Environmental, Social and Governance

ESG Policy Commitment

The ESG policy of the Company is to ensure so far as it is applicable and reasonably practicable that its operations will be carried out with a commitment to:

(a) protecting and enhancing the environment by minimising negative impact and maximising positive impact on the environment;

(b) ensuring appropriate conduct towards, positive impact on and good relationships with employees, customers/clients, suppliers and the community in which it operates; and

(c) conduct its business with integrity and high standards of business ethics, through appropriate structures, systems, processes and procedures.

(the Company’s “ESG Commitment”).

The ESG Commitment is a fundamental principle of the Company’s business.

Fulfilling the ESG Commitment is the responsibility of the Directors of the Company.

General ESG Principles

In fulfilling the ESG Commitment, the Company seeks to:

  • comply with all applicable local and national laws, rules, regulations and other measures having the force of law that are relevant to any aspects of its ESG Commitment; and
  • where it is practicable and appropriate to do so, establish and meet standards relevant to any aspects of its ESG Commitment which are higher than the standards imposed by law.

All Company employees must, in carrying out their duties, adhere to the principles and objectives of this ESG Policy Statement. Training will be given to employees to ensure that they are familiar with, and work in accordance with, this ESG Policy Statement.

The Company expects suppliers of goods and services to the Company and contractors working for the Company and their suppliers and sub-contractors to adopt and implement the ESG Commitment in their own businesses.

All suppliers to the Company are expected to adopt policies and standards fully consistent with those set out in this ESG Policy Statement and to achieve comparable levels of performance.

Environmental

The Company has produced the following objectives as a framework for the introduction of practices to implement the environmental aspects of the ESG Commitment, in addition to the Environmental Policy the Company has in place:

  • Identifying and managing environmental risks and hazards
  • Carrying out of environmental audits when required
  • Promoting a culture of environmental awareness amongst all employees
  • Providing training for all employees as appropriate to enable them to carry out their job functions in a manner that shows care for the environment
  • Involving customers, suppliers and subcontractors in the implementation of these ESG objectives
  • Continuously improving environmental performance and integration of recognised environmental best practice into business operations
  • Measuring, and acting to reduce, the carbon footprint of business activities through the Fixed Carbon Reduction Plan
  • Focusing on action to conserve resources and energy, to minimise emission to air, water and land and to increase recycling rates
  • Minimising of waste by evaluating operations and ensuring they are as efficient as possible
  • Managing waste generated from business operations according to the principles of reduction, re-use and recycling
  • Taking steps to improve environmental efficiency of transport and business travel, including considering whether, to avoid travelling, any meetings can be held remotely
  • Where possible, using recycled or ecologically friendly paper
  • Using ‘waste’ paper for notepads unless confidentiality may be compromised
  • Reducing consumption of resources and improving efficiency of those resources by printing double sided where practicable
  • Recycling of all paper products, ink or toner cartridges

Social

The Company has produced the following policies that act as a framework for the introduction of practices to implement the social aspects of the ESG Commitment:

  • Modern Slavery and Human Rights Policy
  • Bribery Act Policy
  • Ethics Policy
  • Health, Safety and Wellbeing Policy
  • Privacy Policy

Governance

The Company has produced the following objectives[1] as a framework for the introduction of practices to implement the governance aspects of the ESG Commitment:

  • Ensuring that the Company complies with, at least, all applicable local and national laws and regulations, relevant standards and codes of practice relating both generally and in particular to transparency and corporate governance
  • Establishing clear and effective governance for ESG, promoting the use of best practice on corporate governance when relevant and possible, and setting goals and establishing accountability and reports to its board
  • Ensuring that the Company promotes strong oversight and transparency at all levels of its organization
  • Adopting and maintaining suitable and clear governance structures, including terms of reference for the board that, amongst other matters, set out the required composition of the board, its powers and responsibilities
  • Ensuring that the Company adopts and implements adequate internal controls, processes, procedures and proactive risk management
  • The Company is committed to establishing and maintaining high standards of business ethics through a strong code of ethics and business conduct, ongoing ethics training and promotion of a culture of integrity, honesty, ethical and responsible conduct in its business activities and behaviours – see Ethics Policy for more details
  • The Company is committed to ensuring that no corruption, bribery, money laundering or internal misconduct activities are taking place in the business
  • Establishing and maintaining detailed policies covering anti-bribery and corruption, code/s of conduct, conflicts of interest, privacy and human resources, as part of the governance structure of the Company
  • Engaging with stakeholders about ESG issues
  • Ensuring that the Company cultivates strong stakeholder relationships through transparency, open communications and responding to stakeholder input on ESG issues
  • Dealing with regulators, tax authorities and auditors and other relevant stakeholders in an open and co-operative manner
  • Ensuring the resilience and long-term preservation of value for the Company’s business
  • Ensuring that the Company mitigates risk exposure and builds the resilience of its business to climate change, earthquakes and other catastrophic events

Status of this ESG Policy Statement

The Directors endorse this ESG Policy Statement and are fully committed to its implementation.

This ESG Policy Statement will be regularly reviewed and updated as necessary.

This ESG Policy Statement has been approved & authorised by:

| Name: | Lucy Clarke | | --- | --- | | Position: | Director | | Reviewed | 5 April 2023 |

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