Converge Sustainability Report 2022

We have an established Sustainability Governance Structure that is Sustainability Governance

supported by committees and groups that guide the decisions and actions
we take with respect to sustainability. and Management
GRI 2-9, 2-12, 2-13, 2-14, 2-16, 2-17, 2-18, 2-19, 2-20
We included the Sustainability perspective in our Corporate Performance
Management process, which includes Annual Operating Plan development
Converge is headed by a Board of Directors (BOD). As set out in
and Key Performance Indicators (KPI) that are aligned with our
our Manual on Corporate Governance, the duties and functions
sustainability targets and commitments. Incentives are part of our
of the board includes identifying key risk areas and performance
annual performance incentive award program wherein certain members
indicators and monitoring these factors with due diligence. This
of management are evaluated based on the attainment of specific
will enable the corporation to anticipate and prepare for possible
sustainability targets, including those related to climate change.
threats to its operational and financial viability.
We also extended our Enterprise Risk Management (ERM) framework to
The Board has delegated to the BROC overall responsibility for
the active management of sustainability risks, including climate change
ensuring that the Company’s impacts on the economy, environment
risks, as set out in our Sustainability Policy. Our ERM team has instituted a
(including climate), and people (including human rights) are
risk policy that integrates climate change mitigation measures. The Chief
managed. The BROC’s duties and responsibilities with respect to
Risk Officer reports to the Board Risk Oversight Committee (BROC) sustainability can be found in its Charter. Every quarter, BROC
on a quarterly basis and takes up climate change matters. The BROC is reported with the progress on EES Initiatives and KPIs. They
considers climate-change scenarios and adverse news when assessing the keep track of how the sustainability partners fulfill the reporting
Company’s Risk Profile. This Risk Profile is revisited twice a year to keep requirements and suggest initiatives that the company may take on.
the Company abreast of the top climate change risks that could affect its
operations and results. We have adopted principles of good corporate governance
practices such as the following:
By instituting policies and programs relating to the environment (e.g.
Energy Management Policy), social (including human rights), and
governance, we are taking steps to operationalize our
Sustainability Policy.
Collective
We have started to implement our sustainability commitments with and Knowledge of the
through our business relationships by: Board
Including sustainability-related requirements from vendors as part
of vendor accreditation such as Environmental Compliance
Certificate, Certificate of No Pending Case, Conflict Minerals POLICY & PRACTICE PROGRESS & ACCOMPLISHMENTS
Commitment, etc.
.
Having sessions with selected vendors to share sustainability We have an annual continuing In 2022, the following topics
education program for the relevant to sustainability were
practices and experience Directors to ensure that they covered:
are continuously informed
Briefing session with Sales to enlighten them on the of the developments in the National Broadband Plan
Sustainability Commitments of Converge so they can further business and regulatory
environments, including CHIP (Connect – Harness –
share this with our customers
emerging risks relevant to the Innovate – Protect)
Corporation. There shall be Implementation Plan
During 2022, we conducted briefings with the leaders and sustainability technical, technological, and
business unit partners. This is to launch the Converge process on business training at least twice National ICT Ecosystem
management and internal/external reporting of the EES commitments. As a year for the Board. Framework
we launched the quarterly report for EES, we onboarded our partners on Legislation on Open Internet
their responsibility to drive sustainability across Converge. and Content Blocking

How we make our network

resilient

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Board Committee
Responsible for
Sustainability
POLICY & PRACTICE
The BROC oversees the
development and implementation
of the Company’s sustainability-
related strategies, policies,
and practices that assist the
Company in addressing actual
and potential impacts to public
and stakeholders in the EES
areas, including climate change
risks. The BROC also oversees
the preparation of an annual
Sustainability Report, as required
by regulations, and reviews and
approves this report.
POLICY & PRACTICE
The requirements for
communication of critical concerns
is set out in our Manual on
Corporate Governance, Section 10
Adequate and Timely Information
(page 14).
Evaluation
of Board
Performance
POLICY & PRACTICE
The Board conducts an annual
self-assessment of its performance,
including the performance of the
Chairperson, Board members,
committees, and key control
officers. This is in line with our
Manual on Corporate Governance,
Section 17 Governance Self Rating
System (page 19).
PROGRESS & ACCOMPLISHMENTS
In 2022, the BROC reviewed EES
performance in five meetings to
track progress in the development
and implementation of our
Sustainability Strategy and Plan.
Communication
of Critical
Concerns
PROGRESS & ACCOMPLISHMENTS
and sets sustainability strategy (including
In 2022, one critical concern
raised on a data breach was
communicated to the Board.
Further details can be found
in the Customer Data and
Privacy Section.
PROGRESS & ACCOMPLISHMENTS
In 2022, the Board evaluation for
individual member evaluation,
Chairman evaluation, Chief
Executive Officer (CEO) and
President evaluation conducted
did not result in any change in the
board composition. Every three
years, an external facilitator shall
support the assessment. The
first evaluation facilitated by an
external party will be conducted
in Q4 2023. Such a system shall
allow for a feedback mechanism
from the shareholders.
Converge Sustainability Report 2022
PROGRESS & ACCOMPLISHMENTS
Determination of
Remuneration In 2022, two Remuneration
Committee meetings were held.
POLICY & PRACTICE
We have a Remuneration Committee who oversees the process of determining
the remuneration of the Board and senior management as set out in our Manual
on Corporate Governance. The board remuneration is based on a pay for
performance reward system with variable pay and retirement plan.
Our sustainability management structure is set out below.
Provides overall guidance and
governance in establishing and
executing the sustainability
strategy (including climate),
including the relevant topics to the
appropriate business unit partner
Executes action plans,
provides KPI data and
Defines and monitors sustainability key reports the progress to
performance indicators and initiatives the Sustainability Core
Team and/or Sustainability
climate), in collaboration with the Council
Sustainability Business Unit Partners
(e.g. roadmap definition and execution,
program management)
Sustainability
Council
Sustainability
Business Unit
Sustainability Partners
Core Team
For Energy and Emissions, the VP For Climate Adaptation and
& Head of Workplace, Premises and Resilience, the VP & Head of
Fleet Management Group (WPFMG), Enterprise Risk Management
together with the EVP & Chief Network leads the assessment of potential
Transformation Officer, ensures the losses from key perils and climate
monitoring of our energy consumption, change. The results are reported
and the development and execution of our to the senior management and
initiatives towards reduction of greenhouse relevant departments, along with
gas emissions. Any progress on the recommendations to address any
initiatives are reported by WPFMG through potential losses.
the regular departmental meetings with
the senior management.
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Converge Sustainability Report 2022
OPERATING A RESPONSIBLE COMPANY AND LEADING WITH INTEGRITY AND GOOD GOVERNANCE

Anti-Corruption GRI 3-3, 205

Topic Owner:
SVP & Corporate Compliance and Data Protection Officer

The Philippines ranked 116th in Transparency International’s 2022

Corruption Perception Index. The UN Convention Against Corruption
recognizes the role of the private sector in combating corruption.
Hence, aligning with UNGC Principle 10 and SDG Target 16.5, we
continue to do our part to strengthen our anti-bribery controls. Our
amended Anti-Bribery/Anti-Corruption Policy embeds in our ways Total number of confirmed incidents of corruption
of working the requirements of the Organisation for Economic Co-
operation and Development Anti-Bribery Convention, the United TARGET ACTUAL
States Foreign Corrupt Practices Act, and Philippine laws relating to
bribery and corruption. 0 10

There were 10 confirmed incidents of corruption reported in 2022.

These include:
To strengthen the culture of integrity, the Company led anti-
1. Conflict of interest
corruption and other related key initiatives for 2022, 2. Solicitation of bribes
which include: 3. Offering of kickbacks to employees
4. Falsification of documents
1. Updating core compliance policies and procedures 5. Misappropriation of assets
such as the Anti Bribery and Anti Corruption Policy,
Whistleblower Policy and Procedure, Compliance The reported incidents did not involve government officials, agencies,
Risk Management (CRM) Policy, and Blacklisting and or their employees. Converge employees confirmed to be involved in
said incidents have faced disciplinary action and termination. Moving
Suspension Policy; forward, cases with corruption nature shall be dealt with severely as
a major offense through a more robust investigation process and the
2. Developing new policies on human rights, tightening strict implementation of the Employee Discipline Policy.
controls on issuance of cash bonds, and formalizing a
process for company sponsorships;

3. Conducting open forums with key officers to encourage

employees to reach out to these officers and build
stronger business relationships;
4. Promoting the Whistleblowing Platform as an
independent tool for stakeholders to report any
wrongdoing without fear of retaliation; and
5. Conducting Compliance Risk Assessment activities
covering 12 departments (22% of the all departments) to
determine the significant risks related to corruption. This
activity is the initial stage to implement improvement
plans on the selected departments to prevent corruption.
With our CRM Program, we enjoined different department
representatives to improve, rectify, or develop their internal
processes to manage actual negative impacts of corruption.
Upon identifying the gaps via the CRM program, opportunities for
improvement were noted and were enforced in our policies (e.g.
Human Rights Policy, Amended ABAC Policy, Third-Party Due
Diligence Questionnaire, Third-Party Code of Conduct, Blacklisting
and Suspension Policy, Whistleblowing Program, etc.)
To track the effectiveness of the actions of the related departments,
regular checkpoint meetings are held to communicate and ensure
that the action items agreed on are being acted upon and executed.

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 Converge Sustainability Report 2022
OPERATING A RESPONSIBLE COMPANY AND LEADING WITH INTEGRITY AND GOOD GOVERNANCE

Competitive Behavior
and Open Internet GRI 3-3, 206; SASB TC-TL-520a.1,
TC-TL-520a.2, TC-TL-520a.3

Topic Owners:
SVP & Corporate Compliance and Data Protection Officer
EVP & Chief Network Transformation Officer

Recognizing the 2017-2022 Philippine Developmental Plan’s (PDP)

push to promote competition in the market, and the provisions
of the Philippine Competition Act (RA 10667), Converge issued
its Anti-Trust/Anti-Competition Policy to guide employees on fair
competition. For the telecommunications sector, the “open internet”
concept is a key competition issue being debated in the Philippines
and abroad. The open internet also relates to SDG Target 16.10 on
ensuring access to information.

Currently, there are no open internet or net neutrality rules in the

Philippines, although bills have been filed in Congress. The PDP
2023-2028 lists the proposed Open Access in Data Transmission
Act as a priority bill that will “level the playing field in the data
transmission and telecommunications market.”

Nonetheless, Converge does not block or slow access to any specific

content on the internet, except as required by law (e.g. to prevent
online sexual exploitation of children under RA 9775), nor does it
engage in zero rating.

In 2022, there was no pending or completed legal action against

Converge involving anti-competitive behavior and violations of
antitrust and monopoly. Consequently, we did not experience any
monetary losses as a result of any such legal proceedings.

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