Pwint Thit Sa

Transparency in Myanmar Enterprises

Seventh Report | 2022

MCRB: info@myanmar-responsiblebusiness.org | www.mcrb.org.uk | www.mcrb.org.mm

Yever: + 95 9 422 091 979 | contact@yever.org | www.yever.org

Pwint Thit Sa is intended to encourage better corporate governance

and increased transparency by Myanmar businesses.
© Copyright Myanmar Centre for Responsible Business (MCRB) and Yever, February 2023. Published
by MCRB and Yever. All rights reserved. MCRB and Yever permit free reproduction of extracts from
this publication provided that due acknowledgment is given and a copy of the publication carrying the
extract is sent to MCRB or Yever. Requests for permission to reproduce and translate the publication
should also be addressed to MCRB or Yever. Media and analysts are requested to credit both MRCB
and Yever when referencing this report.

The Myanmar Centre for Responsible Business (MCRB) was set up in 2013 by the Institute of Human
Rights and Business, and the Danish Institute for Human Rights. It has received funding from several
donor governments including UK, Denmark, Norway, Switzerland, Netherlands, and Ireland. Based out
of London since 2023, MCRB continues to provide a trusted and impartial platform for the creation of
knowledge, building of capacity, undertaking of advocacy and promotion of dialogue amongst businesses,
civil society, governments, experts and other stakeholders, with the objective of encouraging responsible
business conduct throughout Myanmar. Responsible business means business conduct that works for
the long-term interests of Myanmar and its people, based on responsible social and environmental
performance within the context of international standards.

Myanmar Centre for Responsible Business

info@myanmar-responsiblebusiness.org
www.mcrb.org.uk and www.mcrb.org.mm
Legacy website: www.myanmar-responsiblebusiness.org

Based in Yangon, Yever is a consultancy offering custom-made solutions to corporate leaders.

Yever aims to foster their company’s business transformation while building their market leadership
responsibly and sustainably. We support Myanmar organisations in their journey and provide them
support to enhance their corporate governance and disclosure, strengthen their performance, and
develop sound management practices. Established in 2016, our team combines Myanmar talents
and international expertise. Purpose-driven, we aim to walk the talk: we are the only B Corp certified
company in Myanmar and are proud to contribute pro bono for various projects.
Yever
www.yever.org

The views expressed in this publication are those of the authors. The mention of specific companies
does not imply that they are recommended by MCRB or Yever. The ranking is not intended to make
judgments to the business performance of companies.
The information provided in this report does not, and is not intended to, constitute legal advice;
instead, all information, content, and materials are for general informational purposes only. Information
in this report may not constitute the most up-to-date legal or other information. Users should contact
their lawyer to obtain advice with respect to any particular legal matter.

Cover photo: Firewheel (Gaillardia pulchella) by Svetlana Zens

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TABLE OF CONTENTS
—
ABBREVIATIONS 4

EXECUTIVE SUMMARY 5

METHODOLOGY 11
Assessment Criteria 11
Scoring 12
Selection of Participants 13
Companies and Groups 13
Assessment Timeline and Company Engagement 13
Limitations of the Research Methodology 14

RESULTS 14
The quality of the disclosure has improved 14
Disclosure need not be a challenge for SMEs 16
Banks still need to make more effort to comply 16
Regulators need to guide companies on disclosure, and enforce compliance 17
Dialogue is crucial to foster better practices 17
Disclosure needs to be more strategic and more focused on material information 17
More companies are using international reporting frameworks and standards 17
ESG reporting remains weak 18

ANNEX 1: CRITERIA ASSESSED 20

FIGURE 1: Range of scores, 2020 and 2022 by category 9

FIGURE 2: Evolution of Corporate Transparency in Myanmar Enterprises between 16

2018 and 2020
BOX 1: The MCRB and Yever Partnership 6

BOX 2: Pwint Thit Sa and the Sustainable Development Goals (SDGs) 7

TABLE 1: Evolution of average scores 9
TABLE 2: Criteria used in the 2022 scoring system 12
TABLE 3: Top 30 Companies in Pwint Thit Sa 2022 15
TABLE 4: Evolution of the number of companies referencing international standards 18
TABLE 5: Environmental and social topics disclosed by companies 19

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ABBREVIATIONS
—

ACGS ASEAN Corporate Governance Scorecard

ACMF ASEAN Capital Markets Forum
ASEAN Association of South East Asian Nations
BoD Board of Directors
CG Corporate Governance
CSR Corporate Social Responsibility
DICA Directorate of Investment and Company Administration
ESG Environmental, Social and Governance
FY Financial Year
GRI Global Reporting Initiative
IFRS International Financial Reporting Standards
IIRC International Integrated Reporting Council
KPI Key Performance Indicator
MCGS Myanmar Corporate Governance Scorecard
MCRB Myanmar Centre for Responsible Business
MSDP Myanmar Sustainable Development Plan
SASB Sustainability Accounting Standards Board
SECM Securities and Exchange Commission of Myanmar
SEE/SOE State-owned Economic Enterprise
YSX Yangon Stock Exchange

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EXECUTIVE This is the seventh Pwint Thit Sa1/Transparency in Myanmar Enterprises
SUMMARY (TiME) report. It assesses information disclosure on the corporate websites
— of over 250 large Myanmar companies. It examines publicly listed and
‘public’ companies, and privately-owned companies which are influential
or significant taxpayers, significant state-owned economic enterprises
(SEEs), as well as smaller companies which volunteered for inclusion. The
objective of Pwint Thit Sa is to incentivise greater publication of corporate
governance (CG) and other information by Myanmar companies through
publicly recognising them for their disclosure and transparency. It remains
the most extensive public report published about the state of corporate
disclosure (CD) in Myanmar.
MCRB published its first report in July 2014, and further reports were
published in 2015, 2016, 2018, 2019 and 2020. Since 2018, the report
has covered an expanded number of companies, and used criteria aligned
with the emerging corporate governance agenda in Myanmar, and specifically
the ASEAN Corporate Governance Scorecard (ACGS).
As in 2018, 2019 and 2020, this report has been jointly authored by MCRB
and Yever, whose contribution is pro bono (see Box 1).
Pwint Thit Sa remains one of MCRB’s most popular reports, with just under
6,000 downloads of the 2020 report in English (compared to just under
8,000 for the 2019 report) and over 1,500 of the Myanmar Executive
Summary. It was also viewed 2,000 times on the Yever website.
Pwint Thit Sa has served as a reference point for international organisations
and companies conducting due diligence. High-scoring Myanmar companies
have publicised it in their annual reports and websites. Furthermore, some
banks and other institutions use a company’s Pwint Thit Sa ranking as one
factor to assess risks before granting loans or providing financing.
International investors, banks, and business partners are currently conducting
enhanced due diligence on Myanmar entities, not least as a consequence
of Myanmar’s addition to the Financial Action Task Force (FATF) ‘black list’
in October 2022.2 Myanmar companies and businesses that are ready and
able to provide those business partners with governance information will
have a business advantage. Disclosure is also important to maintain the
trust of shareholders and stakeholders, who are increasingly focussed on
‘ESG’ (Environment-Social-Governance) and sustainability performance,
both at international and ASEAN level. Good corporate governance and
corporate disclosure are therefore ultimately essential for accessing finance,
sustaining business, and safeguarding jobs.
The 2022 report continues the methodological approach adopted since 2018
by drawing heavily on the ASEAN Corporate Governance Scorecard (ACGS)
(Table 3), using 71 of its most relevant criteria. The ACGS was developed
by the ASEAN Capital Markets Forum, of which Myanmar’s Securities and
Exchange Commission is a member. It is used widely in the region to assess

1 Pwint Thit Sa means ‘new blooms’ (and figuratively, ‘new talent’). The name was
chosen to reflect the emergence of transparency and corporate governance practices
in Myanmar after 2012.
2 High-Risk Jurisdictions subject to a Call for Action, Financial Action Task Force, 21
October 2022

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 BOX 1:

The MCRB and Yever Partnership

Who is Yever? Yever is an independent and purpose-driven business consultancy, which
aims to enable Myanmar business leaders to embrace more responsible and sustainable
practices. In 2018 MCRB decided to join forces with this new Myanmar-based business
sustainability consultancy, whose Director, Nicolas Delange, had been conducting a
similar private benchmarking exercise of sustainability reporting indicators of Myanmar
companies for several years. Nicolas Delange has also supported the IFC on the SECM
corporate governance scorecard initiative, and worked for IFC as a consultant on corporate
governance between November 2017 and February 2021.
Respective roles: As in 2018, 2019 and 2020, for Pwint Thit Sa 2022, MCRB managed the
relationships with the companies that were analysed during the project. Yever performed
the assessment for each company (on a pro bono basis, which included around 250 days
of pro bono work), and compiled the feedback on draft scores. MCRB and Yever then
provided this to the companies, and where companies asked for it, provided pointers for
improvement.
Conflict of Interest Declaration: Yever provided paid consultancy services in 2021 and
2022 to five companies included in the Pwint Thit Sa 2022 report. These are City Mart
Holdings Limited, KBZ Bank, Maha, Myanma Awba Group and TMH. To avoid conflict of
interest, their final scores were independently checked by MCRB.
All companies, regardless of whether or not they were current or former Yever clients,
were provided with the same information and the same offers of dialogue and deadline
extensions where requested.
Practice what you preach: Yever benchmarked its own disclosed information against the
same criteria as the companies. MCRB’s overall score is 29% (17% in 2020) equivalent
to 26th; the improvement was driven by the disclosure of MCRB’s Communication on
Engagement to the UN Global Compact in August 2022. Yever’s overall score of 52%
(16% in 2020) places them 12th. Yever disclosed its strategy, policies and sustainability
dashboard on its website.
Although the survey questions were designed for large enterprises, these scores show
that many of the disclosure criteria for the ASEAN CG Scorecard can be applicable even to
micro-enterprises (Yever has 16 staff). Yever is also the only certified B Corp member in
disclosure3
Myanmar, demonstrating its own commitment to sustainability and disclosure3.

disclosure of corporate governance by large companies. It was also used in 2018/19 by

Myanmar regulatory bodies to develop a Myanmar Corporate Governance Scorecard to assess
the current corporate governance practices of 24 large Myanmar companies.4 More and more
Myanmar companies are adopting it as a disclosure framework (nine, compared to eight in
2020, and three in 2019). This demonstrates the influence of Pwint Thit Sa in encouraging
companies to align to appropriate international frameworks.
3 www.bcorporation.net/en-us/find-a-b-corp/company/yever
4 Myanmar Corporate Governance Scorecard 2018: A Report on the Assessment of Myanmar Companies,
International Finance Corporation (IFC), April 2019

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However not all ACGS criteria have been used for Pwint Thit Sa and the methodology also
sources from other international standards. Since 2019, some additional performance criteria
concerning sustainability and its relationship to the company’s business model have been
added, aligned with the Integrated Reporting Framework <IR>. This is intended to challenge
and stretch the leading companies, and reflect and support the Myanmar Sustainable
Development Plan and Myanmar’s achievement of SDGs 12 and 16 (see Box 2).

BOX 2:

Pwint
2018 Sa and the
Thit Sustainable
Myanmar Sustainable
Development Plan5 Development Goals (SDGs)
Number of companies publishing sustainability reports6
Pwint Thit Sa is intended to support the implementation of the 2018 Myanmar
such as GRI, SASB and IFRS.7 5
Sustainable Development Plan and in particular business’ contribution to Sustainable
Development
national level to Goal (SDG)
measure 16:
progress 8

• SDG 16: Promote peaceful and inclusive societies for sustainable development,
provide access to justice for all and build effective, accountable and inclusive
institutions at all levels;
• SDG 16.5: Substantially reduce corruption and bribery in all their forms;
• SDG 16.6: Develop effective, accountable and transparent institutions at all levels.
By promoting coordination of capacity-building efforts and enhancing policy coherence,
and partnerships, it also directly supports SDG 17 (global partnerships for sustainable
development, capacity building, policy coherence and public-private dialogue). Indirectly it
supports all SDGs, since businesses with good corporate governance and sustainability
practice can contribute to the realisation of all the Goals.
Furthermore, corporate disclosure supports SDG 12 (Ensure sustainable consumption
and production patterns) and specifically SDG Indicator 12.6.1 – Number of companies
publishing sustainability reports.6 This is the only one of the 231 SDG indicators which
monitors the practices of private sector entities. Given the varied approaches and
quality of corporate sustainability reports, a methodology is being developed globally to
establish a minimum requirement for sustainability reports, as well as advanced level.
This will be based on international standards such as GRI, SASB and IFRS.7 Countries
will be able to use this at national level to measure progress.
Pwint Thit Sa aims to incentivize uptake of international sustainability reporting standards
in Myanmar, and thereby national progress against SDG Indicator 12.6.1.8

The scoring methodology once again assesses four dimensions - Corporate Profile, Corporate
Governance, Sustainability Management and Reporting – using 151 criteria (83 disclosure-
based, 68 performance-based) with a maximum possible score of 219 (83 Disclosure,
136 Performance). This year a few additional criteria were added related to the COVID-19
pandemic and ongoing political crisis. A few which were not considered meaningful were
dropped. Furthermore, the scorecard aimed this year to reward companies that embraced a
5 Myanmar Sustainable Development Plan 2018-2030, August 2018
6 SDG Indicators Metadata Repository, United Nations Statistics
7 Background on recent consolidations of reporting standards is available from the newly formed IFRS
Foundation.
8 The Myanmar SDG Indicator Baseline Report, 2017 Myanmar Central Statistical Office and UNDP identified
the value of this indicator as zero in 2016.

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 more holistic and comprehensive approach to disclosure: a compliance-driven approach to
Pwint Thit Sa was therefore not sufficient to secure the maximum score possible.
For most companies in this study, with the exception of those who are publicly listed and ‘public
companies’9 with more than 100 shareholders and banks, there is no legal requirement to
disclose any of this information on their website under Myanmar law. However, to do so can
help a company to obtain a competitive edge with potential business partners and investors
whose first research on a company may involve looking at their website.
This year, the methodology has been further strengthened to distinguish between where
companies have a legal obligation to disclose and where private companies are choosing
to do so. To incentivize disclosure beyond compliance, bonus points were added where
companies volunteered to disclose information such as financial statements. Further details
are in the Methodology section.
Results show that the average score in 2022 was 8% compared to 7% in 2020: overall
disclosure has slightly improved, with some leading companies rising to the challenge of
disclosing more data related to Corporate Governance (CG), sustainability management and
reporting on their performance.
The three companies in 2022 which score highest on corporate disclosure are CityMart
Holdings Limited (CMHL), uab and FMI (First Myanmar Investment). The Top 30 companies
are listed in the Results section.
CMHL, uab and FMI were in the Top 5 of the 2020 Pwint Thit Sa report. But all of them have
made added efforts in Pwint Thit Sa 2022 to enhance disclosure, particularly on corporate
governance, sustainability and non-financial reporting. So did the 39 companies who opted to
meet (virtually) with MCRB/Yever to discuss their draft scores or to gain a better understanding
of the criteria and what they mean for company disclosure. This direct engagement process
helped them to improve their score by 68% on average. Table 1 shows the overall evolution
of the scores, for each category.
Listed companies, which scored average 40%, are outperforming public (6%) and private
companies (8%). However, the variance within each category is significant: Figure 1 shows,
for each type of company, the maximum, minimum and mean scores in 2020 and 2022.
A comparison of scores between the years shows that average score by category mostly
improved, except for SEEs and public companies whose scores remain stable compared
to 2020. For the banks, despite a more stringent assessment, the average score slightly
increased, by 1 percentage point.
Figure 1 also shows that the highest performing company (City Mart Holdings Limited) is one
which is privately owned, rather than listed or public. It is also not a bank. It therefore has no
mandatory disclosure obligations. This shows that some private companies actively choose
to measure and disclose significant quantities of corporate governance and performance
information, believing it is in their business interest. Furthermore, some privately owned
companies have made significant progress against tough competition and now rank in the
Top 20 such as Myanma Awba Group (up 20 places) and AYA Bank (up 11 places).

9 MCL S.1.xxviii defines a “public company” (or Public Limited Liability Company) as a company incorporated
under the MCL, or under any repealed law, which is not a private company. A ‘public company’ can issues
shares to the public. It must have at least 7 shareholders/members (no maximum number), and at least
3 directors, at least one of whom must be a Myanmar citizen, ordinarily resident in Myanmar (MCL S.4(a)
(vi)). It must also apply for a Certificate of Commencement of Business before its operations begin.
Generally public companies in Myanmar are not foreign owned, although the provision in the 2017 MCL
to allow a foreign shareholding of up to 35% may change that.

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 TABLE 1 - EVOLUTION OF AVERAGE SCORES

Pwint Thit Sa

assessment

Final result
companies
Number of

compared
after first

to 2020
in 2022

Change
2022 –
Score
2020
Overall average score 271 7% 6% 8% +1%
Top 10 10 70% 68% 73% +3%
Publicly Listed Companies 7 39% 36% 40% +1%
Banks 31 12% 10% 13% +1%
Insurance companies 12 N/A 6% 7% New
Privately owned companies 185 7% 6% 8% +1%
Public companies 51 5% 5% 5% 0%
State-owned enterprises 28 2% 2% 2% 0%

FIGURE 1:
Range of scores, 2020 and 2022 by category

Despite multiple challenges in 2021 and 2022, some Myanmar companies did their best
not only to maintain the quantity and quality of their disclosure, but increase it: in the 2020
report, companies had to score at least 16% to be in the Top 30: in this edition, they had to
achieve at least 22%. This increase of 6 points is significant and encouraging, as it indicates

9
 that Myanmar companies increasingly understand that sharing information is valuable to
them, and helps them obtain and maintain the trust of their stakeholders.
The main area of strength amongst the leading companies is Corporate Governance, with an
average score of 99% for the top 10 (bonus points for private companies voluntarily disclosing
on specific dimensions which are mandatory for banks and public companies explain the
scores above 100%). The weakest areas are Reporting and Sustainability Management, each
with an average score of 67% for Top 10 companies, compared to 56% and 55%, respectively,
in 2020.
However, not all Myanmar companies understand the importance of transparency. Of the
271 companies and SEEs surveyed, 111 (41%) do not have a corporate website or do not
disclose anything at all. Even where companies do have websites, many of them publish little
or no data relating to the criteria covered in this survey. Of those companies which disclosed
corporate information (including SEEs), another 41% of those assessed scored less than the
overall average score of 8%.
As ever, this survey and the ranking it produces is limited by the fact that it only uses
publicly available information provided by the companies. It does not assess the quality or
detailed performance of the company or the accuracy of the data, something which requires
the assurance of an independent expert audit. To combat the risk of companies adopting a
tickbox or cut-paste approach, more marks were given for some criteria relating to policies
and sustainability to reflect how closely a company’s policy commitment was genuinely
aligned to the business. Furthermore, MCRB and Yever’s direct engagement with companies
suggested that those who have higher scores are also those developing a stronger corporate
governance culture and understanding of sustainability.
There has been little to report concerning policy and regulatory developments in corporate
governance and disclosure in Myanmar over the last two years, so the 2022 Pwint Thit Sa
report does not include an update on this, unlike previous reports. Nor does it cover the many
emerging issues at the international level, including on ESG reporting and standards field,
and regulatory requirements for due diligence.
The 2022 report also does not make Recommendations to companies, government or the
Yangon Stock Exchange. However much of the content of the 2020 Pwint Thit Sa report,
including the regulatory framework for disclosure, and the previous Recommendations,
remain relevant at the time of publication of the 2022 report.10
In 2023, MCRB and Yever plan to continue to support interested companies to improve their
policies, reporting, disclosure, and website accessibility – including for persons with disability
– and to complement the training provided by the Myanmar Institute of Directors on corporate
governance. A further Pwint Thit Sa report may be produced in 2024.
 

10 Pwint Thit Sa/Transparency in Myanmar Enterprises 2020 report, Myanmar Centre for Responsible
Business and Yever, 3 December 2020

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METHODOLOGY To keep pace with changes in corporate disclosure practices, the methodology
— and indicators are reviewed prior to each edition of Pwint Thit Sa (PTS) to
ensure its ongoing relevance. For the 2022 edition the number of criteria
and their distribution is almost identical to that of 2020 (Table 2). However,
specific changes were implemented to reflect differences between mandatory
disclosure and voluntary disclosure.
As with previous editions, PTS 2022 has been structured using relevant
criteria from:
• the ASEAN Corporate Governance Scorecard with a focus on the Role
of Stakeholders; Disclosure and Transparency; and Responsibilities
of the Board.
• the Global Reporting Initiative (GRI) Standards and the Integrated
Framework with a focus on sustainability management and reporting.
PTS scoring methodology assesses the quality of the corporate disclosure
of significant Myanmar companies, where:
• “quality” can be understood as the capacity for a company
to provide material information on its strategy, governance,
management and performance on Environmental, Social and
Governance (ESG) topics. No assessment is made of the reliability
and sincerity of the information.
• “corporate disclosure” pertains to all publicly available information,
such as data, documents and information disclosed on websites
and other communication channels such as social media. No non-
public information was considered as part of the process.
• “significant Myanmar companies” refers to the companies that
meet at least one of the following conditions:
• listed on the Yangon Stock Exchange
• a public company with more than 100 shareholders recognised
as such by the SECM
• one of the top 100 tax payers for commercial and/or corporate
income tax
• a bank
• a SOE operating in the extractive, energy, financial or logistics
sector
• a prominent or influential company
• a company that has volunteered to be included.

ASSESSMENT PTS 2022 uses 151 criteria to assess companies (see annex). These
CRITERIA are grouped into 4 categories: corporate profile; corporate governance;
— sustainability management and reporting.
Following the 2019 and 2020 reports, some companies commented that
the scorecard offered an unfair advantage to listed and public companies,
since the scoring system covered information that was mandatory for them
to report. This meant that companies that had to comply with laws and

11
 regulations were treated in the same way as companies that voluntarily
decided to disclose this information.
For PTS 2022, the scoring system has been adjusted so that all types of
companies could earn the same number of points on 122 of the 151 criteria.
However the remaining 29 indicators offered privately-owned companies,
and state-owned economic enterprises an opportunity to get bonus points
for disclosing information voluntarily and not because it was a requirement
under the various legal and regulatory frameworks. Therefore, using the PTS
scoring system, the maximum points attainable for companies in this group
was 184 points.
Table 2 summarises the differences between the two categories in term of
scoring.

TABLE 2 – CRITERIA USED IN THE 2022 SCORING SYSTEM

Perfor-mance
Performance

- Disclosure
Disclosure

Bonus –
Bonus
Pillar

Total
Type

Corporate Profile 15 9 — — 24
Corporate Governance 39 6 — — 45
Listed/Public/
Sustainability
Banks/ 18 25 — — 43
Management
Insurance
Reporting 11 28 — — 39
Total 83 68 0 0 151
Corporate Profile 13 7 2 2 24
Corporate Governance 18 2 21 4 45
Private/
Sustainability
State-owned 18 25 0 0 43
Management
Enterprise
Reporting 11 28 0 0 39
Total 60 62 23 6 151

SCORING For the disclosure criteria, each criterion is weighted equally, using YES = 1
— point and NO = 0 points. To receive a point, the disclosure of the information
needed to be sufficiently clear and complete and should be easily identifiable
as officially established by the company, and accessible for the reader. It
also needed to be up to date and, in the case of annual reports, not more
than two years old.
For the performance criteria, a YES scored 2 points. For Q71, 74, 78, 98 and
99 a scaling system was introduced to assess the alignment of companies’
practices with international standards. Companies which disclosed recent
information covering their overall business scored more points than

12
 companies only disclosing information about part of their business. The
total score for a company was then calculated by adding the score for each
of the 151 criteria.

SELECTION OF PTS 2022 assessed 271 companies of which 31 are banks. These include:
PARTICIPANTS
• 7 companies listed on the Yangon Stock Exchange (YSX), of which 2
— are banks
• 45 public companies – of which 8 are banks – identified by the SECM as
regulated by them because they have more than 100 shareholders11
• 191 privately owned companies – of which 17 are banks – who either:
• paid significant commercial and/or Income tax according to the
latest top 1,000 Myanmar companies taxpayers list issued by the
Internal Revenue Department
• are well-known or influential in Myanmar, or
• volunteered to participate
• 28 State-owned Economic Enterprises (SEEs), of which 4 are banks.

COMPANIES AND The word “Group” in Myanmar is used inconsistently, with some entities
GROUPS operating as a registered Group or Holdings entity with a clear legal structure,
— while others form a loose alliance of companies and call themselves a
Group without a legal registration as a single entity. Companies in the latter
category were given the option of being assessed as a whole group entity or
by their individual companies. All banks were assessed separately from any
‘group’ they might be associated with.

ASSESSMENT • September 2021: webinar to explain methodology, advertised through

TIMELINE AND all MCRB/Yever communication channels, and with invitations sent
COMPANY by email and mail (where this information was publicly available) to
ENGAGEMENT companies to be included in PTS 2022.
— • October 2021: first assessment of publicly disclosed information
commences
• January 2022: draft scores shared with companies in hard copy and
by email
• February 2022: webinar used to share results, with companies invited
to meet individually to discuss their draft scores and receive specific
feedback on how to improve their disclosure. Thirty-nine companies
met with the assessment team.12
11 The current list is available at secm.gov.mm/en/public-companies/ Pwint Thit Sa
2022 surveyed those on the SECM’s list in early 2022
12 MCRB/Yever met with: A Bank, Amata Holding Public, Asia World, Authentic Group,
AYA Bank, Ayeyar Hinthar, AYA Sompo, City Mart Holding, Dagon Group, Europe &
Asia Commercial, Ever Flow River, Excellent Fortune Development, First Myanmar
Investment Public (FMI), First Private Bank, Kanbawza Bank, IKBZ Insurance, KMD,
Maha Agriculture Microfinance, Mandalay Myotha Industrial Development Public, Max
Myanmar, Mya Ayer, Myanma Awba, Myanma Tourism Bank, Myanmar Oriental Bank,
Myanmar Thilawa SEZ Holdings Public, Myeik Public Corporation, Peace Myanmar

13
 • May 2022: last opportunity to finalise the disclosure of information.
However, up to three more months were given to those who requested
it due to late updating of websites or due to a late decision for
voluntary inclusion.
• December 2022: finalisation of scores by Yever with cross checking
performed by MCRB including of Yever’s clients to avoid any potential
conflicts of interest (see Box 1). No discrepancies were identified
during these checks.

LIMITATIONS OF As with any corporate governance assessment based on publicly available

THE RESEARCH information there are limitations in the questionnaire and ranking of
METHODOLOGY Myanmar companies. This Research Methodology simply assesses whether
— the information has been disclosed and is sufficiently clear and complete.
As the method relies on publicly available information via the internet,
policies or reports that are only available in hard copies are not captured
in the assessment. Furthermore, although an attempt has been made in
Pwint Thit  Sa 2022 to assess the quality and implementation of policies,
in particular through the introduction of the points scale described above,
and assess the accuracy of the information, it remains the case that
unless audited by a reliable auditor, the reliability of the information is still
dependent on self-disclosure.

RESULTS Table 3 (overleaf) lists the Top 30 companies for corporate disclosure out of
— the 271 assessed.

THE QUALITY OF On average, the average score of the 271 companies was 8% in 2022,
THE DISCLOSURE compared to 7% in 2020 (Figure 2). All categories improved their average
HAS IMPROVED scores between 2020 and 2022 except for SEEs and public companies
— which remained stable. SEEs are still the worst-performing category of
companies.
This increase of 1 percentage point in the overall average score is material
as more companies were assessed in 2022. The 2022 scorecard was also
more demanding: one indication of this was that companies that appeared
not to have updated their disclosure since 2020 lost on average at least 25
points.
Furthermore, although companies had to deal with multiple challenges in
2021 and 2022, the average score for the Top 10 grew significantly from
70% to 73%. The score of the top performer was 89% in 2022 (CMHL). (In
2020 it was 96% (uab); the change in methodology which favoured private
companies with no mandatory disclosure requirements was one factor
contributing to the reduction in uab’s score, since uab is a bank).

Group, Proven Group, Shwe Bank, Shwe Taung, Smart Technical Services, SME
Development Bank, Suntac Engineering & Construction, Supreme Group, TMH, uab,
UPG, Zaw Gyi Premier, Zega Finance.

14
TABLE 3 – TOP 30 COMPANIES IN PWINT THIT SA 2022

Sustainability
Management
Governance

Reporting
Corporate

Corporate
2022

2020
Rank

Rank
Company Name Type SCORE

Profile
1 2 CITY MART HOLDING (CMHL) PR 93% 145% 84% 73% 89%

2 1 UAB BANK PR 73% 90% 85% 81% 82%

2 5 FIRST MYANMAR INVESTMENT (FMI) L 100% 84% 88% 66% 82%

4 6 MAX MYANMAR GROUP PR 96% 164% 60% 65% 79%

5 3 SHWE TAUNG GROUP PR 74% 91% 72% 75% 75%

6 20 MAHA AGRICULTURE MICROFINANCE PR 85% 118% 60% 54% 68%

7 4 YOMA BANK PR 79% 67% 55% 73% 66%

7 7 KBZ BANK PR 79% 76% 56% 65% 66%

9 29 MYANMA AWBA GROUP PR 81% 77% 55% 67% 65%

10 11 MYANMAR AGRO EXCHANGE PUBLIC (MAEX) P 76% 75% 51% 50% 60%

11 9 TMH TELECOM PUBLIC L 100% 53% 32% 67% 58%

12 12 KMD PR 96% 82% 35% 36% 49%

13 18 PROVEN GROUP PR 70% 95% 37% 34% 47%

14 25 AYEYARWADY BANK (AYA BANK) PR 52% 45% 37% 56% 46%

15 8 MYANMAR THILAWA SEZ HOLDINGS (MTSH) L 64% 55% 42% 27% 43%

16 15 ALPHA POWER ENGINEERING PR 56% 23% 32% 47% 39%

16 10 DAGON GROUP PR 85% 55% 41% 15% 39%

16 17 IGE GROUP PR 70% 105% 29% 16% 39%

19 23 AUTHENTIC GROUP PR 67% 59% 26% 34% 38%

20 13 SMART TECHNICAL SERVICES PR 56% 55% 29% 30% 36%

21 26 AMATA HOLDING PUBLIC L 79% 53% 16% 14% 33%

21 36 MYA AYER PR 74% 27% 26% 27% 33%

21 16 MYAN SHWE PYI TRACTORS (MSP CAT) PR 59% 23% 24% 37% 33%

24 24 EVER FLOW RIVER (EFR) L 58% 35% 34% 17% 32%

25 33 GREAT HOR KHAM P 61% 49% 18% 17% 31%

MYANMAR AGRIBUSINESS PUBLIC
26 21 P 48% 27% 30% 14% 27%
CORPORATION (MAPCO)
MANDALAY MYOTHA INDUSTRIAL
27 49 P 73% 27% 14% 10% 24%
DEVELOPMENT

28 19 GRAND GUARDIAN INSURANCE PR 36% 16% 21% 27% 23%

AYEYARWADDY FARMERS' DEVELOPMENT BANK
28 28 P 30% 22% 21% 24% 23%
(A BANK) 15

30 31 UNITED PAINTS GROUP (UPG) PR 41% 18% 14% 25% 22%

 FIGURE 2:
Evolution of average scores in the 2019, 2020 and 2022 reports

DISCLOSURE The 20 companies that volunteered to be included are privately-owned SMEs

NEED NOT BE A which would not be included in another category. Four of these made it to
CHALLENGE FOR the Top 20. This demonstrates that companies in Myanmar of all sizes
SMES can adopt good governance and corporate disclosure practices, particularly
— when they receive clear guidance and support from initiatives such as
Pwint Thit Sa, the Myanmar Institute of Directors (MIOD) and the Myanmar
Private Equity and Venture Capital Association (MPEVCA).13 Getting this right
in the start-up phase will be essential for securing future funding for growth,
particularly at a time of increased focus by investors on ‘ESG’ investing and
reporting.

BANKS STILL Three banks, all privately owned, are again in the Top 10 this year (uab,
NEED TO MAKE Yoma, KBZ). The average score of the Banks slightly improved from 12% in
MORE EFFORT TO 2020 to 13% despite a more stringent methodology. However, the spread
COMPLY of the Total Score for Banks is from 0% to 82% (uab bank), despite all of
them being subject to the same regulatory requirements under the Financial
—
13 For more details see myanmariod.com and mpevca.org

16
 Institutions Law.
Three years after the Central Bank of Myanmar issued Directive 10/2019
which requires all banks to publish an annual report and audited financial
statements, a significant number of banks are still failing to do so. This
includes some banks which are public with more than 100 shareholders, and
therefore also subject to similar SECM regulatory disclosure requirements.

REGULATORS Only five of the seven publicly listed companies on Yangon Stock Exchange,
NEED TO GUIDE and five of the 45 public companies with more than 100 shareholders who
COMPANIES ON are subject to SECM oversight are ranked in the top 30 (see Table 3). These
DISCLOSURE, findings are consistent with the third Annual Report of the Securities and
AND ENFORCE Exchange Commission of Myanmar (SECM)14. This notes that only 14%
COMPLIANCE of listed and public companies fully comply with Notification 1/2016 on
continuous disclosure. For the second time, the SECM has also individually
—
rated each company’s compliance as Good, Acceptable or Insufficient. Clear
and relevant guidance on disclosure and enforcement of compliance by the
companies they oversee is necessary from all regulators.

DIALOGUE IS MCRB/Yever took time to meet with 39 companies between the first
CRUCIAL TO and second assessment and the briefings they received supported them
FOSTER BETTER in improving their corporate disclosure. On average, the score of these
PRACTICES companies went from 22% for their initial score to 34% for the final ones.
One volunteer company, Authentic Group, managed to improve its score by
—
184%, and another, Mya Ayer by 110%. Ten other companies managed to at
least double their score thanks to the guidance they received.

DISCLOSURE Only 3% of companies managed to clearly explain their goals and how they
NEEDS TO BE want to achieve them. Likewise, 6% of the companies detailed how they
MORE STRATEGIC are addressing risks but only 2% of the companies disclosed a materiality
AND MORE analysis where the outcomes are articulated with business issues/priorities.
FOCUSED ON Listed and public companies should improve their disclosure on these
MATERIAL matters are they are essential for shareholders and market players.
INFORMATION
Disclosures varied in their depth and completeness. On corporate governance,
— 26% stated that they had a Board of Directors, but only 22% disclosed the
actual number of Directors, 13% the responsibilities of the Board and 8%
the duties of the chairperson.

MORE Companies should also make use of international reporting frameworks

COMPANIES that are robust and facilitate the comparability of the performance with
ARE USING their peers. The table overleaf summarises the main evolution in terms of
INTERNATIONAL standards.
REPORTING
While the SDGs are still the main framework referenced by companies (other
FRAMEWORKS
than the UN Global Compact)15, a few companies have started to adopt more
AND STANDARDS
—
14 Securities and Exchange Commission Annual Report, 2022
15 Out of the 81 Myanmar companies members of the UN Global Compact as of January
2023, 14 were assessed in Pwint Thit Sa 2022.

17
 TABLE 4: EVOLUTION OF THE NUMBER OF COMPANIES REFERENCING INTERNATIONAL
STANDARDS

PTS 2020

PTS 2022

Change
Sustainable Development Goals (SDGs) 23 28 +5
ASEAN Corporate Governance Scorecard (ACGS) 9 18 +9
Global Reporting Initiative (GRI) 9 12 +3
Integrated Reporting <IR> 2 4 +2
Sustainability
Sustainability Accounting Accounting
Standards Standards
Board (SASB)16Board (SASB)
2
16
3 +1

robust reporting frameworks like GRI, <IR> or SASB. These companies17

should be recognised for setting the trend for better corporate disclosure
and reporting in Myanmar. Listed and public companies should particularly
be encouraged and incentivised to adopt similar practices.

ESG REPORTING Finally, regarding disclosure of environmental and social issues (the E&S
REMAINS WEAK in ESG), few companies disclose much information (Table 5). There is still
— an overemphasis on publicising charitable donations rather than disclosing
environmental and social impacts. Most companies only disclose vague
statements regarding their E&S performance, or have Key Performance
Indicators (KPIs) whose scope or relevance are questionable.
There is a business case for identifying relevant KPIs. A company that can
disclose its energy consumption is probably better positioned to reduce
energy costs, and therefore to increase its future profitability.
Tracking and disclosing data on employee engagement is an important KPI
with a bearing on profitability and growth prospects, as it indicates their
views on working conditions and their motivation and the companies’ ability
to attract, develop and retain the best human resources. Currently only 3%
of companies disclose such information compared to 2% in 2020, a slight
increase.

16 The SASB is now part of the International Financial Reporting Standards (IFRS)
Foundation. SASB standards will be incorporated into new IFRS Sustainability
Disclosure Standards which are under development.
17 FMI, AYA, Max Myanmar, MSP CAT, MTSH, Myanma Awba Group, Proven Group, Shwe
Taung Group, TMH, uab bank, Yoma Bank.

18
TABLE 5 – ENVIRONMENTAL AND SOCIAL TOPICS DISCLOSED BY COMPANIES

PTS 2020

PTS 2022
Themes Topics

Social Equal opportunity employer (gender, race, age) 8% 8%

Societal Philanthropic activities 8% 8%
Social Training 7% 7%
Social Turnover 7% 6%
Environmental Energy 6% 5%
Social Careers' development / appraisals 5% 5%
Social HSE 5% 4%
Environmental Carbon 4% 4%
Social Frequency rate / Fatality rate 6% 4%
Environmental Waste 3% 4%
Environmental Water 3% 4%
Social Employees' engagement 2% 3%
Social Absenteeism rate 5% 3%
Societal Product responsibility 4% 3%
Societal Supply chain management 4% 3%
Social Disability 3% 2%

19
 ANNEX 1: CRITERIA ASSESSED
—

ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
CORPORATE PROFILE

Company’s Presentation

1 Does the company have an updated vision and mission statement? D S E.1.4

Does the board of directors/commissioners periodically review and approve the

2 D S E.1.5
vision and mission and has it done so at least once during the last five years?

3 Does the company disclose its corporate values? D S

Does the company explain its activities briefly? Does it provide its company
4 D S
profile?

Does the company clearly explain their business model, and how it creates value
5 P S
for stakeholders?

Ownership Structure

Does the company disclose details of the parent/holding company, subsidiaries,

6 associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ D S D.1.5
(SPVs)?
Does the information on shareholdings reveal the identity of beneficial owners,
7 D S D.1.1
holding 5% shareholding or more?

Does the company disclose the direct and indirect (deemed) shareholdings of
8 D S D.1.2
major and/or substantial shareholders?

Does the company disclose the direct and indirect (deemed) shareholdings of
9 D S D.1.3
directors?

Does the company disclose the direct and indirect (deemed) shareholdings of
10 D S D.1.4
senior management?

Company’s Strategy

Does the company clearly explain their goals, and how they want to achieve
11 P S
them?

Does the Board of Directors have a process to review, monitor and oversee the
12 D S E.1.6
implementation of the corporate strategy?

Does the company clearly explain how the challenges caused by the current
13 crises in Myanmar impact on pursuing its strategy, and the potential implications
for its business model and future performance?

- Covid-19 pandemic P S
- Ongoing political crisis P S
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
Corporate Communication

14 Does the company use the following mode of communication:

- Company website D S D.6.2

Facebook D S

Does the company have a website disclosing up-to-date information on the

15
following:

- Downloadable annual report D B D.8.3

- Notice of AGM and/or EGM D B D.8.4

- Minutes of AGM and/or EGM P B D.8.5

Does the company have a separate corporate responsibility (CR) report/section

16 D S C.1.7
or sustainability report/section?

17 Is the information reliable, accessible and up-to-date? P S

Does the company regularly communicate with external stakeholders on business

18 P S
impacts of Covid-19?

Does the company regularly communicate with external stakeholders on business

19 P S
impacts of the ongoing political crisis?

Has the company performed a gap analysis between the information disclosed
20 P B
and the requirement from the ASEAN Corporate Governance Scorecard?

CORPORATE GOVERNANCE

Shareholders’ Engagement

Does the company disclose the voting results including approving, dissenting,
21 and abstaining votes for all resolutions/each agenda item for the most recent P B A.3.6
AGM?
Does each resolution in the most recent AGM deal with only one item, i.e., there
22 D B B.2.1
is no bundling of several items into the same resolution?

Is the company's notice of the most recent AGM/circulars fully translated into
23 D B B.2.2
English and published on the same date as the local-language version?

Board of Directors’ Structure

24 Does the company have a Board of Directors? D S

25 Is the number of BoD members disclosed? D S

Does the board of directors/ commissioners comprise at least five members and
26 D S
no more than 12 members?

27 Do different persons assume the roles of chairman and CEO? D B E.4.1

 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
28 Is the chairman a non-executive director? D B

29 Is the chairman an independent director? D B E.4.2

If the chairman is not independent, has the Board appointed a Lead/Senior

30 D B E.4.5
Independent Director and has his/her role been defined?

31 Were any of the directors CEO of the company in the past 2 years? D B E.4.3

Among the directors, how many may be considered as 'independent' according to

32 D B
the definition provided by the company?

Do independent, non-executive directors/commissioners number at least three

33 D B E.2.4
and make up more than 50% of the board of directors?

Are the independent directors/commissioners independent of management and

34 D B
major/substantial shareholders?

Has the company set a limit of five board seats in publicly-listed companies that
35 D B E.2.6
an individual director/commissioner may hold simultaneously?

Board of directors’ responsibilities

36 Are the roles and responsibilities of the board of directors clearly stated? D S E.1.3

37 Are the types of decisions requiring board of directors' approval disclosed? D S E.1.2

38 Are the role and responsibilities of the chairman disclosed? D S E.4.4

Does the company disclose the number of board of directors meetings held
39 D S E.3.2
during the year?

Does the company disclose the attendance of each director/commissioner in D.2.6 /

40 D S
respect of meetings held? E.3.3

41 Does the company have orientation programmes for new directors? D B E.5.1

Does the company disclose the details of remuneration of the CEO and each D.2.7 /
42 D B
member of the board of directors? E.3.12

43 Does the Board of Directors discuss/ review the impact/ challenges caused by?

Covid-19 pandemic P S

Ongoing political crisis P S

Audit committee

44 Does the company have an Audit Committee? D S E.2.18

Is the Audit Committee comprised entirely of non-executive directors with a

45 D B E.2.19
majority of independent directors?
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
46 Is the chairman of the Audit Committee an independent director/commissioner? D B E.2.20

Does at least one of the independent directors/commissioners of the committee

47 D S E.2.22
have accounting expertise (accounting qualification or experience)?

48 Does the Annual Report disclose the number of Audit Committee meetings held? D S E.2.23

49 Is the attendance of members at Audit Committee meetings disclosed? D S E.2.23

Nominating committee

50 Does the company have a Nominating Committee (NC)? D S E.2.8

Does the Nominating Committee comprise entirely of non-executive directors with

51 D B E.2.9
a majority of independent directors?

Is the chairman of the Nominating Committee an independent director/

52 D B E.2.10
commissioner?

Does the Annual Report disclose the number of Nominating Committee meetings
53 D S E.2.12
held?

54 Is the attendance of members at Nominating Committee meetings disclosed? D S E.2.12

Remuneration Committee/ Compensation Committee

55 Does the company have a Remuneration Committee (RC)? D S E.2.13

Does the Remuneration Committee comprise entirely of non-executive directors

56 D B E.2.14
with a majority of independent directors?

Is the chairman of the Remuneration Committee an independent director/

57 D B E.2.15
commissioner?

Does the Annual Report disclose the number of Remuneration Committee

58 D S E.2.17
meetings held?

59 Is the attendance of members at Remuneration Committee meetings disclosed? D S E.2.17

Performance review & board appointments

Does the company disclose how the board of directors plans for the succession
60 P B E.5.3
of the CEO/Managing Director/President and key management?

Does the board of directors conduct an annual performance assessment of the

61 D B E.5.4
CEO/Managing Director/President?

Does the company disclose the criteria used in selecting new directors/
62 P B E.3.9
commissioners?

63 Is an annual performance assessment of the board of directors conducted ? D B E.5.5

64 Does the company disclose the criteria used in the board assessment? P B E.5.5
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
SUSTAINABILITY MANAGEMENT

Risk Management

Does the company disclose the internal control procedures/risk management

65 D S E.3.19
systems it has in place?
Does the Annual Report disclose that the board of directors/commissioners has
66 conducted a review of the company's material controls (including operational, D S E.3.20
financial and compliance controls) and risk management systems?

67 Does the company disclose how key risks are managed? P S E.3.21

68 Are the following risks mentioned in the annual report?

- Environment D S
- Social (HR) D S
- Social (Society) D S
- Governance D S
- Finance D S
Does the annual report explain how the organization is addressing its ability to
69
create value over the short, medium and long term due to:

- Covid-19 pandemic P S

- Ongoing political crisis P S

Strategy

70 Does the company have a sustainability manager / officer? D S

71 Does the company have a sustainability strategy? P S

72 Does the company explain its stakeholder mapping process? D S

73 Does the company disclose its materiality analysis? D S

Does the company clearly explain how the materiality analysis is relevant for
74 P S
business issues ?

75 Does the company disclose its mid-long term targets on sustainability topics? P S

Are the sustainability targets explicitly aligned with the materiality analysis, with a
76 P S
high level of commitment and a reasonable timeframe?

Does the company engage with its external stakeholders to get their views on
77 D S
specific topics?
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
Corporate Policies

78 Are the following area covered by a specific policy?

- Board Policy P S E.1.1

- BoD's conflict of interest (abstention in specific meeting, …) P S

- Code of conduct P S
B.4.1 /
- Disclosure of Directors' interest in transactions and any other conflicts of interest P S B.4.2 /
B.4.3

- Dividend policy P S D.2.4

- Employment / Labour P S

- Equal opportunities policies / Diversity P S

- Donations / Philanthropy P S

- Anti-harrassment P S

- Health & Safety Policy P S

- Human rights P S

- Professional education programmes for director (on-going or continuous) P S

B.4.2 /
- Related Party Transactions P S B.4.3 /
D.3.1
Remuneration (fees, allowances, benefit-in-kind and other emoluments) for
- P S
executive directors and CEO
Reward/compensation for the performance of the company beyond short-term C.3.3 /
- P S
financial measures E.3.12

- Use of knowledge generally not available on the market / Insider trading P S

Business Ethics

79 Are the details of the code of ethics or conduct disclosed? D S E.2.1

Does the company disclose that all directors/commissioners, senior

80 D S E.2.2
management and employees are required to comply with the code?

Does the company disclose how it implements and monitors compliance with the
81 D S E.2.3
code of ethics or conduct?

Whistleblowing

Does the company provide contact details via the company's website or Annual Report
82 which stakeholders (e.g. customers, suppliers, general public etc.) can use to voice their D S C.2.1
concerns and/or complaints for possible violations of their rights?

83 Is it possible to submit an issue anonymously? D S

Does the company have a policy or procedure to protect an employee/person

84 D S C.4.2
who reveals illegal/unethical behaviour from retaliation?
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
Sustainability Reporting

85 Does the company use a dashboard to monitor and report its performance? P S

Does the company publish a COP / sustainability report for the current or the last
86 D S
fiscal year?

87 Is the scope/perimeter of the report clearly described? P S

REPORTING

Annual Report

88 Does the company publish an annual report? D S

89 Is the annual report available in English? D S

90 Is the annual report available in Burmese? D S

91 Is the annual report released within 120 days of the end of the financial year? D S D.7.2

92 Does the company's annual report disclose the following items:

- Corporate objectives D S D.2.1

Biographical details (at least age, qualifications, date of first appointment,

- relevant experience, and any other directorships of listed companies) of directors/ D S D.2.5
commissioners

Framework

93 Is the company compliant with the following framework:

- AA1000 P S

- DJSI P S

- GRI P S

- Integrated Reporting P S

- SASB P S

- SDGs D S

Financial & operations

94 Is the company publishing its main financial KPIs? D S D.2.2

95 Is the company publishing its tax? D S

Is the same firm engaged for both audit and non-audit services (i.e. advisory
96 D S
services)?

97 Is the company publishing its expenditures related to charity for last fiscal year? D S
 ASEAN Corporate
Standard/Bonus
Performance

Governance
Disclosure/
#

Scorecard
Non Financial

Does the company disclose the activities that it has undertaken to implement
98
the following policies:

- Customer health and safety P S C.1.1

- Supplier/Contractor selection and criteria P S C.1.2

- Environmentally-friendly value chain P S C.1.3

- Interaction with communities P S C.1.4

- Anti-corruption programmes and procedures P S C.1.5

- Creditors' rights P S C.1.6

99 Does the company disclose some quantitative KPIs on the following topics:

SOCIAL ISSUES

- Employee engagement P S D.2.3

- Turnover P S D.2.3
D.2.3 /
- Absenteeism rate P S C.3.1
D.2.3 /
- HSE P S C.3.1
D.2.3 /
- Frequency rate / Fatality rate P S C.3.1
D.2.3 /
- Training P S C.3.2

- Career development / appraisals P S D.2.3

- Equal opportunity employer (gender, race, age) P S D.2.3

- Disability P S D.2.3

ENVIRONMENTAL ISSUES

- Waste P S D.2.3

- Energy P S D.2.3

- Carbon P S D.2.3

- Water P S D.2.3

SOCIETAL RESPONSIBILITY

- Product responsibility P S D.2.3

- Supply chain management P S D.2.3

- Philanthropic activities P S D.2.3

100 Are the non-financial data audited by a third party? P S

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