The company states that it works intensively to mitigate human rights violation risks, also, it states that in addition to the Ethics and Compliance Committee it has a multidisciplinary Human Rights Working Group, focusing on articulating the necessary actions to mitigate and address the identified risks. However, it does not describe its global system to take action to prevent, mitigate or remediate its salient human rights issues. Also, there is no evidence the company discloses what it considers to be its salient human rights risks (meeting 4a or 4b) and it is, therefore, unable to meet this element, which requires a global system to take action to prevent, mitigate or remediate its salient human rights risks, which must be transparently shared