Reporting

NKT signed the UN Global Compact on 27 March 2009 and this is our third Communication on Progress (COP) Report, covering the period 1 July 2010 to 30 June 2011.

Reporting structure
Given that the Group’s four business areas are diverse, so are the challenges related to CSR. Therefore, we report separately on each of the four business areas. Our COP reports address the UN Global Compact's 10 principles divided into three parts: Human & Employee Rights, Environment and Anti-corruption.

Group guidelines and policies
The first efforts on a corporate level were to relate the 10 principles of the UN Global Compact to our company standards, leading to a definition of ethical guidelines for the Group. These guidelines have been supplemented by Group policies and have been communicated throughout the Group. Some of the business areas have taken the guidelines a step further and enhanced them with Codes of Conduct.

Reporting system
To improve benchmarks and ensure continuous progress we have established a comprehensive reporting system within the Group. The reporting system provides data and information from the individual units within the Group and now delivers most of the necessary data and information on which our CSR works and future reporting will be based. The four business areas are responsible for data collection and the quality of the Key Performance Indicators (KPIs).

The reporting system is composed of four elements:

• A whistleblower system where all Group employees can report serious concerns about a number of behaviours, events or circumstances that seem incorrect. Reporting can be made anonymously.
• A data collection system where we can continuously register various KPIs, such as work accidents, type and amount of fuel and energy consumption, CO2 emission from travel and transport, raw material consumption, undesirable events such as environmental spills and fines. 
• A Statement of Representation on Corporate Social Responsibility signed off by local management in the Group companies once a year to ensure that they are familiar with and work to advance the UN Global Compact principles.
• A special reporting scheme where the four business units annually report on matters such as diversity in management, efforts within R&D to support the UN Global Compact, etc.

Both the reporting system and the Statement of Representation include almost 100 units worldwide.

GRI
NKT has been inspired by the parameters of the Global Reporting Initiative (GRI). We have carried out an assessment of materiality of the GRI indicators based on the methodology proposed by the GRI. The methodology remains unchanged from 2010, and we have chosen to report on a total of 16 indicators.

In cooperation with the business areas, the Group has formulated a comprehensive set of parameters, reporting procedures and related instructions which form the basis for this reporting system.

Data reliability
Although the implementation of the consolidated reporting system is complete, some elements are not yet fully operating in all areas. Procedures and instructions related to data quality, data traceability and control measures are still under development. Therefore, the uncertainties of the primary input data, which still exist as a result of this ongoing work, have to be taken into account when considering the conclusions of this report. However, the employment of data has become more consistent as the employees gain more experience in reporting.

Auditing
The NKT Communication on Progress 2011 Report on the Group's CSR efforts is not audited by an independent auditor.

It is the intention to conduct test audits in selected companies within the NKT Group in the coming reporting period. The test audits will focus on data collection procedures, data quality and business procedures in general.