Group Policies

Our Human Rights policy establishes a framework for protecting and advancing human rights, both in our work and in our sphere of influence.

Respect for human rights is one of TITAN’s core values, as reflected in our Code of Conduct. Our policy is guided by the principles in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.

The policy aims to raise awareness on human rights issues and ensure the commitment of all TITAN employees to the protection of human rights throughout the Group.

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Protection of the confidentiality, integrity, and availability of information is imperative to TITAN Group’s business. Our Group Information Security policy aims to provide the main principles required to protect information assets from a wide range of threats based on the following broad principles:

1. Confidentiality: confirming that information is accessible only to those authorized and confirming that confidential or sensitive information is appropriately protected.
2. Integrity: safeguarding the accuracy and completeness of information and its associated information processing methods.
3. Availability: confirming that authorized users have access to information, and the associated assets or systems, on a timely basis and when required.

The policy is supported by a robust set of information security sub-policies, procedures and guidelines and applies to all employees of TITAN Group acting in different roles within the business functions as well as any suppliers accessing corporate information and information systems for business purposes.

Our Diversity, Equity and Inclusion (DE&I) Policy sets out TITAN Group’s principles, definitions, scope and approach to diversity and inclusion.

At TITAN, we recognize that achieving our aspirations for DE&I in the work we do and the way we work is an on-going process that requires awareness, action, responsibility and accountability from everyone in our business.

Depicting our commitment to creating an environment where all differences are valued and where everyone has the opportunity to flourish and experience a sense of belonging, the Policy applies to all employees of TITAN Group, while it is expected to also be applied by our partners and business associates.

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Our Corporate Social Responsibility (CSR) policy establishes a framework for pursuing our business goals in a socially responsible manner and contributing to the wellbeing of our employees and their families, the sustainability of the communities we work in, and society at large.

CSR is a core TITAN value, and our commitment to making a positive impact on the world around us goes beyond legal and regulatory compliance. Our policy also aims to add value to our business by promoting good business practices, enhancing our reputation, strengthening our license to operate and improving our competitiveness.

We aim to proactively and continuously improve in this area and adapt to an ever-changing business and social environment creating sustainable value for all. Essential to this is listening, engaging, communicating and building mutual trust with our stakeholders.

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Our Whistleblowing Policy aims to guide our ongoing efforts to promote and strengthen ethical behaviors already embedded in our work culture. It establishes the framework for reporting work-related incidents that constitute, or may constitute, a violation of our corporate values and policies or retaliation against any person within TITAN Group.

The objective of the policy is to:

1. encourage the reporting of Incidents in good faith;
2. provide guidance as to how to make reports; and
3. provide comfort to reporting persons that their reports will be taken seriously and treated with confidentiality without fear of retaliation.

The Policy applies to all employees of TITAN Group worldwide, regardless of the legal basis of the working relationship and the position or the function of the employee. Third parties who have an ongoing relationship with TITAN may also rely on this Policy to report Incidents.

The Policy is supported by TITAN EthicsPoint, a platform where employees from every country can report work related concerns with confidentiality, by phone or online. The launch of this common platform across the Group enhances our efforts to foster a culture of integrity and ethical conduct across all our business units, while strengthening our ability to monitor non-compliance with TITAN policies.

Our Anti-Bribery and Corruption policy aims to ensure compliance with the respective rules prohibiting bribery and corruption. The policy applies to all TITAN Group employees, representatives and agents, all of whom are expected to follow the highest standards of professional and personal conduct at all times.

Dealing with a range of issues related to bribery and corruption, our policy complies with all applicable laws and contains TITAN Group’s global standards.

TITAN complies with all applicable anti-bribery laws, including the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and the local laws in every country in which we do business.

Our Competition Law Compliance policy and guidelines aim to ensure compliance with competition laws in every country where we operate. The policy and guidelines place responsibility on all business units and entities controlled or managed by the TITAN Group, as well as every TITAN employee, to treat all customers and suppliers fairly, equally and openly.

The policy guides employees through the fundamental principles of competition law and helps identify solutions where relevant issues may arise. Additional to it, several guidelines are provided, which give an overview of key competition law provisions and indicate the types of conduct that might give rise to antitrust issues. TITAN employees are also required to obtain expert advice when faced with issues involving competition laws or when in doubt about compliance.

Our Environmental Policy reflects our commitment to sustainable development and our approach towards addressing the challenges and opportunities of climate change.

Main elements of our environmental policy include: assessment impacts, quarry rehabilitation, protection of local biodiversity, conservation and stewarding of water resources, resource recovery and managing waste, creating an environmentally responsible culture with our business partners and embedding innovation in our strategy.

The policy also encompasses our priorities under the Climate Change Mitigation Strategy, namely: energy efficiency, co-processing of alternative fuels and raw materials, product innovation and new technologies, and assessment of risks and opportunities across the value chain.

The policy sets out the environmental responsibilities by all business units and entities controlled or managed by the TITAN Group, as well as each TITAN employee.

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Our Procurement Policy establishes a framework for the fundamental principles governing procurement, which TITAN Group employees must follow and suppliers are expected to be aligned with, when engaged in procurement activities involving the Group.

Our key objective through the procurement of goods and services is to meet all the needs of our plants and operating units with a view to optimizing the cost, improving the competitiveness of TITAN Group, and enhancing our commitment of being a socially responsible, ethical and environmentally sensitive business organization.

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TITAN Group considers personal data as a core asset that needs to be safeguarded. Processing personal data according to the best global practices is an essential part of the TITAN Group strategies towards customers, employees and all other stakeholders.

The objectives of our Framework Policy for the Protection of Personal Data are:

1. To state the commitment of TITAN Group for the most effective personal data management, especially through the IT assets and activities.
2. To provide general guidelines for the data privacy issues related to the collection, use, processing, disclosure, monitoring, etc., of the personal data that TITAN Group processes.
3. To set the key requirements to be followed when processing personal data, keeping into account the provisions of the General Data Protection Regulation (GDPR) and respective national law.

Our Conflict of Interest policy aims to ensure that all employees of Titan Group do business in a way that their business judgement and decision-making are not influenced by undue personal interest.

The policy applies to all employees worldwide. It stipulates TITAN Group’s global standards, principles and rules for preventing or addressing Conflict of Interest situations, in areas where these may more often occur and is aligned with all applicable laws.

Employees must act in the best interest of TITAN Group while performing their job for the company. Personal interests and relationships must not interfere, or appear to interfere, with the ability to make decisions in the best interest of the company.

Our Sanctions policy aims to ensure compliance with sanction laws in every jurisdiction where the TITAN Group operates.

Our international presence as a Group obliges us to comply with any sanctions imposed, administered or enforced by international organizations or relevant national authorities. Under such circumstances, the Group is expected to implement and maintain adequate systems and controls to ensure compliance.

Our policy includes a practical guide and a list of best practices on issues including when to carry out due diligence, screening associated parties, training, and audit trail and record keeping.

Our Health & Safety policy aims to achieve a healthy work environment free of incidents, injuries and accidents for all of our direct and indirect employees. It is aligned with all applicable laws and directives where TITAN is active.

At TITAN, Health and Safety is managed as an integrated system of goals with clear responsibilities and accountabilities. Our aim is to continuously improve and create an environment where every TITAN employee is responsible for their own and their colleagues’ safety. TITAN’s (Occupational) Health & Safety policy also includes sharing our know-how with stakeholders, suppliers, contractors and third parties to adopt similar health and safety policies.

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