparation of sustainability statements
1.1.1
BP-2
Disclosures in relation to specific circumstances
1.1.2
GOV-1
Roles and responsibilities of the administrative, management
and supervisory bodies
1.1.3
GOV-2
Sustainability matters reported to and addressed by
administrative, management and supervisory bodies
1.1.4
GOV-3
Integration of sustainability performance in incentive schemes
1.1.5
GOV-4
Statement on due diligence
1.1.6
GOV-5
Risk management and internal controls over sustainability
reporting
1.1.7
SBM-1
Strategy, business model and value chain
1.1.8
SBM-2
Interests and views of stakeholders
1.1.9
SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
1.1.10
IRO-1
Description of processes to identify and assess material impacts,
material risks and material opportunities
1.1.11
IRO-2
Disclosure Requirements in ESRS covered by the undertaking's
sustainability statements
1.1.12
ESRS E1 Climate change
GOV-3
Integration of sustainability-related performance in incentive
schemes
2.1.1
E1-1
Transition plan for climate change mitigation
2.1.2
IRO-1
Description of the processes to identify and assess material
climate-related impacts, risks and opportunities
2.1.3
SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
2.1.4
E1-2
Policies related to climate change mitigation and adaptation
2.1.5
E1-3
Actions and resources in relation to climate change policies
2.1.6
E1-4
Policies related to climate change mitigation and adaptation
2.1.7
E1-5
Energy consumption and energy mix
2.1.8
E1-6
Gross Scopes 1, 2, 3 and Total GHG emissions
2.1.9
E1-7
GHG removals and GHG mitigation projects financed through
carbon credits
Immaterial
E1-8
Internal carbon pricing
Immaterial
E1-9
Anticipated financial effects from material physical and transition
risks and potential climate-related opportunities
Phasing out provision,
qualitative only, 2.1.10
ESRS E2 Pollution
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Disclosure number
Disclosure name
Note number
IRO-1
Description of the processes to identify and assess material
pollution-related impacts, risks and opportunities
2.2.1
E2-1
Policies related to pollution
2.2.2
E2-2
Actions and resources related to pollution
2.2.3
E2-3
Targets related to pollution
2.2.4
E2-4
Pollution of air, water and soil
2.2.5
E2-5
Substances of concern and substances of very high concern
Immaterial
E2-6
Anticipated financial effects from pollution-related risks and
opportunities
Phasing out provision,
2.2.6
ESRS E5 Resource use and circular economy
IRO-1
Description of the processes to identify and assess material
resource use and circular economy-related impacts, risks and
opportunities
2.3.1
E5-1
Policies related to resource use and circular economy
2.3.2
E5-2
Actions and resources related to resource use and circular
economy
2.3.3
E5-3
Targets related to resource use and circular economy
2.3.4
E5-4
Resource inflows
2.3.5
E5-5
Resource outflows
2.3.6
E5-6
Anticipated financial effects from resource use and circular
economy-related impacts, risks and opportunities
Phasing out provision,
2.3.7
ESRS S1 Own workforce
SBM-2
Interests and views of stakeholders
3.1.1
SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
3.1.2
S1-1
Policies related to own workforce
3.1.3
S1-2
Processes for engaging with own workforce and workers’
representatives about impacts
3.1.4
S1-3
Processes to remediate negative impacts and channels for own
workforce to raise concerns
3.1.5
S1-4
Taking action on material impacts on own workforce, and
approaches to managing material risks and pursuing material
opportunities related to own workforce, and effectiveness of
those actions
3.1.6
S1-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and
opportunities
3.1.7
S1-6
Characteristics of the undertaking’s employees
3.1.8
S1-7
Characteristics of non-employee workers in the undertaking’s
own workforce
3.1.9
S1-8
Collective bargaining and social dialogue
Not a material topic
S1-9
Diversity indicators
3.1.10
S1-10
Adequate wages
3.1.11
S1-11
Social protection
Phasing out provision used
S1-12
Persons with disabilities
Not a material topic
S1-13
Training and skills development indicators
3.1.12
S1-14
Health and safety indicators
3.1.13
S1-15
Work-life balance indicators
Phasing out provision used
S1-16
Compensation indicators (pay gap)
3.1.14
S1-17
Incidents and complaints and severe human rights impacts and
incidents
3.1.15
ESRS S2 Workers in the value chain
SBM-2
Interests and views of stakeholders
3.2.1
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Disclosure number
Disclosure name
Note number
SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
3.2.2
S2-1
Policies related to value chain workers
3.2.3
S2-2
Processes for engaging with value chain workers about impacts
3.2.4
S2-3
Processes to remediate negative impacts and channels for value
chain workers to raise concerns
3.2.5
S2-4
Taking action on material impacts on value chain workers, and
approaches to managing material risks and pursuing material
opportunities related to value chain workers, and effectiveness of
those action
3.2.6
S2-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and
opportunities
3.2.7
ESRS S4 Consumers and end-users
SBM-2
Interests and views of stakeholders
3.3.1
SBM-3
Material impacts, risks and opportunities and their interaction
with strategy and business model
3.3.2
S4-1
Policies related to consumers and end-users
3.3.3
S4-2
Processes for engaging with consumers and end-users about
impacts
3.3.4
S4-3
Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
3.3.5
S4-4
Taking action on material impacts on consumers and end-users,
and approaches to mitigating material risks and pursuing
material opportunities related to consumers and end-users, and
effectiveness of those actions
3.3.6
S4-5
Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and
opportunities
3.3.7
ESRS G1
GOV-1
Roles and responsibilities of the administrative, management
and supervisory bodies
4.1.1
IRO-1
Description of the processes to identify and assess material
impacts, risks and opportunities
4.1.2
G1-1
Corporate culture and business conduct policies
4.1.3
G1-2
Management of relationships with suppliers
4.1.4
G1-3
Prevention and detection of corruption and bribery
4.1.5
G1-4
Confirmed incidents of corruption or bribery
4.1.6
G1-5
Political influence and lobbying activities
Immaterial
G1-6
Payment practices
4.1.7
Entity-specific
Data security
4.1.8
E3, E4 and S3 topics proved to be immaterial as a whole thus these are not mentioned above.
Disclosure Requirement and related
datapoint
Reference to other EU legislation
Note number
ESRS 2 GOV-1 Board's gender
diversity paragraph 21 (d)
Indicator number 13 of Table #1 of Annex 1 (SFDR),
Commission Delegated Regulation (EU) 2020/1816,
Annex II
1.1.3
ESRS 2 GOV-1 Percentage of board
members who are independent
paragraph 21 (e)
Delegated Regulation (EU) 2020/1816, Annex II
1.1.3
ESRS 2 GOV-4 Statement on due
diligence paragraph 30
Indicator number 10 Table #3 of Annex 1 (SFDR)
1.1.6
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Disclosure Requirement and related
datapoint
Reference to other EU legislation
Note number
ESRS 2 SBM-1 Involvement in
activities related to fossil fuel activities
paragraph 40 (d) i
Indicators number 4 Table #1 of Annex 1 (SFDR),
Article 449a Regulation (EU) No 575/ 2013;
Commission Implementing Regulation (EU)
2022/2453 Table 1: Qualitative information on
Environmental risk and Table 2: Qualitative
information on Social risk, Delegated Regulation
(EU) 2020/1816, Annex II
No such activity,
immaterial
ESRS 2 SBM-1 Involvement in
activities related to chemical
production paragraph 40 (d) ii
Indicator number 9 Table #2 of Annex 1 (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
No such activity,
immaterial
ESRS 2 SBM-1 Involvement in
activities related to controversial
weapons paragraph 40 (d) iii
Indicator number 14 Table #1 of Annex 1 (SFDR),
Delegated Regulation (EU) 2020/1818, Article 12(1)
Delegated Regulation (EU) 2020/1816, Annex II
No such activity,
immaterial
ESRS 2 SBM-1 Involvement in
activities related to cultivation and
production of tobacco paragraph 40
(d) iv
Delegated Regulation (EU) 2020/1818, Article 12(1)
Delegated Regulation (EU) 2020/1816, Annex II
No such activity,
immaterial
ESRS E1-1 Transition plan to reach
climate neutrality by 2050 paragraph
14
Regulation (EU) 2021/1119, Article 2(1) (EU Climate
Law)
2.1.2
ESRS E1-1 Undertakings excluded
from Paris-aligned Benchmarks
paragraph 16 (g)
Article 449a Regulation (EU) No 575/2013;
Commission Implementing Regulation (EU)
2022/2453 Template 1: Banking book-Climate
Change transition risk: Credit quality of exposures by
sector, emissions and residual maturity, Delegated
Regulation (EU) 2020/1818, Article12.1 (d) to (g),
and Article 12.2
Immaterial
ESRS E1-4 GHG emission reduction
targets paragraph 34
Indicator number 4 Table #2 of Annex 1 (SFDR),
Article 449a Regulation (EU) No 575/2013;
Commission Implementing Regulation (EU)
2022/2453 Template 3: Banking book – Climate
change transition risk: alignment metrics, Delegated
Regulation (EU) 2020/1818, Article 6
2.1.7
ESRS E1-5 Energy consumption from
fossil sources disaggregated by
sources (only high climate impact
sectors) paragraph 38
Indicator number 5 Table #1 and Indicator n. 5 Table
#2 of Annex 1 (SFDR)
2.1.8
ESRS E1-5 Energy consumption and
mix paragraph 37
Indicator number 5 Table #1 of Annex 1 (SFDR)
2.1.8
ESRS E1-5 Energy intensity
associated with activities in high
climate impact sectors paragraphs 40
to 43
Indicator number 6 Table #1 of Annex 1 (SFDR)
2.1.8
ESRS E1-6 Gross Scope 1, 2, 3 and
Total GHG emissions paragraph 44
Indicators number 1 and 2 Table #1 of Annex 1
(SFDR), Article 449a; Regulation (EU) No 575/ 2013;
Commission Implementing Regulation (EU) 2022/
2453 Template 1: Banking book – Climate change
transition risk: Credit quality of exposures by sector,
emissions and residual maturity, Delegated
Regulation (EU) 2020/1818, Article 5(1), 6 and 8 (1)
2.1.9
ESRS E1-6 Gross GHG emissions
intensity paragraphs 53 to 55
Indicators number 3 Table #1 of Annex 1 (SFDR),
Article 449a Regulation (EU) No 575/ 2013;
Commission Implementing Regulation (EU) 2022/
2453 Template 3: Banking book – Climate change
transition risk: alignment metrics, Delegated
Regulation (EU) 2020/1818, Article 8(1)
2.1.9
ESRS E1-7 GHG removals and
carbon credits paragraph 56
Regulation (EU) 2021/1119, Article 2(1)
Immaterial
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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Disclosure Requirement and related
datapoint
Reference to other EU legislation
Note number
ESRS E1-9 Exposure of the
benchmark portfolio to climate-related
physical risks paragraph 66
Delegated Regulation (EU) 2020/1818, Annex II
Delegated Regulation (EU) 2020/1816, Annex II
Phasing out,
qualitative disclosure
only, 2.1.10
ESRS E1-9 Disaggregation of
monetary amounts by acute and
chronic physical risk paragraph 66 (a)
ESRS E1-9 Location of significant
assets at material physical risk
paragraph 66 (c).
Article 449a Regulation (EU) No 575/ 2013;
Commission Implementing Regulation (EU) 2022/
2453 paragraphs 46 and 47; Template 5: Banking
book - Climate change physical risk: Exposures
subject to physical risk.
Phasing out,
qualitative disclosure
only, 2.1.10
ESRS E1-9 Breakdown of the carrying
value of its real estate assets by
energy-efficiency classes paragraph
67 (c).
Article 449a Regulation (EU) No 575/ 2013;
Commission Implementing Regulation (EU) 2022/
2453 paragraph 34; Template 2:Banking book -
Climate change transition risk: Loans collateralised
by immovable property - Energy efficiency of the
collateral
Phasing out,
qualitative disclosure
only, 2.1.10
ESRS E1-9 Degree of exposure of the
portfolio to climate- related
opportunities paragraph 69
Delegated Regulation (EU) 2020/1818, Annex II
Phasing out,
qualitative disclosure
only, 2.1.10
ESRS E2-4 Amount of each pollutant
listed in Annex II of the E- PRTR
Regulation (European Pollutant
Release and Transfer Register)
emitted to air, water and soil,
paragraph 28
Indicator number 8 Table #1 of Annex 1 Indicator
number 2 Table #2 of Annex 1 Indicator number 1
Table #2 of Annex 1 Indicator number 3 Table #2 of
Annex 1 (SFDR)
2.2.5
ESRS E3-1 Water and marine
resources paragraph 9
Indicator number 7 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS E3-1 Dedicated policy
paragraph 13
Indicator number 8 Table 2 of Annex 1 (SFDR)
Immaterial
ESRS E3-1 Sustainable oceans and
seas paragraph 14
Indicator number 12 Table #2 of Annex 1
Immaterial
ESRS E3-4 Total water recycled and
reused paragraph 28 (c)
Indicator number 6.2 Table #2 of Annex 1
Immaterial
ESRS E3-4 Total water consumption
in m 3 per net revenue on own
operations paragraph 29
Indicator number 6.1 Table #2 of Annex 1
Immaterial
ESRS 2- SBM 3 - E4 paragraph 16 (a)
Indicator number 7 Table #1 of Annex 1 (SFDR)
Immaterial
ESRS 2- SBM 3 - E4 paragraph 16 (b)
Indicator number 10 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS 2- SBM 3 - E4 paragraph 16 (c)
Indicator number 14 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS E4-2 Sustainable land /
agriculture practices or policies
paragraph 24 (b)
Indicator number 11 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS E4-2 Sustainable oceans / seas
practices or policies paragraph 24 (c)
Indicator number 12 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS E4-2 Policies to address
deforestation paragraph 24 (d)
Indicator number 15 Table #2 of Annex 1 (SFDR)
Immaterial
ESRS E5-5 Non-recycled waste
paragraph 37 (d)
Indicator number 13 Table #2 of Annex 1 (SFDR)
2.3.6
ESRS E5-5 Hazardous waste and
radioactive waste paragraph 39
Indicator number 9 Table #1 of Annex 1 (SFDR)
2.3.6
ESRS 2- SBM3 - S1 Risk of incidents
of forced labour paragraph 14 (f)
Indicator number 13 Table #3 of Annex I (SFDR)
3.1.2
ESRS 2- SBM3 - S1 Risk of incidents
of child labour paragraph 14 (g)
Indicator number 12 Table #3 of Annex I (SFDR)
3.1.2
ESRS S1-1 Human rights policy
commitments paragraph 20
Indicator number 9 Table #3 and Indicator number
11 Table #1 of Annex I
3.1.3
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Disclosure Requirement and related
datapoint
Reference to other EU legislation
Note number
ESRS S1-1 Due diligence policies on
issues addressed by the fundamental
International Labor Organisation
Conventions 1 to 8, paragraph 21
Delegated Regulation (EU) 2020/1816, Annex II
3.1.3
ESRS S1-1 Processes and measures
for preventing trafficking in human
beings paragraph 22
Indicator number 11 Table #3 of Annex I (SFDR)
Immaterial
ESRS S1-1 Workplace accident
prevention policy or management
system paragraph 23
Indicator number 1 Table #3 of Annex I (SFDR)
3.1.3
ESRS S1-3 Grievance/complaints
handling mechanisms paragraph 32
(c)
Indicator number 5 Table #3 of Annex I (SFDR)
3.1.5
ESRS S1-14 Number of fatalities and
number and rate of work-related
accidents paragraph 88 (b) and (c)
Indicator number 2 Table #3 of Annex I (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
3.1.13
ESRS S1-14 Number of days lost to
injuries, accidents, fatalities or illness
paragraph 88 (e)
Indicator number 3 Table #3 of Annex I (SFDR)
3.1.13
ESRS S1-16 Unadjusted gender pay
gap paragraph 97 (a)
Indicator number 12 Table #1 of Annex I (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
3.1.14
ESRS S1-16 Excessive CEO pay ratio
paragraph 97 (b)
Indicator number 8 Table #3 of Annex I (SFDR)
Not included
ESRS S1-17 Incidents of
discrimination paragraph 103 (a)
Indicator number 7 Table #3 of Annex I (SFDR)
3.1.15
ESRS S1-17 Non-respect of UNGPs
on Business and Human Rights and
OECD Guidelines paragraph 104 (a)
Indicator number 10 Table #1 and Indicator n. 14
Table #3 of Annex I (SFDR), Delegated Regulation
(EU) 2020/1816, Annex II Delegated Regulation
(EU) 2020/1818 Art 12 (1)
3.1.15
ESRS 2- SBM3 – S2 Significant risk of
child labour or forced labour in the
value chain paragraph 11 (b)
Indicators number 12 and n. 13 Table #3 of Annex I
(SFDR)
3.2.1
ESRS S2-1 Human rights policy
commitments paragraph 17
Indicator number 9 Table #3 and Indicator n. 11
Table #1 of Annex 1 (SFDR)
3.2.3
ESRS S2-1 Policies related to value
chain workers paragraph 18
Indicator number 11 and n. 4 Table #3 of Annex 1
(SFDR)
3.2.3
ESRS S2-1 Non-respect of UNGPs on
Business and Human Rights principles
and OECD guidelines paragraph 19
Indicator number 10 Table #1 of Annex 1 (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1)
3.2.3
ESRS S2-1 Due diligence policies on
issues addressed by the fundamental
International Labor Organisation
Conventions 1 to 8, paragraph 19
Delegated Regulation (EU) 2020/1816, Annex II
3.2.3
ESRS S2-4 Human rights issues and
incidents connected to its upstream
and downstream value chain
paragraph 36
Indicator number 14 Table #3 of Annex 1 (SFDR)
3.2.6
ESRS S3-1 Human rights policy
commitments paragraph 16
Indicator number 9 Table #3 of Annex 1 and
Indicator number 11 Table #1 of Annex 1
Immaterial
ESRS S3-1 non- respect of UNGPs on
Business and Human Rights, ILO
principles or OECD guidelines
paragraph 17
Indicator number 10 Table #1 Annex 1 (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1)
Immaterial
ESRS S3-4 Human rights issues and
incidents paragraph 36
Indicator number 14 Table #3 of Annex 1 (SFDR)
Immaterial
ESRS S4-1 Policies related to
consumers and end-users paragraph
16
Indicator number 9 Table #3 and Indicator number
11 Table #1 of Annex 1 (SFDR)
3.3.3
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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Disclosure Requirement and related
datapoint
Reference to other EU legislation
Note number
ESRS S4-1 Non-respect of UNGPs on
Business and Human Rights and
OECD guidelines paragraph 17
Indicator number 10 Table #1 of Annex 1 (SFDR),
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1)
3.3.3
ESRS S4-4 Human rights issues and
incidents paragraph 35
Indicator number 14 Table #3 of Annex 1 (SFDR)
3.3.6
ESRS G1-1 United Nations
Convention against Corruption
paragraph 10 (b)
Indicator number 15 Table #3 of Annex 1 (SFDR)
4.1.3
ESRS G1-1 Protection of whistle-
blowers paragraph 10 (d)
Indicator number 6 Table #3 of Annex 1 (SFDR)
4.1.3
ESRS G1-4 Fines for violation of anti-
corruption and anti-bribery laws
paragraph 24 (a)
Indicator number 17 Table #3 of Annex 1 (SFDR)
4.1.6
ESRS G1-4 Standards of anti-
corruption and anti- bribery paragraph
24 (b)
Indicator number 16 Table #3 of Annex 1 (SFDR)
4.1.6
2 ENVIRONMENTAL INFORMATION
2.1 ESRS E1 CLIMATE CHANGE
2.1.1 GOV-3 INTEGRATION OF SUSTAINABILITY-RELATED PERFORMANCE IN INCENTIVE
SCHEMES
There are no climate-related targets within the executive directors’ compensation.
2.1.2 E1-1 TRANSITION PLAN FOR CLIMATE CHANGE MITIGATION
ASBIS does not have a transition plan to a sustainable economy.
2.1.3 IRO-1 DESCRIPTION OF THE PROCESS TO IDENTIFY AND ASSESS MATERIAL CLIMATE-
RELATED IMPACTS, RISKS AND OPPORTUNITIES
The processes have been described in the SBM-1 part of this sustainability statement.
2.1.4 SBM-3 MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH
STRATEGY AND BUSINESS MODEL
Climate risks are identified and managed at the level of Board of Directors. Looking at ASBIS from the double-materiality
perspective, we see both the ways in which ASBIS affects the environment and ways in which environment affects ASBIS.
Within the double materiality assessment both material impacts as well as risks and opportunities in terms of climate have
been identified. Within impacts, material ones were marked to be impact on suppliers and offer of goods distributed, amount
of eco-friendly products and goods in the offer as well as mode of transportation chosen for the goods.
The double materiality assessment recognised both the transition and physical risks. In terms of transition risks that arise
from the transition to a low-carbon and climate-resilient economy, we may face the following risks: policy and legal risks
(there may be laws or policies put in place that may require a more environmentally cautious approach to raw materials
and land use), technology risks (changes in technology used to produce IT equipment) – these both may lead to growing
prices in terms of IT equipment and solutions. We may also face market risk with consumers switching to more energy-
efficient appliances or making more savvy purchases to limit their own impact on the environment as well as reputational
risk. We will monitor these trends and introduce the latest hardware for our customers. We may also face reputational risks
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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with difficulties in attracting customers, business partners and employees if we do not take strong enough actions against
climate changes.
In terms of physical risks resulting from climate changes, we may face both acute and chronic risks. Acute physical risks
may arise from weather-related events in the form of floods, fires or droughts that may damage factories in certain regions,
cause factories to limit or temporarily stop their production or disrupt our supply chain in other ways. These may result in
temporary limitations in our product offering or rising prices of hardware and components. Chronic physical risks - i.e. risks
that may result from long-term changes in climate, may also affect ASBIS. Growing temperatures worldwide may cause a
need for more temperature-resilient hardware and appliances and may also result in more hardware malfunctions that may
increase warranty claims. We believe that technology and market risks are those transition risks that are going to be the
most important to ASBIS business model over upcoming years. We believe the chronic risks may prove more material
than the acute climate risks.
Identified within double materiality assessment climate opportunities included reductions in GHG emissions by designing
energy-efficient products, using sustainable materials, partnering with sustainable suppliers, using recycled packaging
materials, and new eco-friendly products and solutions. ASBIS could be selling new products and solutions to its
customers. These products could be more environmentally friendly, less energy consuming and use up fewer resources.
On top, ASBIS could reduce greenhouse gases emissions by optimizing transportation routes and saving energy on own
operations.
We look at both climate risk and opportunities in short, medium and long-term with the time horizons now aligned with
those in ESRS.
Short-term
Climate risks
We believe that in the short-term impact of both transition and physical risks may be
rather limited. On the transition risk side, we may see demand moving more towards
eco-products, using less electricity. We also may feel pressure to conduct more
actions towards sustainable development in order to retain our employees and
access new talent. There is potential for acute physical climate risk to affect some of
production sites from we source products. These disturbances should however be
short in their nature.
Climate opportunities
We believe we should be faced with climate opportunities. We have strong relations
with key producers. Thus, we should be able to obtain all latest hardware and
appliances offering. Also, our position could be strengthened by a broad portfolio of
private labels.
Medium-term
Climate risks
We believe that in the medium-term, the transition risks may become more visible.
There may be policy and legal risks in the form of laws or policies put in place that
may require more environmentally cautious approach to raw materials and land use
which could result in changes in product offering, e.g. due to suspension of some
products manufacturing. Technology risks are likely to be stronger than in short-term
– changes in technology used to produce IT equipment may be expensive to
incorporate, as a result, some portion of the Company’s suppliers may not be able
to afford these, which may result in growing prices of IT equipment, which our
customers may not be able to afford, Also, we may face not only acute climate risks,
but also start to experience chronic physical risks, with either often floods or/and fires
in places from which production is sourced, disturbing the production sites to a
stronger extent or requiring changes in sourcing countries.
Climate opportunities
On top of product-oriented climate opportunities, we should also experience climate-
opportunities coming from more renewables in energy mixed, efficiency measures
and waste reductions measures, which could be undertaken
Long-term
Climate risks
We believe that in the long-term, chronic physical risks may be stronger than
transition risks. Depending on global scale of GHG reductions, physical risks may be
so strong in selected countries that production will need to be transferred. Also, rising
temperatures and potentially some electricity shortages may lead to electronic
equipment not working properly, increasing warranty costs and decreasing
consumer satisfaction.
Climate opportunities
We believe that in the long-term climate opportunities may be the smallest. Much will
depend on the scale of GHG reductions and global climate conditions.
2.1.5 E1-2 POLICIES RELATED TO CLIMATE CHANGE MITIGATION AND ADAPTATION
ASBIS does not have any formal policies related to climate change mitigation and adaptation apart from:
• Corporate Car Policy indicating that all new cars must be hybrid ones,
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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• Travel Policy which defines “DOs” and “DON’Ts” for employees who travel for business trips and conferences.
2.1.6 E1-3 ACTIONS AND RESOURCES IN RELATION TO CLIMATE CHANGE POLICIES
ASBIS conducts the following actions in order to contribute to climate change adaptation and mitigation:
• minimising the usage of paper by applying electronic invoices as much as possible,
• limiting the usage of corporate vehicles and car fleet, available only to senior executives with limits put on the
value of car, with employees paying for fuel,
• reducing the usage of diesel/ petrol cars and move towards hybrids (all new cars must be hybrid),
• using cartons (small boxes) received from vendors for our courier deliveries, minimizing the quantity of additional
packaging and looking for ways to minimize empty space in pallets,
• developing green packaging for our own brands. All packages used at DC are made from recycled materials,
while plastic blisters and hooks have been replaced with paper trays and hooks,
• reusing the cartons that come with the products purchased by our vendors, which results in much lower carton
usage,
• hosting battery recycling points in our offices where employees can bring used up batteries to be recycled and
conducting standard recycling of waste in offices,
• hiring teams of professionals who dismantle products to be discarded (mostly PC tablets and smartphones) by
separating elements of the products in categories depending on their manufacturing origin and each material is
processed by the appropriate specialized company,
• using technology to save time on traveling to different countries and lower our environmental and climate impact,
• obtaining ISO 14001 (Environmental Management System).
2.1.7 E1-4 TARGETS RELATED TO CLIMATE CHANGE MITIGATION AND ADAPTATION
ASBIS does not have targets related to climate change mitigation and adaptation.
2.1.8 E1-5 ENERGY CONSUMPTION AND MIX
ASBIS business model is best described by G section of the NACE classification which indicates that ASBIS is considered
a “high climate impact sector”. As a result, the Company presents the extended table regarding energy consumption based
on Scope 1 and Scope 2 activities.
Energy consumption and mix
2024
2023
(1) Fuel consumption from coal and coal products (MWh)
0
0
(2) Fuel consumption from crude oil and petroleum products (MWh)
2,268
2,183
(3) Fuel consumption from natural gas (MWh)
0
0
(4) Fuel consumption from other fossil fuel (MWh)
0
0
(5) Consumption of purchased or acquired electricity, heat, steam, and
cooling from fossil sources (MWh)
2,737
3,163
(6) Total fossil energy consumption (MWh) (calculated as the sum of lines 1
to 5)
5,005
5,346
Share of fossil sources in total energy consumption (%)
78%
94%
(7) Consumption from nuclear sources (MWh)
0
0
Share of consumption from nuclear sources in total energy consumption (%)
0%
0%
(8) Fuel consumption for renewable sources, including biomass (also
comprising industrial and municipal waste of biologic origin, biogas,
renewable hydrogen, etc.) (MWh)
0
0
(9) Consumption of purchased or acquired electricity, heat, steam, and
cooling from renewable sources (MWh)
1,231
334
(10) The consumption of self-generated non-fuel renewable energy (MWh)
148
0
(11) Total renewable energy consumption (MWh) (calculated as the sum of
lines 8 to 10)
1,379
344
Share of renewable sources in total energy consumption (%)
22%
6%
Total energy consumption (MWh) (calculated as the sum of lines 6, 7 and
11)
6,384
5,690
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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The energy intensity (total energy consumption per net revenue) associated with activities in high climate impact sectors
(all ASBIS activities) came in at 2.12 MWh per US$1m revenue in 2024.
2.1.9 E1-6 GROSS SCOPES 1, 2, 3 AND TOTAL GHG EMISSIONS
ASBIS has been conducting GHG emissions calculations since 2019, yet these have been sizeably expanded its GHG
calculation methodology for 2024 sustainability statement. When possible, the base year has been added (e.g. providing
2023 data which had not been presented in 2023 sustainability report). Calculations have been conducted for all
greenhouse gases and are provided in CO2e tonnes - when needed GWP indicators have been applied.
Calculations have been conducted in line with the internationally recognised Greenhouse Gas Protocol (further „GHG
Protocol”) as described in: 1) The GHG Protocol A Corporate Accounting and Reporting Standard; 2) GHG Protocol Scope
2 Guidance; and 3) Corporate Value Chain (Scope 3) Accounting and Reporting Standard.
Organisation boundaries
Companies forming ASBIS capital group have been divided into: 1) full-method consolidated companies over which ASBIS
has operating control – 100% of their emissions have been taken into account in calculations, even though in selected
cases ASBIS owns less than 100%, their emissions are shown in Scope 1 and 2, 2) equity share approach – companies
in which ASBIS does not have control are shown in Scope 3, category 15 (investments), and 3) companies in which a
lower than 20% stake is owned by ASBIS are not taken into account due to their immateriality.
Operational boundaries
Operational boundaries have been set based on operational and financial control. Following a detailed analysis of type of
control, ability to direct the use and form of leases, the Company decided, that whenever possible it will apply control
assumptions similarly to those in the financial statements. Details for each Scope and category are presented below.
Scope 1: Scope 1 includes only emissions from fuel consumed in corporate cars. There are no stationary, processing or
fugitive emissions. For 2023 ASBIS used conversion factors from GHG Protocol while for 2024 UK Government indicators
have been applied to kilometres driven by different types of cars (Passenger cars sheet).
Scope 2: After the assessment of operating boundaries, it has been decided that electricity used in offices, warehouses,
DCs and stores falls into this category. For the location-method calculations, electricity usage per country was multiplied
by electricity intensity factors for the countries in which emission sources are located or nearby countries if appropriate
emissions factors have not been found at www.eea.europa.eu. For the market-method – which was first time calculated
for 2024 – electricity consumption has been split by suppliers and where possible their electricity intensity factors have
been applied.
Scope 3 category 1: Inventory purchases and cash SG&A costs for 2024 have been recalculated using spend-based
publicly available conversion factors from Climatiq database.
Scope 3 category 2: 2024 purchases have been split into category groups and recalculated in GHG emissions using
appropriate and publicly available conversion factors from Climatiq database.
Scope 3 category 3: Well-to-tank emissions have been calculated for the first time – for 2024 and 2023 – for fuel
consumed by corporate cars and electricity consumed in premises under operating control. 2024 and 2023 UK Government
indicators from the WTT sheets have been applied.
Scope 3 category 4: For upstream transportation and distribution ASBIS used its estimates for tonne.km travelled by
various modes of transportation (road, sea, air and rail) from suppliers to DCs and from DCs to warehouses. UK
Government indicators from (Freighting goods sheet) have been used for 2024 and 2023 calculations.
Scope 3 category 5: Due to a sizeable part of subsidiaries outside the EU where detail waste identification and
management systems are present, ASBIS has not been able to gather verified data for calculations for 2024 and 2023.
Scope 3 category 6: Business travel emissions have been estimated based on kilometres travelled by various means of
transportation, i.e. rail, bus, car and air, with the latter taking the class of the flight and the short/long haul split. For 2023
calculation GHG Protocol intensity factors were taken into account. For 2024 conversion factors from UK Government
databases (Business travel sheets) were taken into account. Additionally, for 2024 emissions from hotel stays were added.
Scope 3 category 7: Employee commuting data have been gathered based on a detailed survey of kilometres travelled
including mode of transportation, type of car (large, medium, small) and fuel type. There have been only minor adjustments
in 2023 calculations which were based on a mix of GHG Protocol and UK Government conversion factors. For 2024 all
estimates have been conducted with the use of UK Government conversion factors (Passenger vehicle and Business
travel land sheets).
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
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Scope 3 category 8: There are no calculations presented as leased assets have been shown in Scope 2.
Scope 3 category 9: For downstream transportation and distribution ASBIS used its estimates for tonne.km travelled by
various modes of transportation (road, sea, air and rail) from warehouses to customers. UK Government indicators
(Freighting goods sheets) have been used for 2024 and 2023 calculations.
Scope 3 category 10: ASBIS only sells finished goods thus there are no emissions from processing of sold products.
Scope 3 category 11: Basing on its IT systems, ASBIS obtained the weight of goods sold in the year. This has been
converted into greenhouse gas emission by using “data from UK Government files (Material use sheet).
Scope 3 category 12: Due to lack of verified data for this category, estimates have not been conducted.
Scope 3 category 13: There are no calculations presented as ASBIS has no downstream leased assets.
Scope 3 category 14: There are no calculations presented as ASBIS has no franchises.
Scope 3 category 15: In investments proportionate share of Scope 1 and Scope 2 emissions of equity-consolidated
associated was shown. These have been converted into CO2e using location-method (average emission factors for
countries where the HQs of these companies are located).
Scope and category
Base year
2024
2023
YoY growth
Scope 1 CO2e (tonnes)
Scope 1 emissions
2019
584
685
-15%
Scope 1 greenhouse gases from regulated
trading
-
0
0
-
Percentage of Scope 1 greenhouse gas
emissions from regulated emissions trading
systems
-
0%
0%
-
Scope 2 CO2e (tonnes)
Scope 2 gross emissions (location-method)
2019
1,954
1,350
45%
Scope 2 gross emissions (market-method)
2024
1,381
-
-
Scope 3 CO2e (tonnes)
Total gross Scope 3 emissions
1. Purchased goods and services
2024
185,094
-
-
2. Capital goods
2024
5,645
-
-
3. Fuel and energy-related activities not included
in Scope 1 and Scope 2
2023
370
333
11%
4. Upstream transportation and distribution
2023
3,750
3,999
-6%
5. Waste generated in operations
-
-
-
No data available
6. Business travel
2019
1,827
548
233%
7. Employee commuting
2019
1,979
2,108
-6%
8. Upstream leased assets
-
-
-
Included in Scope 2
9. Downstream transportation and distribution
2023
35
208
-83%
10. Processing of sold products
-
0
0
Not present
11. Use of sold products
2024
92,309
-
-
12. End of life treatment of sold products
-
-
-
No data available
13. Downstream leased assets
-
0
0
Not present
14. Franchises
-
0
0
Not present
15. Investments
2024
3
-
-
Total GHG emissions (CO2e tonnes)
Total GHG emissions (location-based)
293,550
9,230
Incomparable
Total GHG emissions (market-based)
292,977
7,880
Incomparable
ASBIS also presents the intensity ratios – per revenues (as required by ESRS) – and per item sold (as historically
disclosed).
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
28
GHG intensity
2024
2023
YoY growth
GHG intensity per net revenues
Total GHG emissions Scope 1+ Scope 2
(location-method) + Scope 3 per net
revenues (US$ m)
98
3
Incomparable
Total GHG emissions Scope 1+ Scope 2
(market-method) + Scope 3 per net
revenues (US$ m)
97
3
Incomparable
Net revenues (US$ m)
3,009
3,061
-2%
GHG intensity per item sold
Total GHG emissions Scope 1+ Scope 2
(location-method) + Scope 3 per item sold
4
0
Incomparable
Total GHG emissions Scope 1+ Scope 2
(market-method) + Scope 3 per item sold
4
0
Incomparable
Number of items sold
82,492
77,068
7%
2.1.10 E1-9 ANTICIPATED FINANCIAL EFFECTS FROM MATERIAL PHYSICAL AND TRANSITION
RISKS AND POTENTIAL CLIMATE-RELATED OPPORTUNITIES
As per Section C ESRS 1 exemption, ASBIS presents only a qualitative description of the financial effects of climate risks.
To fully understand the impact of transition and physical climate risks as well as counteractive actions that can be taken
by the Board of Directors, we also conducted a scenario analysis. We analysed the resilience of our business model using
two scenarios. One scenario assumes global temperatures to rise less than 2°C versus the preindustrial era, while the
second one assumes global temperatures to rise more than 2°C versus the preindustrial era. The above-mentioned
scenario analysis has been conducted on a qualitative not quantitative basis with the use of publicly available climate
scenarios as published by IPCC (Intergovernmental Panel on Climate Change) in AR6 (Assessment Report) publications.
Scenario SSP1-2.6 according to which global temperatures are unlikely to rise above 2°C versus the preindustrial levels
Possible impact of climate risks
We believe that in this scenario the impact of transition risks would be much stronger
than of physical risks. In that scenario, the policy and legal risks could be visible with
new laws and regulations being put in place, strongly limiting using selected raw
materials and technology risks could also be visible, impacting the product offering,
tilting it towards eco-friendly products only. Market risks may materialize with
customers being interested only in offering limited their own carbon footprint.
Counteractive actions that we could take
ASBIS business model is a flexible one. The Board of Directors will monitor all
climate risks, especially the transition ones, and will aim to use all available climate
opportunities.
Scenario SSP1-7.0 according to which global temperatures are likely to rise above 2°C versus the preindustrial levels
Possible impact of climate risks
We believe in this scenario, transition risks would not be sizeable, yet that physical
risks would be dominating. Growing temperatures worldwide may cause the need for
more temperature-resilient hardware and appliances, may also result in more
hardware malfunctions that may increase warranty claims. Also, certain areas from
which we source our products may no longer be available, as these may be flooded
or suffer from lack of water or electricity. Thus, our supply chain may need to be
modified.
Counteractive actions that we could take
ASBIS business model is a flexible one. The Board of Directors will monitor all
climate risks, especially the physical ones, and will aim to use all available climate
opportunities.
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2.2 ESRS E2 POLLUTION
2.2.1 IRO-1– DESCRIPTION OF THE PROCESS TO IDENTIFY AND ASSESS MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
Air pollution and microplastics turned out as material topics in Pollution.
2.2.2 E2-1 POLICIES RELATED TO POLLUTION
ASBIS has adopted the RBA Code of Conduct (version 8.0 from 2024) which, among others, recognises that environmental
responsibility is integral to producing world class products. As such, companies should identify the environmental impacts
and minimize adverse effects on the community, environment, and natural resources, while safeguarding the health and
safety of the public. All required permits should be obtained and kept, while reporting requirements should be followed. On
top, pollution is to be prevented, among others by reducing resource usage, minimisation of hazardous substances, solid
waste and air emissions. Companies are to manage water and energy consumption, with the latter being aimed at GHG
emissions reduction (Scope 1 & 2). There are no other formalised policies present.
2.2.3 E2-1 ACTIONS AND RESOURCES RELATED TO POLLUTION
ASBIS does not conduct actions directly targeting air pollution in its value chain but has conducted several actions to limit
the use of packaging and microplastics. ASBIS receives already packaged products from the vendors such as Apple, Dell,
Intel, AMD etc. all of which are companies with very good environmental record. What ASBIS does additionally is put over-
carton over the goods and place them on the pallets. Sometimes we place most valuable goods inside wooden boxes. For
additional security we may use small plastic crates (boxes). We mostly use over-carton, wooden boxes, small plastic boxes
as packaging. We use exactly what is required. Over-carton and wooden boxes are used only for the goods of the highest
value and only to destinations where such security measures are needed. We use the cartons (small boxes) received from
vendors for our courier deliveries, minimizing the quantity of additional packaging and find ways to minimize empty space
in pallets. But if needed we use empty cardboard boxes or bubble foil. We are mainly a distributor and have no direct
impact on the actual packaging of goods (retail packaging). We developed green packaging for our own brands. All
packages used at DC are made from recycled materials, while plastic blisters and hooks have been replaced with paper
trays and hooks. ASBIS reuses the cartons that come with the products purchased by our vendors, which results in much
lower carton usage.
2.2.4 E2-3 TARGETS RELATED TO POLLUTION
ASBIS does not have any targets related to air pollution and microplastics.
2.2.5 E2-4 POLLUTION OF AIR, WATER AND SOIL
ASBIS is in the process of analysing the topic of air and microplastics pollution. For the time being the Company is not
prepared to present any calculations, however it understands that:
• upstream and downstream transportation may be the key source of air pollution,
• packaging is likely to be the main source of microplastic pollution.
2.2.6 E2-6 ANTICIPATED FINANCIAL EFFECTS FROM POLLUTION-RELATED RISKS AND
OPPORTUNITIES
As per Section C ESRS 1 exemption, ASBIS does not present this information.
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2.3 ESRS E5 RESOURCE USE AND CIRCULAR ECONOMY
2.3.1 IRO-1– DESCRIPTION OF THE PROCESS TO IDENTIFY AND ASSESS MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
Circular economy was found to be a material topic for ASBIS.
2.3.2 E5-1 POLICIES RELATED TO RESOURCE USE AND CIRCULAR ECONOMY
At ASBIS there are no formalized policies related to resource use and circular economy.
2.3.3 E5-2 ACTIONS AND RESOURCES IN RELATION TO RESOURCE USE AND CIRCULAR
ECONOMY
ASBIS conducts the following actions to effectively use resources and contribute to circular economy:
• Choice of goods sold – ASBIS mostly distributes products manufactured by large corporations that follow the
applicable regulation and comply with high international standards. Many of these have their own sustainability
actions and strategy aimed, among others, on quality of their products or lengthening the time of their use.
• Careful selection of own products (private labels) - it is in ASBIS best interest to distribute products which are
durable and meet the expectations of end-customers. This limits customer complaints and reduces the number
and cost of warranties, which are of high importance to ASBIS in case of private labels, as we are then ultimately
responsible for the repair.
• Breezy concept: one of ASBIS revenue streams originates from the sale of refurbished electronic products.
Through this operation, electronic products that could have been disposed at the expense of the environment are
brought back to use. At the end of 2024, Breezy concept was operating in 8 countries and generated US$ 47.4m
of revenues, though was still loss making.
• Packaging encompasses two aspects:
1) packaging by manufacturers – on which ASBIS has a limited direct impact, though notices actions conducted by
large manufacturers and producers aimed at minimising the size of the packaging,
2) ASBIS’ own actions as distributor - The Company uses the cartons (small boxes) received from vendors for our
courier deliveries, minimizing the quantity of additional packaging and ways to minimize empty space in pallets. We
developed green packaging for our own brands. All packages used at DC are made from recycled materials, while
plastic blisters and hooks have been replaced with paper trays and hooks. ASBIS reuses the cartons that come with
the products purchased by our vendors, which results in much lower carton usage.
• Waste reduction policies: ASBIS recognizes that electronic waste is harmful for the environment, and we try to
recycle or dispose of it in a proper way.
1) According to current regulations, especially WEEE Directive (Waste Electrical and Electronic Equipment) electronic
waste disposal has to be paid by the company which enters the product on the market. In ASBIS case these are our
subsidiaries, which are registered in local organizations. The latter deal with the matter. We do provide scrap
operations, it is done by specialized companies.
2) We host battery recycling points in our offices where employees can bring used up batteries to be recycled. Recycling
is performed by specialized organizations in agreement with the government. We also conduct standard recycling of
waste in offices.
3) We have certain teams of professionals who dismantle products to be discarded (mostly PC tablets and
smartphones) by separating elements of the products in categories depending on their manufacturing origin and each
material is processed by the appropriate specialized company.
2.3.4 E5-3 TARGETS RELATED TO RESOURCE USE AND CIRCULAR ECONOMY
ASBIS does not have targets related to resource use and circular economy.
2.3.5 E5-4 RESOURCE INFLOWS
The most important resources related to material IROs are IT products and goods distributed by ASBIS. ASBIS does not
have a detailed knowledge of quantities of raw materials used to manufacture the goods sold. It has however conducted
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
31
estimates of mass of products introduced. These encompass: IT equipment purchased, and other goods purchased for
operations (furniture, technical equipment, IT equipment). In terms of technical materials, ASBIS understands these as:
office materials, hygienic and chemical materials – both for offices, warehouses and DCs, construction materials and
packaging. Out of the latter, ASBIS has been able to estimate the weight of packaging which is presented below. The
weight of biological materials has not been estimated as it is considered immaterial. Weight of secondary reused and
recycled components has been estimated based on selected data obtained from product manufacturers.
Resource inflows (kgs)
2024
Total mass of products introduced
15,635,253
Total weight of technical materials introduced
108,150
Including secondary reused or recycled components, secondary
intermediary products and secondary materials used to manufacture the
undertaking’s products and services.
2,501,641
Overall weight of biological materials (and biofuels used for non- energy
purposes) used to manufacture the undertaking’s products and services
-
Including sustainability sourced
-
Total weight of technical and biological materials introduced
108,150
Total weight of products, technical materials and biological materials
15,743,403
Percentage weight of biological materials from sustainable sources
-
Percentage weight of secondary reused and recycled components
16%
2.3.6 E5-5 RESOURCE OUTFLOWS
In terms of resource outflows, the largest identified material outflows relate to IT goods sold to consumers and end-users
as well as packaging. The estimates are presented below.
Resource outflows (kgs)
2024
Total weight of products
16,343,876
Total value of products that can be recycled
-
Total value of packaging
552,335
Total value of packaging that can be recycled
552,335
Product Recyclable Material Content Index
-
Packaging Recyclable Material Content Index
100%
ASBIS does not generate any hazardous waste as defined in Article 3(2) of Directive 2008/98/EC and radioactive waste
as defined by Article 3(7) of Council Directive 2011/70/Euratom.
2.3.7 E5-6 ANTICIPATED FINANCIAL EFFECTS FROM RESOURCE USE AND CIRCULAR
ECONOMY-RELATED RISKS AND OPPORTUNITIES
As per Section C ESRS 1 exemption, ASBIS does not present this information.
2.4 EU TAXONOMY
For 2024 ASBIS presents Taxonomy calculations including eligibility and alignment calculations in all six environmental
targets. These have been prepared based on:
• Regulation of the EU 2020/852 of the European Parliament and of the Council of June 18, 2020 on the
establishment of a framework to facilitate sustainable investment, especially article 8,
• EU Commission Delegated Regulation of June 4, 2021 establishing the technical screening criteria for determining
the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation
or climate change adaptation and for determining whether that economic activity causes no significant harm to
any of the other environmental objectives (Technical screening criteria),
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• Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of
the European Parliament and of the Council by specifying the content and presentation of information to be
disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally
sustainable economic activities, and specifying the methodology to comply with that disclosure obligation
(Disclosure Regulation),
• Commission Delegated Regulation (EU) 2022/1214 of 9 March 2022 amending Delegated Regulation (EU)
2021/2139 as regards economic activities in certain energy sectors and Delegated Regulation (EU) 2021/2178 as
regards specific public disclosures for those economic activities (expanding the Technical screening criteria),
• Commission Delegated Regulation (EU) 2023/2485 of 27 June 2023 amending Delegated Regulation (EU)
2021/2139 establishing additional technical screening criteria for determining the conditions under which certain
economic activities qualify as contributing substantially to climate change mitigation or climate change adaptation
and for determining whether those activities cause no significant harm to any of the other environmental
objectives,
• Commission Delegated Regulation (EU) 2023/2486 of 27 June 2023 supplementing Regulation (EU) 2020/852 of
the European Parliament and of the Council by establishing the technical screening criteria for determining the
conditions under which an economic activity qualifies as contributing substantially to the sustainable use and
protection of water and marine resources, to the transition to a circular economy, to pollution prevention and
control, or to the protection and restoration of biodiversity and ecosystems and for determining whether that
economic activity causes no significant harm to any of the other environmental objectives and amending
Commission Delegated Regulation (EU) 2021/2178 as regards specific public disclosures for those economic
activities.
Based on the above-mentioned legal acts, ASBIS verified Taxonomy alignment on the consolidated level. This has been
conducted in several steps:
• Verification of Taxonomy-eligibility: during this stage we verified whether the eligible activities defined in earlier
years are still valid. The analysis included also activities defined in the Commission Delegated Regulation (EU)
2022/1214, 2023/2485 and 2023/2486.
• Obtaining financial elements: we gathered and calculated financial elements needed for disclosures, i.e.
revenues, capital expenditures and operating expenses in line with definitions presented in Commission
Delegated Regulation (EU) 2021/2178.
• In the third step we allocated the business elements identified in step one to the financial metrics found in step
two.
• Verification of Taxonomy-alignment took place in the form of 1) Technical screening criteria for which we verified
the “significant contribution” and “do not significant harm” principles as described in Commission Delegated
Regulation (UE) 2021/2139 and 2023/2485 and 2023/2486; and 2) Minimum Safeguards in line with Platform on
Sustainable Finance recommendations.
• Filling in the required latest disclosure tables and preparing information needed as specified in Commission
Disclosure Regulation (EU) 2023/2486. ASBIS business model has mostly not been included within legal acts
related to sustainable development Taxonomy, as these have been focused on sectors having the strongest
climate impact.
Taxonomy eligible activities identified include: (6.5) Transportation by motorbikes, passenger cars and light commercial
vehicles in Climate Change Mitigation (CCM) - that is a new element identified, Renovation of existing buildings (7.2) in
Climate change mitigation (CCM), Acquisition and ownership of buildings (7.7) in Climate change mitigation (CCM) and
(5.4) Sale of second-hand goods in Circular economy. No activities described in Commission Delegated Regulation (EU)
2022/1214 have been found.
Financial aspects of the calculations were based on data from ASBIS financial system and definitions applied in
Commission Delegated Regulation 2021/2178, i.e.:
• Turnover: calculated as defined in Article 2, point (5) of Directive 2013/34/EU. Turnover covers revenue
recognised pursuant to International Accounting Standard (IAS) 1, paragraph 82(a), as adopted by Commission
Regulation (EC) No 1126/2008;
• Capex: calculated as additions to tangible and intangible assets during the financial year considered before
depreciation, amortisation and any re-measurements, including those resulting from revaluations and
impairments, for the relevant financial year and excluding fair value changes. The denominator also covers
additions to tangible and intangible assets resulting from business combinations. Specifically, capex covers, if
appl: 1) a) IAS 16 Property, Plant and Equipment, paragraphs 73, (e), point (i) and point (iii);); 2) b) IAS 38
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
33
Intangible Assets, paragraph 118, (e), point (i); and 3) IFRS 16 Leases, paragraph 53, point (h). As such, these
differ from capital expenditures shown in the consolidated financial statements;
• Opex: calculated as direct non-capitalised costs that relate to research and development, building renovation
measures, short-term lease, maintenance and repair, and any other direct expenditures relating to the day-to-day
servicing of assets of property, plant and equipment by the undertaking or third party to whom activities are
outsourced that are necessary to ensure the continued and effective functioning of such assets. Thus, the
definition is much narrower than the one used for the purpose of consolidated financial statements.
After allocating Taxonomy-eligible activities to financial lines, the next step involved verification of Taxonomy-alignment,
which we have conducted for six environmental targets. Environmentally sustainable activities need to add significant
contribution to one of the environmental targets and do no significant harm to other environmental targets. These targets
encompass: climate change mitigation, climate change adaptation, water and marine resources, pollution, circular
economy as well as biodiversity and ecosystems. Thus, we verified whether the identified activities meet Technical
screening criteria as defined by Commission Delegated Regulation 2021/2139, 2023/2485 and 2023/2486.
Minimum Safeguards verification has been conducted based on Platform on Sustainable Finance recommendations
presented in Final Report on Minimum Safeguards. In frames of Human Rights, we have verified whether ASBIS does not
fulfil four premises:
• The company has not established an adequate human rights due diligence process as outlined in the UNGPs and
OECD Guidelines for MNEs.
• The company has finally been found in breach of labour law or human rights.
• An OECD National Contact Point has accepted a case, however the company refuses to engage with the party
which has initiated it, or the company has been found non-compliant with the OECD guidelines by the NCP.
• The Business and Human Rights Resource Centre (BHRRC) has taken up an allegation against the company,
and the company has not answered it within 3 months, only if these letters are less than 2 years old.
Minimum Safeguards verification carried out also covered corruption, taxation and fair competition. The sufficiency of due
diligence processes was checked on the basis of internal verification of existence and effectiveness of these processes,
among others by based on the comprehensive Business Code and Labour Policy. Verification of compliance concerned
the OECD Guidelines for Multinational Enterprises (June 2023) and the UN Guiding Principles on Business and Human
Rights (September 2021), including the principles and rights set out in core conventions indicated in the International
Labour Organization Declaration on Fundamental Principles and Rights at Work and the principles and rights set out in the
International Charter of Human Rights. Compliance was checked using the World Benchmark Alliance Core UNGP
indicators proposed by the Platform on Sustainable Finance. As a result of the analysis, it was determined that the
organization has a complete due diligence process that meets the assumptions of the guidelines. The analysis conducted
confirmed there were no final judgments against ASBIS. Similar information was provided by the verification of the OECD
NCP application database and the Business and Human Rights Resource Center (BHRRC) application database. As a
result, it was established that the Minimum Safeguards are met at the level of Capital Group.
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34
Taxonomy – Group revenues for 2024
Economic activities
Code(s )
Absolute turnover
(US$ m)
Proportion % of
turnover
Substantial contribution criteria
Do No Significant Harm criteria
Minimum safeguards
Y/N
Taxonomy
-aligned
proportion of revenues
for 2023
Category (enabling
activity)
Category (transitional
activity)
Climate change
mitigation
(Y,N,N/EL)
Climate change
adaptation
(Y,N,N/EL)
Water (Y,N,N/EL)
Pollution
(Y,N,N/EL)
Circular economy
(Y,N,N/EL)
Biodiversity and
ecosystems
(Y,N,N/EL)
Climate change
mitigation (Y/N)
Climate change
adaptation (Y/N)
Water (Y/N)
Pollution (Y/N)
Circular economy
(Y/N)
Biodiversity and
ecosystem (Y/N)
A. Taxonomy eligible activities
A1. Environmentally sustainable activities (Taxonomy-aligned)
Sale of second
hand goods
CE 5.4
13.2
0.4%
N/EL
N/EL
N/EL
N/EL
Y
N/EL
Y
Y
Y
Y
Y
Y
Y
0.1%
-
-
Turnover of
environmentally
sustainable activities
(Taxonomy aligned)
US$
13.2
m
0.4%
0.0%
0.0%
0.0%
0.0%
0.4%
0.0%
Y
Y
Y
Y
Y
Y
Y
0.1%
of which enabling
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
N
N
N
N
N
N
Y
0.0%
E
of which transitional
0.0%
N
N
N
N
N
N
Y
0.0%
T
A2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
EL,
N/EL
EL,
N/E
EL,
N/E
EL,
N/E
EL,
N/E
EL,
N/EL
N/A
0.0
0.0%
N/EL
N/EL
N/EL
N/EL
N/EL
N/EL
0.0%
Turnover of Taxonomy-eligible
but not environmentally sustainable
activities (not Taxonomy aligned) = US$ 0m
0.0%
0.0%
Total A1+A2 = US$ 13.2m 0.4%
0.0%
B. Taxonomy non-eligible activities
Turnover of Taxonomy non-eligible activities = US$ 2,995.3 m 99.6% 99.9%
Total A + B = US$ 3,008.5 m
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Both in 2024 and in 2023 the Breezy concept met all of the criteria of circular economy 5.4 and thus was treated as taxonomy aligned activity.
Taxonomy – Group Capital expenditures for 2024
Economic activities
Code (s)
Absolute capex
(US$ m)
Proportion % of capex
Substantial contribution criteria
Do No Significant Harm criteria
Minimum safeguards
Y/N
Taxonomy
-aligned
proportion of capex for
2023
Category (enabling
activity)
Category (transitional
activity)
Climate change
mitigation
(Y,N,N/EL)
Climate change
adaptation
(Y,N,N/EL)
Water (Y,N,N/EL)
Pollution (Y,N,N/EL)
Circular economy
(Y,N,N/EL)
Biodiversity and
ecosystems
(Y,N,N/EL)
Climate change
mitigation (Y/N)
Climate change
adaptation (Y/N)
Water (Y/N)
Pollution (Y/N)
Circular economy
(Y/N)
Biodiversity and
ecosystem (Y/N)
A. Taxonomy eligible activities
A1. Environmentally sustainable activities (Taxonomy-aligned)
Transport by
motorbikes, passenger
cars and light
commercial vehicles
CCM 6.5/
CCA 6.5
0.04
0.2%
EL
EL
N/EL
N/EL
N/EL
N/EL
Y
Y
Y
Y
Y
Y
Y
0.2%
-
-
Capex of
environmentally
sustainable activities
(Taxonomy aligned)
US$
0.04m
0.2%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
Y
Y
Y
Y
Y
Y
Y
0.2%
of which enabling
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
N
N
N
N
N
N
Y
0.0%
E
of which transitional
0.0%
N
N
N
N
N
N
Y
0.0%
T
A2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
Transport by
motorbikes, passenger
cars and light
commercial vehicles
CCM
6.5/
CCA
6.5
0.8
3.6%
EL
EL
N/EL
N/EL
N/EL
N/EL
4.2%
Renovation of existing
buildings
CCM
7.2/
CCA7.2
/ CE3.2
0.0
0.0%
EL
EL
N/EL
N/EL
EL
N/EL
2.8%
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Acquisition and ownership
of buildings
CCM
7.7/
CCA
7.7
15.6
68.3%
EL
EL
N/EL
N/EL
N/EL
N/EL
57.8%
Capex of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy aligned) = US$ 16.4 m 72.0% 60.6%
Total A1+A2 = US$ 16.4m 72.2% 66.7%
B. Taxonomy non-eligible activities
Capex of Taxonomy
non-eligible activities = US$ 6.3m 27.8% 33.3%
Total A + B = US$ 22.8m
The situation with capital expenditures was different than with revenues. Firstly, in comparison to earlier years, capex activities have been expanded by Transport by motorbikes,
passenger cars and light commercial vehicles 6.5 CCM/CCA activity, which – depending on the vehicle type – proved either taxonomy aligned (electric vehicles) or taxonomy eligible
(2023 data have been amended). Capex from Renovating of existing buildings and Acquisition and ownership of buildings did not meet the technical screening criteria. Overall, 0.2% of
capex was taxonomy aligned and 72.0% eligible for 2024.
Taxonomy – Group Opex for 2024
Economic activities
Code(s)
Absolute opex
(US$ m)
Proportion % of opex
Substantial contribution criteria
Do No Significant Harm criteria
Minimum safeguards
Y/N
Taxonomy
-aligned
proportion of opex for
2023
Category (enabling
activity)
Category (transitional
activity)
Climate change
mitigation
(Y,N,N/EL)
Climate change
adaptation
(Y,N,N/EL)
Water (Y,N,N/EL)
Pollution
(Y,N,N/EL)
Circular economy
(Y,N,N/EL)
Biodiversity and
ecosystems
(Y,N,N/EL)
Climate change
mitigation (Y/N)
Climate change
adaptation (Y/N)
Water (Y/N)
Pollution (Y/N)
Circular economy
(Y/N)
Biodiversity and
ecosystem (Y/N)
A. Taxonomy eligible activities
A1. Environmentally sustainable activities (Taxonomy-aligned)
N/A
0.0
0.0%
N/EL
N/EL
N/EL
N/EL
N/EL
N/EL
N
N
N
N
N
N
Y
0.0%
-
-
Opex of
environmentally
sustainable activities
(Taxonomy aligned)
US$
0.0m
0.0%
0.0%
0.0%
0.0
0.0%
0.0%
0.0%
N
N
N
N
N
N
Y
0.0%
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37
of which enabling
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
N
N
N
N
N
N
Y
0.0%
E
of which transitional
0.0%
0.0%
N
N
N
N
N
N
Y
0.0%
T
A2. Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
EL,
N/EL
Acquisition and
ownership of buildings
CCM 7.7/
CCA7.7
5.3
66.4%
EL
EL
N/EL
N/EL
N/EL
N/EL
63.9%
Opex of Taxonomy-eligible
but not environmentally
sustainable activities (not
Taxonomy aligned)
US$
5.3m
66.4%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
63.9%
Total A1+A2 =US$ 5.3m 63.9%
B. Taxonomy non-eligible activities
Opex of Taxonomy
non-eligible activities = US$ 2.7m 33.6% 36.1%
Total A + B = US$ 8.0m
In terms of opex there were no operating expenditures aligned but 66.4% eligible for 2024.
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
38
Taxonomy summary tables
Target// Turnover part/Total turnover
Taxonomy alignment by targets
Taxonomy eligibility by targets
CCM
0.0%
0.0%
CCA
0.0%
0.0%
WTR
0.0%
0.0%
CE
0.4%
0.0%
PPC
0.0%
0.0%
BIO
0.0%
0.0%
Target// Capex part/Total capex
Taxonomy alignment by targets
Taxonomy eligibility by targets
CCM
0.2%
72.0%
CCA
0.0%
0.0%
WTR
0.0%
0.0%
CE
0.0%
0.0%
PPC
0.0%
0.0%
BIO
0.0%
0.0%
Target// Opex part/Total opex
Taxonomy alignment by targets
Taxonomy eligibility by targets
CCM
0.0%
66.4%
CCA
0.0%
0.0%
WTR
0.0%
0.0%
CE
0.0%
0.0%
PPC
0.0%
0.0%
BIO
0.0%
0.0%
Nuclear energy related activities
YES/NO
1
The undertaking carries out, funds or has exposures to research,
development, demonstration and deployment of innovative electricity
generation facilities that produce energy from nuclear processes with
minimal waste from the fuel cycle.
NO
2
The undertaking carries out, funds or has exposures to construction and
safe operation of new nuclear installations to produce electricity or
process heat, including for the purposes of district heating or industrial
processes such as hydrogen production, as well as their safety
upgrades, using best available technologies.
NO
3
The undertaking carries out, funds or has exposures to safe operation of
existing nuclear installations that produce electricity or process heat,
including for the purposes of district heating or industrial processes such
as hydrogen production from nuclear energy, as well as their safety
upgrades.
NO
Nuclear energy related activities
YES/NO
4
The undertaking carries out, funds or has exposures to construction or
operation of electricity generation facilities that produce electricity using
fossil gaseous fuels.
NO
5
The undertaking carries out, funds or has exposures to construction,
refurbishment, and operation of combined heat/cool and power
generation facilities using fossil gaseous fuels.
NO
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39
Nuclear energy related activities
YES/NO
6
The undertaking carries out, funds or has exposures to construction,
refurbishment and operation of heat generation facilities that produce
heat/cool using fossil gaseous fuels.
NO
3 SOCIAL INFORMATION
3.1 S1 OWN WORKFORCE
Data regarding employees is reported on a per person basis and it includes the parent company and all consolidated
subsidiaries. It does not include affiliates due to their immateriality. It shows average level of employees as according to
the Board of Directors it is more representative than end-of-period values as is in line with financial reporting and non-
financial reporting from the past years. Also, other forms of cooperation have been identified and included. Thus, all own
workforce who could materially be impacted by ASBIS is included in this report. Presented data has been obtained from
own systems and includes Board of Directors.
3.1.1 SBM-2 INTERESTS AND VIEWS OF STAKEHOLDERS
A varied group of employees’ representatives participated in the double materiality assessment process which was the key
basis for identifying material IROs. Opinions expressed by those stakeholders were included in the double materiality
assessment process which is described in the ESRS 2 disclosures.
3.1.2 SBM-3 MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH
STRATEGY AND BUSINESS MODEL
Employment characteristics
ASBIS employs mostly on permanent contracts, with only a fraction hired on a temporary basis and no non-guaranteed
hours persons. We have also identified self-employed persons though ASBIS has not been benefiting from non-employees
provided by undertakings primarily engaged in “employment activities”. ASBIS operates in some 60 countries and our
employees are located in over 30 countries, in which we hold subsidiaries. Countries we operate fall in different regions
with different cultures and religions. Only some 11% of our employees work for the parent company, with the balance
working for subsidiaries. 55% of our employees are employed in the FSU region. The second largest region based on
employment is the CEE region, which employed 38% of average number of employees in 2024, leaving the MEA and other
regions each with 7% of headcount, respectively. We also require employees of different skillset as our key functions
include sales and marketing, administration and IT, logistics and finance.
Impact of ASBIS on own workforce
Impact exerted on own employees results both from the external conditions of the labour markets in which ASBIS operates
and from the adopted business model, including in particular the corporate culture being developed. ASBIS’ identified
material impacts on own workforce are far ranging: working conditions, security of employment, adequate wages, social
dialogue, work-life balance, health and safety, equal treatment and opportunities, gender equality and equal pay, workforce
training and development, measures against violence and harassment in the workplace and diversity.
Risks and opportunities associated with own workforce
Identified material risks and opportunities within the double materiality assessment involved: working conditions, adequate
wages, equal treatment and opportunities, gender equality and equal pay as well as diversity. We see risks in retaining
employees (especially key employees) and our ability to hire new qualified personnel in all countries of operations. Our
business depends upon the contribution of a number of our executive directors, key senior management and personnel.
There can be no certainty that their services will continue to be available to us. We have in the past experienced and may
in the future continue to experience difficulty in identifying expert personnel in our areas of activity, and particularly in the
areas of information technology and sales and marketing, in the countries in which we operate. If we are not successful in
retaining or attracting highly qualified personnel in key management positions, this could have a material adverse effect
upon our business, operating results and financial condition. Thus, it is crucial for ASBIS to offer proper working conditions,
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40
adequate wages, equal treatment and opportunities, gender equality and equal pay for all its diverse workforce. There
were no identified incidents of forced labour or child labour.
3.1.3 S1-1 POLICIES RELATED TO OWN WORKFORCE
At ASBIS there are several policies related to own workforce as the Company is committed to advancing human rights
through policies and business activities:
• Code of Conduct sets forth general guidance on how to carry out daily activities in accordance with our purpose
and values, as well as in compliance with the applicable legal requirements and ASBIS’s policies, standards and
ethical principles. The Code includes 10 guiding principles which are straightforward points written in easy to
comprehend language and simple to follow for all employees (presented in G1-1 section). The Code of Conduct
applies to everyone at ASBIS worldwide and encompasses ethical guidelines which are to support employees in
making the right choices. It promotes honest and ethical conduct, a safe working environment and compliance
with all governmental directives, laws, rules and regulations.
• HR Management Policy – a comprehensive policy at the Group level to standardize processes related to Human
Resources and addresses employer branding actions. It encompasses six key topics aimed at:
1) hiring: the aim of the hiring process is to find the right candidates to fill in for our vacancies and to identify and
attract people who will be building the Company with us,
2) team building: underling the need to focus on proper onboarding of our new hires, motivation of our employees
and building leaders who will shape the future of ASBIS as well as on retaining the talent,
3) motivation: indicating that the best way to motivate employees is to offer a transparent career path, fair and
transparent remuneration as well as development opportunities,
4) leadership: underlining that to build leaders we need to develop our employees, as we believe that trainings are
the key to ASBIS well-being and long-term development,
5) diversity: which is embedded in our everyday operations. We want ASBIS to be an inclusive workplace where
people of all ages, religions, origins will find a common place to work and develop,
6) anti-mobbing: ASBIS to be a place free from any discrimination, mobbing and illegal actions.
• Our Human Rights & Labor Policy sets forth ASBIS’ global standards regarding The Code of Labour Practices.
This policy of labour practice sets forth minimum standards for working time and working conditions and provides
for observance of all of the core standards of the International Labor Organisation including other applicable
Conventions. The policy provides a pledge by the Company to observe these standards and to require its
contractors, subcontractors and suppliers to observe these standards. It also establishes ASBIS’ general
responsibilities concerning human rights, health management, work safety, career management, employees’
rights etc.
• Our Employment Standards and Global Supplier Standards cover company-owned operations as well as our
supplier partners. These policies describe the workplace practices and ethical behaviour that we require for all
workers such as: (1) prohibiting child and forced labour, (2) ensuring non-discrimination and equal opportunity,
(3) supporting a harassment-free and violence-free workplace, (4) prohibiting retaliation or any form of physical
or mental disciplinary practices, (5) respecting workers’ right to freedom of association, (6) ensuring compliance
with laws governing working hours and wages and (7) promoting environmental protection, health and safety.
• Privacy Policy publicly available at ASBIS’ webpage informs what personal information is collected, how it is done
and stored, what is the purpose of data collection as well as indicates how changes can be made to this data.
• Occupational Health & Safety Management System: ASBIS has implemented a set of comprehensive policies,
demonstrating commitment to the health and safety of employees and all stakeholders. The policy focuses on
continual improvement towards an accident-free and disease-free workplace through effective administration,
education, and training.
3.1.4 S1-2 PROCESSES FOR ENGAGING WITH OWN WORKERS AND WORKERS’
REPRESENTATIVES ABOUT IMPACTS
As there are no workers representatives at ASBIS thus the process of engaging with own workers takes place on a country-
by-country level and individual basis. In line with its HR Policy ASBIS has an open-door policy allowing for reporting and
discussing arising situations, career paths and new ideas. ASBIS’ employees are the driving force for new products and
countries developments with the strategic directions being shaped in form of discussions and analysis.
Engagement with own workforce occurs at various stages, such as during the planning phase of new projects, during
implementation, and post-implementation. For example, ASBIS involves employees in the planning stages of new
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41
initiatives through brainstorming sessions and focus groups. Post-implementation, the Company conducts surveys,
requesting the employees’ feedback. Examples of such engagement include:
• Management distributes surveys to gather feedback on various aspects of the workplace such as job satisfaction,
safety, and well-being. A yearly survey provided by the organization Great Place to Work is conducted to measure
the workforce’s satisfaction with the Company and identify areas for improvement.
• Anonymous suggestion boxes were placed to encourage employees to share their ideas and concerns without
fear of reprisal.
• Managers have regular one-on-one meetings with their team members, giving them the opportunity to raise any
concerns or other matters they find important. These provide opportunities for direct feedback and discussion of
any concerns or suggestions.
• The Company organizes focus groups with employees for various company matters. Focus groups play a major
role in the Group’s strategy, mainly in sales. The Group has implemented an in-house Focus Group IT system, to
effectively organize the whole process.
• Workforce feedback has led to changes in company policies. For instance, feedback on company working hours
brought the introduction of remote working options and flexible hours in certain departments/locations. After
employees’ suggestions, certain offices were equipped with ergonomic furniture (adjustable standing desks)
which resulted in a more comfortable and productive workspace.
3.1.5 S1-3 PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND CHANNELS FOR OWN
WORKFORCE TO RAISE CONCERNS
ASBIS through employee surveys and feedback sessions identifies negative impacts on own workforce. Afterwards the
company implements corrective actions to address the causes and prevent recurrence. This includes policy changes,
training programs and improvements in working conditions. Finally, there is continuous monitoring and evaluation through
feedback and performance metrics to ensure their effectiveness.
Channels to raise concerns include:
• anonymous suggestion boxes that allow employees to report concerns without fear of retaliation and ensure
confidentiality,
• Whistleblowing Policy which encourages employees to report unethical behavior or violations. It provides
protection against retaliation and clear procedures for handling reports,
• open-door policy where employees can freely discuss concerns with their managers and HR representatives. This
fosters a culture of transparency and trust.
The Whistleblowing Policy (in place since 2006, updated in 2019 and 2024) allows employees, ASBIS partners, contractors
and consultants and other stakeholders to anonymously raise concerns about possible wrongdoing to the Board of
Directors. Concerns must be reported in writing. These can be delivered either to one of the executive directors or via a
publicly available email on the webpage. It is ASBIS intention to treat all reports seriously and assure appropriate
investigation of each reported manner.
Once a complaint is made, it is promptly acknowledged by the Company (when not anonymous). This initial
acknowledgment reassures employees that their concerns are being taken seriously. The policy foresees that in the case
of a report, a Whistleblowing Committee will be called and will consist of: two executive directors, Head of Legal Department
and Head of HR Department. All whistleblower reports will be dealt with in strict confidentiality. The Whistleblowing
Committee will process the report and decide whether to start an enquiry in connection to the matter. After that a thorough
investigation is conducted to understand the nature of grievance and gather relevant information. This may involve
interviews, document reviews and other fact-finding methods. Findings of the Whistleblowing Committee will be presented
to the executive directors of ASBIS so that they decide on further actions. Once the investigation is complete, the Company
communicates the findings and any corrective actions to the employee who raised the grievance. The whistleblower will
be notified of this decision and reasons on which it is based. Personal data processed will be dealt with in accordance with
ASBIS Privacy Policy. There was no whistleblowing incidents identified in 2024 and in 2023. In the event of anonymous
complaints, the Company announces the findings through HR. ASBIS also monitors and evaluates the effectiveness of its
grievance process to ensure continuous improvement.
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3.1.6 S1-4 TAKING ACTION ON MATERIAL IMPACTS ON OWN WORKFORCE, AND APPROACHES
TO MANAGING MATERIAL RISKS AND PURSUING MATERIAL OPPORTUNITIES RELATED TO
OWN WORKFORCE, AND EFFECTIVENESS OF THOSE ACTION
ASBIS takes several actions on material impacts on own workforce and approaches to managing risks and pursuing
opportunities. They include, among others:
• Assuring a diverse and inclusive working environment: which starts from inclusive culture, respecting the rights of
different employees in 34 countries of different origins, gender, age and religion. Actions taken include: 1) allowing
for hybrid work whenever it is possible, 2) building and maintaining strong teams with focus on proper onboarding
of our new hires, 3) acknowledging all employees with our Mission and Vision, corporate culture and helping them
identify new roles and responsibilities, 4) ensuring employees are equipped with relevant tools and resources to
perform their tasks and that their adaptation is effective and comfortable and 5) a welcome package for each of
our new employees.
• Assuring a fair recruitment process: The recruitment process is oriented on: (1) judging the candidates based on
their competences, (2) assuring objectivity of assessment, also by using IT tools, (3) giving equal opportunities to
candidates regardless of their gender, social or marital status, age or disabilities, and (4) respecting their rights
and relevant laws. While filling in a position we resort to internal and external recruitment. We search for
employees from within ASBIS to allow them to develop as well as advertise the opening outside. If possible, we
prioritize internal promotions versus external to promote long-term commitments. To increase transparency and
objectivity of the hiring process each candidate has at least two meetings with ASBIS managers with different
levels of seniority, before a decision is taken.
• Assuring transparent career paths: Career paths depend on the place of start and area where they originated.
Employees are informed about their potential career path the moment they start work. Remuneration brackets are
set for each position. Employees are motivated by bonuses based on their achievements. In order to make sure
that we pay market salaries, we try to keep up-to-date with the latest developments on the markets where we hold
subsidiaries and we do our research on job portals. We run an assessment model which for each level of our
hierarchy focuses on hard criteria (effectiveness measured by KPIs) and soft criteria (like behaviour, environment
and empowerment).
• Promoting diversity of employees and opinions: Diversity is important for us as it is embedded in our everyday
operations. We recognize that each employee is unique and has own characteristics and we wish to present all
of them with development opportunities. We encourage diversity in opinions. We believe that exchange of ideas
brings our Company forward. We build teams of all nationalities and ages as we wish to use the knowledge of our
experienced employees and the energy and fresh ideas from the younger generations. It is our aim to have a
balanced gender approach for each position which is to be filled. If balance is not possible, we will still aim to have
at least one representative of each gender. We build a workplace which is full of mutual respect between
employees and friendly atmosphere.
• Prohibiting mobbing: We are strongly against employees abusing their positions and acting illegally, unfairly and
not in a dignified manner. This includes any forms of harassment including proliferation of materials on employees
and their personal data. We only allow constructive feedback. We do not tolerate sexual harassment, any other
forms of harassment. We say no to aggressive behaviours. We encourage our employees to report any such
violations and we assure them anonymity and legal assistance. ASBIS considers bullying unacceptable and it is
not tolerated under any circumstances. Although we have not faced such situations to date, it is clear to us that
any employee who will be found in violation of the policy will be disciplined.
• Aiming to be a socially responsible company: We take a decentralized approach to community engagement and
investments allowing our subsidiaries to conduct actions they believe are proper and needed. That need differs
on circumstances and these have been dynamically changing over the last years. E.g. in Cyprus, this involved
sponsoring ASBIS teams in Limassol Marathon and sailing as well as sailing team for youth or taking part in “Let’s
plant tress” initiative.
• Taking care of social aspects for employees, which relates to families of our employees. We offer gifts to kids of
our employees (until these reach 18 years old) especially in the Christmas season. We also offer our employees
opportunities to act in frames of corporate volunteering actions (e.g., some of them are blood donors).
3.1.7 S1-5 TARGETS RELATED TO MANAGING MATERIAL NEGATIVE IMPACTS, ADVANCING
POSITIVE IMPACTS, AND MANAGING MATERIAL RISKS AND OPPORTUNITIES
HR department has targets related to employee turnover and retention of employees who have completed their probation
period.
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43
3.1.8 S1-6 CHARACTERISTICS OF THE UNDERTAKING’S EMPLOYEES
Employment structure in various splits is presented below. Gender split of ASBIS’ employees has remained stable in 2023
- 24 period, with male employees constituting 68% of employees.
The largest countries in which ASBIS is present where more than 10% of headcount is employed encompass: Kazakhstan,
Cyprus and Ukraine.
Employee breakdown by largest countries
2024
2023
Ukraine
353
328
Kazakhstan
480
401
Cyprus
342
328
Other
1,603
1,616
Total employees (average)
2,779
2,673
The majority of employees are permanent employees. All employees have guaranteed hours contracts.
2024 employee characteristics
(average headcount)
Female
Male
Other
Not disclosed
Total
Number of employees
1,833
0
2,779
Number of permanent employees
1,808
0
2,739
Number of temporary employees
25
0
40
Number of non-guaranteed hours
employees
0
0
0
2023 employee characteristics
(average headcount)
Female
Male
Other
Not disclosed
Total
Number of employees
1,793
0
2,673
Number of permanent employees
1,746
0
2,601
Number of temporary employees
47
0
72
Number of non-guaranteed hours
employees
0
0
0
2024 the total number of employees who have left the undertaking during the reporting period came in at 995, down 12%
YoY and the rate of employee turnover in the reporting period came in at 35.8%, down 6.5 pp.
Employee characteristics (average headcount)
2024
2023
Number of employees leaving
995
1,131
Rotation
35.8%
42.3%
The methodology for 2023 and 2024 calculations has not been altered over the years. These have been prepared based
on ASBIS’ electronic records in its systems. Data includes data on employees – permanent and temporary – calculated as
averages for every month. Employees transferring within the group have not been treated as new hiring or firing, persons
from acquired companies have been treated as new employees and the data only relates to subsidiaries.
3.1.9 S1-7 CHARACTERISTICS OF NON-EMPLOYEES IN THE UNDERTAKING’S OWN WORKFORCE
Employment is the most common way of engaging with ASBIS as part of own workforce. At the end of 2024 ASBIS
identified 297 self-employed persons (264 at the end of 2023). There have been no persons provided by undertakings
primarily engaged in employment activities both in 2024 and 2023.
3.1.10 S1-9 DIVERSITY METRICS
The definition of top management employees, as suggested by the ESRS i.e. employees two levels down from the Board
of Directors, does not accurately describe the situation for ASBIS. Within ASBIS there are many employees at two levels
below the Board of Directors who are not "top management". Thus, an internal algorithm has been applied to assure key
personnel is presented. Board of Directors is shown as top management.
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ASBISc Enterprises Plc SUSTAINABILITY STATEMENT, 2024
44
2024
Female
Male
Other
Not disclosed
Total
Top management
32
35
0
0
67
Other employees
914
1,798
0
0
2,712
Total
946
1,833
0
0
2,779
2023
Female
Male
Other
Not disclosed
Total
Top management
31
35
0
0
66
Other employees
849
1,758
0
0
2,607
Total
880
1,793
0
0
2,673
Also, we present employees’ split by age. ASBIS employees are diverse in terms of age. In 2024 some 65% of our
employees were between 30 to 50 years old, while around 26% were below 30 years old. On top, some 34% of our
employees in 2024 were women. The split has remained roughly stable YoY.
Average number of
employees
2024
Female
Male
Other
Not disclosed
Total
under 30 years old
222
488
0
0
710
30-50 years old
639
1,171
0
0
1,810
over 50 years old
86
173
0
0
259
Average number of
employees
2023
Female
Male
Other
Not disclosed
Total
under 30 years old
199
499
0
0
698
30-50 years old
604
1,133
0
0
1,737
over 50 years old
77
161
0
0
238
3.1.11 S1-10 ADEQUATE WAGES
ASBIS does not pay below and at the minimum wage level in countries present (neither at retail stores nor warehouses).
2024
2023
YoY change
Percentage of employees earning wages below the set
level of adequate wages
0%
0%
0
3.1.12 S1-13 TRAINING AND SKILLS DEVELOPMENT METRICS
Trainings and skills development are crucial for ASBIS to strengthen its intellectual capital, build leaders and develop
employees, their well-being and long-term engagement. Implemented actions include:
• training plan and matrix in place which indicates what training should be undertaken depending on the seniority
of the person to ensure employees have the required skills and knowledge to undertake their tasks. Trainings
depend on the department, employees’ performance and new market trends and are fully covered by ASBIS (even
if these require travelling abroad),
• arranging trainings for employees as per the request of managers or directors. We see value in financing
international trainings and certificates as this improves the performance of our employees and makes the
Company more prepared for market changes,
• organising dedicated trainings – a dedicated group of employees organises frequent seminars on a wide range
of fields. There is a number of employees fully dedicated on this matter,
• operating an online portal – which includes a library with all information one could need for their job, like policies,
manuals, business processes – and online learning system, where new courses are uploaded continuously. Some
courses are mandatory, while other are optional. All newcomers need to complete a certain number of courses,
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based on their department and position. On average, sales and marketing employees complete the most training
hours, since it is them who need to keep up to date with the very frequent developments in the IT industry,
• development and promotion of knowledge sharing – when needed, the directors and departmental managers
perform 1-to-1 meetings with employees in order to pass on their knowledge and skills in a more effective manner.
As a result, the average training hours per employee came in 9.84 hours, up 30% YoY.
Average training hours per
employee
Female
Male
Other
Not reported
Total
2024
8.05
11.63
0
0
9.84
2023
6.37
8.8
0
0
7.58
3.1.13 S1-14 HEALTH AND SAFETY METRICS
ASBIS’ takes health and safety of its workforce seriously. We have established internal services for protection and
prevention, a Health and Safety Committee and training programs. Our emergency response plan covers various
scenarios, ensuring preparedness and immediate action. Additionally, we maintain detailed protocols for managing and
recording accidents and incidents, underscoring our proactive approach to workplace safety. Employees are to be in a
safe environment, protected from hazards of the job. In 2023 and in 2024 100% of percentage of ASBIS’ employees who
were covered by the undertaking’s health and safety management system based on legal requirements and/or recognised
standards or guidelines.
Accidents involving employees
2024
2023
Fatalities in own workforce as result of work-related
injuries and work-related ill health
0
0
Fatalities as result of work-related injuries and work-
related ill health of other workers working on
undertaking's sites
0
0
Recordable work-related accidents
0
0
Rate of recordable work-related accidents for own
workforce
0%
0%
Cases of recordable work-related ill health of employees
0
0
Number of days lost to work-related injuries and fatalities
from work-related accidents, work-related ill health and
fatalities from ill health related to employees
0
0
3.1.14 S1-16 REMUNERATION METRICS
Employees’ motivation is linked with a fair remuneration. We want the salaries to include not only a fixed but also a variable
component, to align the remuneration of employees with the performance of the whole Company. The variable part of the
remuneration relates to profitability bonus and/or commission and management bonus. We have an in-house grading
system. The Company provides access for all employees to its IT platform and managers can assign their subordinates
certain tasks or the employees log their tasks on a quarterly basis. From the results of their tasks, managers can check
the employees’ progress and if these are visible, the managers can grant a bonus on a quarterly basis. This allows
employees to work effectively and obtain constructive feedback.
We also emphasise fair remuneration as we want our employees to feel and be treated fairly in all respect. As a result, we
calculate and look at the gender pay gap ratio both at the Group level as well as the key functional units. We believe that
all our employees are fairly remunerated and the 24% gender pay gap ratio identified for 2024 (versus 26% in 2023) results
mostly from the structure of the Group’s line management and years of experience. Women constitute 34% of ASBIS’
employees and 37.5% of Board of Directors. Coincidentally, the average years of experience of men is higher than that of
women. As time goes by, and women employees choose to stay in the company, they gain more experience, and the gap
will be closing. Still, the Board of Directors is devoted to elimination of gender pay gap ratio.
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3.1.15 S1-17 INCIDENTS, COMPLAINTS AND SEVERE HUMAN RIGHTS IMPACTS
In the financial years 2023 -2024, ASBIS did not identify any cases of discrimination or complaints. There were also no
incidents disrespecting human rights related to the undertaking’s workforce in the reporting period. The value of monetary
fines from related accidents came in at US$ 0m (zero) in 2024 and 2023.
3.2 S2 WORKERS IN THE VALUE CHAIN
3.2.1 SBM-2 INTERESTS AND VIEWS OF STAKEHOLDERS
ASBIS double materiality assessment showed three material topics within workers in the value chain: working conditions,
child labour and forced labour.
3.2.2 SBM-3 MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH
STRATEGY AND BUSINESS MODEL
ASBIS does not have direct interactions with workers in the value chain. These have not been directly consulted in double
materiality survey.
3.2.3 S2-1 POLICIES RELATED TO VALUE CHAIN WORKERS
At ASBIS we recognize the importance of preserving human rights in our value chain. We believe in the right to self-
determination, liberty, due process of law, freedom of movement, thought, religion, assembly and association. Thus, we
have policies in place with the aim of assuring these in our value chain. These encompass:
• Human Rights & Labor Policy which sets forth ASBIS’ global standards regarding The Code of Labour Practices. This
policy of labour practice sets forth minimum standards for working time and working conditions and provides for
observance of all of the core standards of the International Labor Organisation including other applicable
Conventions. The policy provides a pledge by the Company to observe these standards and to require its contractors,
subcontractors and suppliers to observe these standards. It also establishes ASBIS’ general responsibilities
concerning human rights, health management, work safety, career management, employees’ rights etc.
• Employment Standards and Global Supplier Standards cover company-owned operations as well as our supplier
partners. These policies describe the workplace practices and ethical behaviour that we require for all workers such
as: (1) prohibiting child and forced labour, (2) ensuring non-discrimination and equal opportunity, (3) supporting a
harassment-free and violence-free workplace, (4) prohibiting retaliation or any form of physical or mental disciplinary
practices, (5) respecting workers’ right to freedom of association, (6) ensuring compliance with laws governing
working hours and wages and (7) promoting environmental protection, health and safety.
• The Whistleblowing Policy allows not only employees but also ASBIS partners, contractors and consultants and other
stakeholders to anonymously raise concerns about possible wrongdoing to the Board of Directors. Concerns must
be reported in writing. These can be delivered either to one of the executive directors or via a publically available
email on the webpage. It is ASBIS intention to treat all reports seriously and assure appropriate investigation of each
reported manner.
• Supplier Code of Conduct, initially approved by the Board of Directors in 2019. Contrary to tailor made internal
documents and policies, ASBIS decided to claim compliance with RBA’s Code of Conduct in terms of its requirements
towards suppliers. The standards set out in the Code reference international norms and standards including the
Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational
Enterprises, ISO and SA standards. Responsible Business Alliance is an industry coalition committed to creating
shared value for businesses, workers and communities. The alliance is open to companies that manufacture or
contract the manufacture of electronic goods or a product in which electronics are essential to the primary functionality
of the product, or supply materials used in the electronics of those goods. The RBA is comprised of more than 500
electronics, retail, auto and toy companies. Selected members include AMD, Alphabet, Amazon, Apple, Cisco, Dell,
Fujitsu, HP, IBM, Intel, Lenovo, Logitech, Meta, Microsoft, Phillips, Seagate and Xerox. The RBA Code of Conduct
(version 8.0 from 2024) is a comprehensive one, covering five crucial topics: labour, health and safety, environment,
ethics and management systems.
1) The Labour part focuses on commitment to upholding the human rights of workers and treating them with dignity.
All workers (incl. temporary, migrant, student, contract, direct employees, and any other type of worker) should be
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free to choose their employment, while child labour should not be used at any stage of manufacturing. A workweek
should not be more than 60 working hours, while wages and benefits should be paid with all applicable wage laws,
including those relating to minimum wages, overtime hours and legally mandated benefits. The Code underlines a
strict commitment to a workplace free of harassment and unlawful discrimination.
2) The Health and Safety part recognises that in addition to minimizing work-related injuries and illnesses, a safe and
healthy working environment enhances the quality of products and services and worker retention and morale. The
Code concentrates on occupational safety, emergency preparedness, and minimisation of occupational injury and
illness. That is to be achieved, among others by industrial hygiene, limiting exposure to physically demanding work,
machine safeguarding, access to proper sanitation, food and housing as well as appropriate health and safety
communication in the form of clean toilet facilities, potable water and sanitary food preparation, storage, and eating
facilities.
3) The third part of the Code recognises that environmental responsibility is integral to producing world class products.
As such, companies should identify the environmental impacts and minimize adverse effects on the community,
environment, and natural resources, while safeguarding the health and safety of the public. All required permits should
be obtained and kept, while reporting requirements should be followed. On top, pollution is to be prevented, among
others by reducing resource usage, minimisation of hazardous substances, solid waste and air emissions. Companies
are to manage water and energy consumption, with the latter being aimed at GHG emissions reduction (Scope 1 &2).
4) The Ethics section underlines that to achieve success, companies need to be socially responsible. Business
integrity among others means no to bribery and corruption which give an improper advantage. All dealings shall be
transparently performed and accurately reflected business books and records and intellectual property rights
respected. On top of fair business, advertising and competition, responsible sourcing of materials and privacy,
companies are to protect identity of whistleblowers and non-retaliation.
5) The fifth part of RBA Code concentrates on management systems. Compliant companies should have systems in
place that will assure compliance with applicable laws and conformance with the Code on top of risk assessment and
management. Companies claiming compliance with the Code should conduct periodic self-evaluations to ensure
conformity to legal and regulatory requirements and shall create and maintain documents and records to ensure
regulatory compliance and conformity.
3.2.4 S2-2 PROCESSES FOR ENGAGING WITH VALUE CHAIN WORKERS ABOUT IMPACTS
At ASBIS there are no direct processes to directly engage with workers in the value chain about impacts.
3.2.5 S2-3 PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND CHANNELS FOR VALUE CHAIN
WORKERS TO RAISE CONCERNS
As described in S1-2 section, ASBIS’ Whistleblowing Policy is available for all external stakeholders which can file their
complaints
• directly to the Whistleblower Committee via email at whistleblowercommittee@asbis.com,
• anonymously through the company’s whistleblowing portal available on the ASBIS website.
These will be dealt with in the same manner as reports filed by employees.
3.2.6 S2-4 TAKING ACTION ON MATERIAL IMPACTS ON VALUE CHAIN WORKERS, AND
APPROACHES TO MANAGING MATERIAL RISKS AND PURSUING MATERIAL
OPPORTUNITIES RELATED TO VALUE CHAIN WORKERS, AND EFFECTIVENESS OF THOSE
ACTION
ASBIS’ position in the value chain of IT distribution minimises its human rights risks as 91.2% of its revenues comes from
suppliers that are RBA’s members. These are large companies, mostly listed on NASDAQ. ASBIS’ direct impact on
suppliers is limited.
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3.2.7 S2-5 TARGETS RELATED TO MANAGING MATERIAL NEGATIVE IMPACTS, ADVANCING
POSITIVE IMPACTS, AND MANAGING MATERIAL RISKS AND OPPORTUNITIES
At ASBIS there are no targets related to managing negative impacts, advancing positive impacts and managing material
risks and opportunities in terms of workers in the value chain.
3.3 S4 CONSUMERS AND END-USERS
3.3.1 SBM-2 INTERESTS AND VIEWS OF STAKEHOLDERS
ASBIS double materiality assessment showed 3 material topics: information related impacts for consumers and end-users,
consumers and end-users' access to (quality) information and health and safety of consumers and end-users.
3.3.2 SBM-3 MATERIAL IMPACTS, RISKS AND OPPORTUNITIES AND THEIR INTERACTION WITH
STRATEGY AND BUSINESS MODEL
Selected representatives of business and retail customers have been consulted in two stages of double materiality
assessment (survey and stakeholder panel) and their views have been taken into account while setting the final list of
material topics.
3.3.3 S4-1 POLICIES RELATED TO CONSUMERS AND END-USERS
At ASBIS there are no formalised policies relating to quality and safety of information and health and safety of third-party
goods distributed. Yet, ASBIS assures all products are safe for customers and end-users: 1) the Company only sells goods
of the largest IT hardware manufacturers which have their own quality and safety policies in place and follow the applicable
regulation and comply with high international standards and 2) ASBIS has processes in place to assure the quality and
safety of its private labels. Moreover, in its actions and cooperation with consumers and end-users ASBIS adheres to all
relevant international standards, guidelines and conventions.
3.3.4 S4-2 PROCESSES FOR ENGAGING WITH CONSUMERS AND END-USERS ABOUT IMPACTS
Processes for engaging with customers differ in terms of corporate and retail customers:
• corporate customers: engagement often involves more personalized and long-term strategies, actions are tailored
to meet specific business needs, and there is a focus on maintaining strong, ongoing relationships,
• retail customers: engagement tends to be more standardized, with focus put on providing quick resolutions,
excellent customer service and maintaining a positive shopping experience.
Quality of information
To assure quality of information for consumers and end-users, ASBIS:
• ensures that all product descriptions are detailed, accurate, and up to date. This includes specifications, features,
benefits, and usage instructions – the customers placing orders through IT4Profit platform have access to a
database of detailed product descriptions. This database is continuously updated by the dedicated content team,
• adheres to international standards like ISO 9001 which ensures that ASBIS quality management systems are
effective and consistently improving,
• ensures employee training: regular training programs for employees ensure they are knowledgeable about the
products and can provide accurate information to customers.
Safety of products and goods distributed
In order to assure safety of products and goods distributed ASBIS conducts:
• supplier verification: ASBIS verifies that suppliers adhere to strict safety and quality standards. This includes
conducting audits and requiring certifications that demonstrate compliance with relevant safety regulations,
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• quality control checks: the Company implements quality control checks at various stages of the distribution
process that help to identify and address any safety issues before products reach consumers. This includes
random sampling and testing of products as well as regular audits at supplier’s facilities,
• proper storage conditions: products and goods are stored under appropriate conditions to maintain their safety
and integrity. This includes controlling temperature, humidity, and other environmental factors in warehouses,
• training and education: ASBIS offers training programs for employees on product safety standards and best
practices. This ensures that everyone involved in the distribution process is knowledgeable about maintaining
product safety.
These processes differ depending on the type of goods and products distributed:
• goods distributed: ASBIS focuses on a mix of hardware from various manufacturers. Ensuring safety involves
verifying supplier standards, conducting quality control checks, and complying with relevant regulations,
• private labels: these products allow ASBIS to have more control over the design, quality and branding. This means
ASBIS can implement own safety protocols, customize safety features and ensure higher standards of quality
control.
All processes are supervised by Chief Quality Officer.
3.3.5 S4-3 PROCESSES TO REMEDIATE NEGATIVE IMPACTS AND CHANNELS FOR CONSUMERS
AND END-USERS TO RAISE CONCERNS
It is in our best interest to distribute products which are durable and meet the expectations of end-customers. This limits
customer complaints and reduces the number and cost of warranties. When products become defective within the
manufacturer’s warranty period due to a production or material defect, ASBIS may choose, at its own discretion, to deliver
refurbished or new products, to repair the products or to issue a credit note. Warranties are especially important for ASBIS
in case of private labels, as we are then ultimately responsible for the repair.
Despite these, ASBIS understands that negative impacts can take place. Thus, there are feedback loops that allow
customers and end-users to share their experiences and concerns. An important aspect is social media monitoring. We
monitor social media platforms for mentions, comments, and reviews. This helps companies understand public sentiment
and gather feedback from a broad audience. We monitor social media interaction with customers so that we identify any
complaints. We also monitor other publications made about ASBIS. Once a complaint is identified the appropriate persons
are informed (legal, management, brand managers etc.),
This feedback is used to continuously improve product information and quality. An example of the process to remediate a
negative impact on customers and end-users is when these receive the wrong order. Then ASBIS can engage with them
effectively by following these steps:
• prompt acknowledgment: quickly acknowledge the mistake and apologize for any inconvenience caused. This
helps to reassure the customer that their issue is being taken seriously,
• effective communication: communicate clearly and empathetically with the customer to understand the specifics
of the wrong order. This includes listening to their concerns and gathering all necessary details,
• immediate resolution: offer a prompt resolution, such as sending the correct order, providing a refund, or offering
a discount on future purchases. Ensure the customer is satisfied with the proposed solution,
• follow-up: follow-up with the customer to confirm that the issue has been resolved to their satisfaction. This helps
to rebuild trust and demonstrate commitment to customer service.
Similar process is applied in terms of other negative impacts like complaints, including warranty complaints. The approach
of handling complaints can however differ between corporate and retail customers. As corporate customers dominate in
terms of revenues ASBIS offers them:
• dedicated support: corporate customers often receive dedicated account managers who handle complaints and
provide personalized support,
• customized solutions: solutions for corporate customers may be more customized to meet their specific needs
and contractual agreements. These could include more time devoted to understanding the customers’ current and
future needs or on-site visits,
• long-term relationships: focus on maintaining long-term relationships and ensuring ongoing satisfaction through
regular follow-ups and proactive support.
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For retail end customers, who remain a minority at ASBIS, we offer:
• standardized processes: retail complaints are typically handled through standardized processes to ensure
consistency and efficiency. The customers can call, visit or email with their complaints. The complaints are
handled by the store managers and escalated, if necessary,
• customer service channels: retail complaints are managed through various customer service channels, including
phone, email and online support.
• quick resolutions: we focus is on providing prompt and effective solutions, assuring customer satisfaction.
3.3.6 S4-4 TAKING ACTION ON MATERIAL IMPACTS ON CONSUMERS AND END-USERS, AND
APPROACHES TO MANAGING MATERIAL RISKS AND PURSUING MATERIAL
OPPORTUNITIES RELATED TO CONSUMERS AND END-USERS, AND EFFECTIVENESS OF
THOSE ACTIONS
ASBIS takes several actions to address material impacts on consumers and end-users:
• preventive measures: implementation of rigorous quality control and testing protocols to ensure products are safe
and reliable before they reach consumers – ASBIS makes sure that producers of goods distributed do not use
improper chemicals or hazardous materials. We obtain the necessary certificates such as CE (Conformité
Européenne) and RoHS (Restrictions of Hazardous Substances). We have our own QA&QC (Quality Assurance
and Quality Control) team consisting of 31 employees located in China, Czech Republic and Cyprus, who conduct
all the required and necessary tests,
• remediation: addressing any negative impacts by providing prompt resolutions, such as product recalls,
replacements, or refunds,
• positive contributions: engaging in initiatives that positively impact consumers, such as offering educational
resources, enhancing product accessibility, and improving user experience.
In terms of managing material risks and pursuing opportunities ASBIS undertakes the following measures:
• risk identification and mitigation: regular assessment of potential risks related to product safety and data privacy,
implementation of mitigating measures such as robust security protocols and compliance with relevant
regulations,
• opportunity pursuit: identification and leveraging of opportunities to enhance product offerings and customer
satisfaction. This includes investing in innovative technologies, expanding service offerings, and improving
customer support,
• focus on effectiveness of actions: continuous monitoring the effectiveness of actions taken to address material
impacts and manage risks (e.g. tracking key performance indicators (KPIs)) and establishing channels for
consumers and end-users to provide feedback and raise concerns. Using this feedback to make informed
improvements and ensure actions are effective.
As a result of these actions, there were no reported severe human rights issues and incidents connected to its consumers
and/or end-users in 2024 and 2023.
3.3.7 S4-5 TARGETS RELATED TO MANAGING MATERIAL NEGATIVE IMPACTS, ADVANCING
POSITIVE IMPACTS, AND MANAGING MATERIAL RISKS AND OPPORTUNITIES
At ASBIS there are no such targets in terms of consumers and end-users.
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4 GOVERNANCE INFORMATION
4.1 G1 BUSINESS CONDUCT
4.1.1 GOV-1 THE ROLE OF THE ADMINISTRATIVE, SUPERVISORY AND MANAGEMENT BODIES
ASBIS is governed by Board of Directors which consists of executive and non-executive directors, whose powers,
obligations and remuneration is described in 1.1 section.
4.1.2 IRO-1 DESCRIPTION OF THE PROCESSES TO IDENTIFY AND ASSESS MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
Within the double materiality analysis, the majority of business conduct topics came in as material. These included:
corporate culture, protection of whistle-blowers, management of relationships with suppliers, including payment practices
and corruption and bribery. On top, within this section one entity-specific topic has been considered as material - data
security.
4.1.3 G1-1 – BUSINESS CONDUCT POLICIES AND CORPORATE CULTURE
ASBIS business conduct and corporate culture are built by these policies:
• Mission and Vision: Mission and vision of ASBIS are the guidelines by which the Board of Directors looks at the
Company and conducts business. These are communicated to employees and to external stakeholders. ASBIS’ vision
is to be the leading Value Add Distributor, OEM and Solutions Provider of IT, IoT, AI across CEE, FSU, MEA. The
Company’s mission is represented by 5 focus areas: 1) develop and Market IT, IoT, AI solutions, 2) gain expertise in
consultative business, 3) excel and leverage on distribution, 4) grow profitably own brands and 5) manage risks and
zero regulatory issues.
• ASBIS Values: The four values encompass:
1) Transparency – We follow high standards of integrity and maintain openness in communication, striving to build trust
with everyone we interact with at every stage of cooperation. We believe that a competent, motivated, well-trained and
diverse team will be able to deliver on ASBIS strategy and develop the Company.
2) Respect – We respect individuality, provide equal opportunities and encourage diversity in opinions and approaches
to work, creating an environment where people of different nationalities, cultures, religions, ages, and genders can feel
comfortable and engaged. We believe that a competent, motivated, well-trained and a diverse team will be able to
deliver on ASBIS strategy and develop the Company.
3) Partnership – We work with advanced technologies, but most importantly we work with people, so strong and
mutually beneficial relationships are the foundation of our success. We take pride in the team spirit of our employees,
their enthusiasm and skill, which we try to maintain knowing that together we can achieve great things.
4) Leadership – Strong leaders lead by example. We strive to be an example for others and help develop leadership
skills in our employees. Our desire to develop professional skills and personal qualities allows us to grow leaders whose
example inspires all team members and makes us stronger.
• Code of Conduct: ASBIS corporate culture is a unique one and it is being developed, promoted and evaluated on an
ongoing basis. The first element building the corporate culture is ASBIS Code of Conduct which sets forth general
guidance on how to carry out daily activities in accordance with ASBIS purpose and values, as well as in compliance
with the applicable legal requirements and ASBIS’s policies, standards and ethical principles. The Code includes 10
guiding principles which are straightforward points written in an easy to comprehend language and simple to follow for
all employees. These are: “We are honest”, “We are trustworthy”, “We promote diversity”, “We are team players”, “We
use good judgement”, “We are responsible”, “We stick to the law and our policies, “Never compromise on integrity”,
“Just say no” and “Select business partners carefully”. The Code of Conduct also encompasses ethical guidelines
which are to support employees in making the right choices. The Code applies to everyone at ASBIS worldwide. It
promotes an honest and ethical conduct, a safe working environment and compliance with all governmental directives,
laws, rules and regulations.
• HR Management Policy: Another aspect of developing, promoting and evaluating the corporate culture is ASBIS’
comprehensive HR Management Policy at the Group level which standardises processes related to Human Resources
and building of corporate culture. The HR Management Policy encompasses six key topics: hiring, team building,
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motivation, leadership, diversity and anti-mobbing. On top, it also addresses employer branding actions. The key
aspects of this policy are described in S1-2.
• Human Rights & Labor Policy which sets forth ASBIS’ global standards regarding The Code of Labour Practices.
This policy of labour practice sets forth minimum standards for working time and working conditions and provides for
observance of all of the core standards of the International Labour Organisation including other applicable Conventions.
The policy provides a pledge by the Company to observe these standards and to require its contractors, subcontractors
and suppliers to observe these standards. It also establishes ASBIS’ general responsibilities concerning human rights,
health management, work safety, career management, employees’ rights etc.
• Employment Standards and Global Supplier Standards cover company-owned operations as well as our supplier
partners. These policies describe the workplace practices and ethical behaviour that we require for all workers such
as: (1) prohibiting child and forced labour, (2) ensuring non-discrimination and equal opportunity, (3) supporting a
harassment-free and violence-free workplace, (4) prohibiting retaliation or any form of physical or mental disciplinary
practices, (5) respecting workers’ right to freedom of association, (6) ensuring compliance with laws governing working
hours and wages and (7) promoting environmental protection, health and safety.
• Whistleblowing Policy which allows employees and external stakeholders to anonymously raise concerns about
possible wrongdoing to the Board of Directors. Concerns must be reported in writing. They can be delivered either to
one of the executive directors or via a publicly available email on the webpage. It is ASBIS intention to treat all reports
seriously and assure appropriate investigation of each reported manner.
• Business Ethics Policy encompasses conflicts of interest. A conflict can take the form of a business relationship with,
or an interest in, a competitor or customer of ASBIS, or participation in sideline activities that prevent employees from
being able to fulfil their responsibilities at ASBIS. It is important that all employees recognize and avoid conflicts of
interest, or even the appearance of a conflict of interest, as they conduct their professional activities. Employees must
inform their supervisor of any personal interest they could possibly have in connection with the execution of their
professional duties.
• The Anti-bribery and Anti-corruption Policy is comprehensive. It outlines ASBIS policy in relation to sponsoring,
donations and memberships, specifies allowed practices in relation to gifts and hospitality and allowed behaviour in
during interactions with business partners and suppliers. On top, it also specifies how to report compliance violations,
how an investigative procedure looks like as well as disciplinary consequences of non-compliant conduct. The policy
is consistent with the United Nations Convention against Corruption.
We believe that thanks to time and effort taken to build the corporate culture:
• parent company obtaining the 'Great place to work' certification third year in a row,
• there were no monetary losses because of legal proceedings associated with labour law violations in 2024 and
2023,
• there were no monetary losses because of legal proceedings associated with employment discrimination
amounted to zero in 2024 and 2023,
• there was no need to create trade unions. At the end of 2024 there were no trade unions at ASBIS (stable YoY).
4.1.4 G1-2 – MANAGEMENT OF RELATIONSHIPS WITH SUPPLIERS
In frames of its value chain, ASBIS co-operates with a sizeable number of suppliers. The Company has long-term relations
with its suppliers based on mutual trust and understanding of mutual needs and constraints. Most of these are large
international companies (OEMs, private labels producers, other producers), with small and medium (SMEs) suppliers
consistently being a minority – thus the Company has no special policy in relation to SMEs. ASBIS emphasises fairness
and transparency in relations with all suppliers, regardless of their size and thus strives to provide these with full visibility
by reporting crucial information on a daily/weekly basis, including stock levels, sales-out reports by country. ASBIS assists
its suppliers in monitoring customer demand and allows them time to comprehend and react to specific market peculiarities.
In 2024, a significant portion of our revenues was generated from ten biggest suppliers, like in 2023. Yet, ASBIS believes
that it places no reliance on any of our suppliers since it carries for every product category a wide portfolio of brands. We
choose new suppliers based on the market trend demands.
Managing relationships with suppliers are crucial for ASBIS business model and value chain as those are the products
that are later on sold by ASBIS and thus generate revenues. There is no formal policy of selecting suppliers, yet to
guarantee uniform high standards in our supplier relationships, we impose a contractual obligation on our suppliers to
abide with our Code of Conduct. In addition to basic requirements pertaining to human rights, labour standards,
environmental protection and occupational safety, the Codes also require suppliers to comply with all relevant laws and
regulations and refrain from corruption. Other aspects taken into account include:
• demand for products offered by selected supplier,
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• dependency on the supplier and thus possible related business risks,
• ability to deliver the required volume in designated timeframe and risk of not fulfilling this obligation,
• pricing and payment terms,
• business conduct and transparency of the supplier.
As a result, essentially all revenues in 2024 and in 2023 were from products third-party certified to environmental and/or
social sustainability standards. Vast majority of ASBIS’ suppliers are RBA’s members which minimises ASBIS’ exposure
onto sustainability risks. In 2024, 91.2% of revenues (2023: 88.9%) came from suppliers that were RBA’s members. These
were large companies, mostly listed on NASDAQ, fulfilling ASBIS’ transparency criteria.
4.1.5 G1-3 – PREVENTION AND DETECTION OF CORRUPTION AND BRIBERY
ASBIS is against bribery and corruption, as these are illegal activities. The Company believes it is against the law to offer,
promise, give, request, agree, receive or accept bribes and we penalize such a behaviour and considers corruption an
obstacle to economic and social development around the world, that has a negative impact on sustainable development
and exposed communities. ASBIS also understands that any such actions if undertaken by our employees could negatively
affect the Company’s reputation.
ASBIS has a Business Ethics Policy which among others incorporates an Anti-bribery and Anti-corruption Policy. The latter
explains to employees that there can be two forms of bribery and corruption, an active and a passive one. An active one
in which a person is one who offers, gives or promises to give a financial or other advantage to another individual in
exchange for improperly performing a relevant function or activity. A passive one covers the offence of being bribed, which
is defined as requesting, accepting or agreeing to accept such an advantage, in exchange for improperly performing such
a function or activity. Both constitute a criminal offence and are not accepted by ASBIS.
The Anti-bribery and Anti-corruption Policy also explains to ASBIS employees that bribery and corruption can be conducted
for the benefit of a Company and for the benefit of a person. It can be tangible and intangible in nature. Tangibility means
that the benefit can be measured in cash (monetary), and it can be represented by e.g. presents, contracts, and sizeable
discounts for goods and services. Intangibility means that the benefit from the bribery can take the form of e.g. a promotion,
lower amount of work, hiring a friend or relative.
To make the matters of bribery and corruption more understandable to ASBIS employees, the Anti-bribery and Anti-
corruption Policy encompasses examples of most prevalent forms of these offences and indicates that breaches of laws
can not only result in sizeable ASBIS reputation loss but also in unlimited fines and imprisonment for individuals.
Apart from policies, there are procedures in place to detect and address bribery. There is a dedicated Risk Director and
team whose aim is to identify vulnerabilities and conduct due diligence on third parties. There are also internal controls in
place such as approval of workflows, segregation of duties and whistleblowing mechanism (described earlier). If incident
happens, it will be investigated (within 30 days) and Board of Directors and relevant corporate bodies will get informed.
To strengthen the anti-corruption and anti-bribery processes, ASBIS’ Business Ethics Policy also encompasses conflicts
of interest. A conflict can take the form of a business relationship with, or an interest in, a competitor or customer of ASBIS,
or participation in side-line activities that prevent employees from being able to fulfil their responsibilities at ASBIS. It is
important that all employees recognize and avoid conflicts of interest, or even the appearance of a conflict of interest, as
they conduct their professional activities. Employees must inform their supervisor of any personal interest they could
possibly have in connection with the execution of their professional duties.
Also, since November 2016, ASBIS has a formal policy in place which regulates hiring of family member at ASBIS. In the
case of intention of hiring family members in any of the legal entities of the Group, the following must apply:
• family members of 1st, 2nd degree and spouse or spouse equivalent may not be employed in the same
department unless approved by the company’s Board of Directors majority vote,
• a supervisor or manager may not be the direct or second level supervisor of a relative.
Moreover, the importance of prevention of any illegal activities is also underlined in ASBIS’ Vision. As a result, our Business
Ethics Code also addresses such important topics like fraud, anti-money laundering, anti-competitive behaviours, among
many others.
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4.1.6 G1-4 – CONFIRMED INCIDENTS OF CORRUPTION OR BRIBERY
Anticorruption and antibribery courses are mandatory to all newcomers and available at any time to any employee. These
define terms like bribery, corruption, conflict of interest, fraud and money laundering and explain the actions to be taken
when such violations occur or are revealed. They also describe the Company's policies on matters like anti-competitive
practices and fair marketing. In addition, in the Code of Conduct, employees are guided on how to perform their daily
activities in an ethical manner.
There were no confirmed incidents of corruption both in 2024 and in 2023. There have been no convictions for violation of
anti-corruption and anti-bribery laws both in 2024 as well as in 2023. The fines for violation of anti-corruption and anti-
bribery law amounted to US$ 0m (zero) in 2024 and 2023.
4.1.7 G1-6 – PAYMENT PRACTICES
For ASBIS relations with its suppliers are of key importance and ASBIS payment practices are aimed at keeping mutually
benefit and proper relations with suppliers. Essentially, all trade suppliers' invoices are paid within the week when the
payment becomes due. Non-trade suppliers, on average, are paid within 30 days of invoice receipt. Trade suppliers, who
constitute the vast majority of suppliers in terms of business volume, provide payment terms of 30 to 60 days. ASBIS does
not make a distinction for large and SME suppliers.
Payable outstanding days in 2023 came in at 49.2 days, while at 55.9 days in 2024. The Company had no outstanding
legal proceedings for late payments both in 2024 and 2023. ASBIS did not have late payments to SMEs in 2024 and 2023
and thus has not negatively affected the businesses of SMEs with which it cooperates.
4.1.8 ENTITY-SPECIFIC TOPIC – DATA SECURITY
Information security is a material topic for ASBIS and is treated as an entity-specific topic. Information security is managed
by the Security Committee. There are policies and best practices in place that aim to minimize data security risks. Some
of them are the "principle of least privilege" per service account and the "single entry point" applied to most of IT services.
In addition, the implementation of "2-factor authentication" to our IT services was finished in 2021, which further increased
data security. Moreover, our high availability (HA) setups are based only on enterprise grade solutions inclusive of vendor
support. Monitoring and notification systems help us track any abnormal activity and respond quickly when necessary.
Currently, data security risks are addressed on an ad-hoc basis by the IT department, mostly as breach prevention. The
IT department deploys and supports its systems and services according to the known best practices. They monitor the
integrity, productivity and user feedback. Any serious issues are reported to the IT management. If the issue is considered
a data security incident, it is escalated to the Information Security Engineer. The most significant incidents are reported to
the Security Committee.
The Security Committee was established in November 2021 to manage the information and data security within the ASBIS
Group. In 2024, similarly as in 2023, there were no data breaches, no incidents involving personally identifiable information
(PII) and no customers were affected in any way (all zero for 2023 as well).
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