1. Policy Overview
1.1 ESG considerations, which include environmental, social, and governance issues, are interconnected and reflect a company’s overall impact on society and the environment. By addressing these issues together, a company can show the positive influence it has on the world. ESG is similar to corporate social responsibility, but with a greater emphasis on measurement and accountability. Companies that prioritize and openly discuss their ESG efforts often receive more attention from various stakeholders, including investors who seek out firms with high ESG ratings.
1.2 This policy outlines the actions and practices we will take to prioritize and address ESG considerations in our business. This includes, but is not limited to, reporting and disclosure, business practices, policies, procedures, investments, board activities, stakeholder engagement, and investor relations.
1.3 This policy does not diminish the importance or role of existing committees in upholding our legal and ethical obligations.
2. Purpose of Policy
2.1 The goal of this policy is to increase understanding and awareness of environmental, social, and governance (ESG) factors within the company.
2.2 This policy has been reviewed and approved by the CEO.
2.3 This policy is not a part of any employment or service contract and is subject to change at any time.
3. Responsibility of Policy
3.1 The CEO is responsible for the overall implementation and effectiveness of this policy, with specific oversight delegated to the responsible department.
3.2 Line managers have day-to-day responsibility for ensuring compliance with this policy. Employees should direct any questions or concerns about this policy to their line manager.
3.3 This policy is reviewed annually and may be updated as needed based on changes in government guidance
4. Our ESG commitment
4.1 Our goal is to create sustainable, equitable, healthy, and diverse communities through innovative business practices and strong ESG performance. This commitment is reflected in all aspects of our business, including project design and development, company operations, stakeholder collaboration, and progress reporting.
4.2 This ESG policy outlines our approach to sustainability. It is based on a corporate culture that prioritizes sustainability in all business operations and decision-making.
5. Climate Change and the Environment
5.1 We are committed to reducing our energy and carbon footprint, as we believe climate change poses significant risks to our world. Our sustainability program focuses on initiatives that provide near-term benefits in terms of efficiency, value, and health for our business, employees, and community while also being environmentally sustainable.
5.2 We encourage our customers to adopt more sustainable practices by recommending the use of eco-friendly materials and promoting a paperless office. We also support our clients in reducing their own printing and strive to be a digital-first business.
5.3 We strive to comply with relevant environmental regulations and minimize the negative impact of our activities on the environment.
5.4 We support the recommendations of the Taskforce on Climate-related Disclosure (TCFD) and engage with our stakeholders to enhance disclosure on issues related to climate change, biodiversity, and the Sustainable Development Goals (SDGs), including efforts to achieve the goals of the Paris Agreement.
6. Social Responsibility
6.1 We prioritize building strong relationships with key stakeholders, including employees, customers, communities, investors, and suppliers.
6.2 We are committed to creating a dynamic, inclusive, and diverse work environment that supports the professional development of our employees and promotes a healthy work-life balance.
6.3 We support initiatives that benefit the environment, human welfare, and education, including workforce development programs for our customers and economic growth in the communities in which we operate.
6.4 We engage with suppliers, customers, and employees on issues related to safety, health, and wellness.
6.5 We uphold and promote the protection of human rights and welfare within our own business and supply chain, in accordance with our Human Rights Policy, Code of Ethics and Business Conduct, Supplier Code of Conduct, and Modern Slavery and Human Trafficking Policy.
7. Ethical Governance
7.1 We prioritize strong oversight, transparency, and risk management to ensure the long-term success and resilience of our business.
7.2 We uphold strong corporate governance practices through responsible board leadership, management accountability, and proactive risk management.
7.3 We strive to mitigate risk exposure and build the resilience of our business to natural disasters and other catastrophic events through careful planning and design.
7.4 We are committed to maintaining high ethical standards through a robust Code of Ethics and Business Conduct, ongoing ethics training, and a culture of integrity promoted by executive leadership.
7.5 We value strong stakeholder relationships and strive for transparency, open communication, and responsiveness to stakeholder input.
7.6 We have established clear governance for ESG and set goals with accountability, overseen by our ESG committee and reported to our board.
8. Our Business and ESG
8.1 ESG is about evaluating and improving our net positive impact on the world through defined, measurable actions. Our value as a company lies in our employees, communities, and the broader world, and ESG is a fundamental part of how we put our values into practice.
8.2 The ethical and practical values that make up ESG have always been central to our company’s beliefs. With the growing focus on ESG, we have a greater opportunity to communicate the positive impact our business has on the world.
8.3 By considering a wide range of factors in a holistic manner, including environmental and climate change, social issues, employee development, business structure, and governance, we can better articulate our positive impact. We welcome the chance to highlight our contributions to the world.
9. Our Duty to the World
9.1 As a business, we have a responsibility to our employees, customers, and the world at large. ESG allows us to bring these impacts together and prioritize investing in our people, protecting the environment, and being a good corporate citizen.
9.2 Our key goals are openness, sustainability, and respect. We value diversity and strive to work as a cohesive team. We view ESG as a ongoing process of aligning our operations and controls with our company values.
9.3 Our commitment to improving our social and environmental performance reflects our strong, well-informed management approach and values-led culture that is attuned to the challenges and opportunities of conducting business responsibly and sustainably.
10. ESG and Reputation
10.1 ESG is crucial to our reputation as a business. Our reputation is shaped by our interactions with stakeholders, and positive interactions lead to a thriving business and reputation. In a volatile economic climate, a strong reputation is essential for long-term success.
10.2 We want all of our stakeholders, including customers, investors, and employees, to be proud to be a part of our business. This includes understanding the positive impact we have on the world.
10.3 Environmental – Environmental sustainability is both an ethical and practical priority. Reducing our carbon footprint is part of our efforts to operate efficiently. Tackling climate change at a corporate level is a key strategic objective.
10.4 Social – Our employees are the foundation of our business. Intellectual capital is crucial to our clients, business model, and long-term sustainability. We strive to create an inclusive environment that values and nurtures the unique talents and contributions of every individual. While we have work to do, we are committed to building a culture of inclusivity and empowering change.
10.5 Governance – Good governance is essential to all aspects of ESG and our business. We go beyond just fulfilling compliance obligations and strive to embed compliance into the core of our business.
11. Our Responsibility to Customers
11.1 We have a responsibility to provide excellent service to our customers, who are the foundation of our business. Part of this commitment involves responding to their needs, listening to their concerns, and working to achieve customer satisfaction.
11.2 Our best customers are those who see us as partners in their own enterprise. In turn, these customers reward us with their loyalty and help us maintain our reputation as a world-class company.
11.3 ESG priorities are influenced not only by investor concerns but also by customer needs. Customers want to know how we are improving the world and acting as responsible corporate citizens through efforts such as protecting the environment, investing in our communities, and more. It is important that all of our interactions with customers reflect this and that they see us as a partner they are proud to work with and recommend.
11.4 Understanding ESG and its impact on our company is important for all employees so that they can feel proud of the positive impact we have on the world and share this pride with our customers.
12. Your Role to Play in ESG
12.1. As a member of our business, you have a vital responsibility to ensure our organisation thrives. When it comes to ESG, this means understanding your role in each area of ESG. You can start to do this by familiarising yourself with the concept of ESG, such as through this course, and also our strategic objectives around ESG. You should know:
• Our strategic ESG goals
• How we plan to achieve them and over what time
• Your individual and team contribution to those goals
• How to discuss our ESG goals with customers and third parties
• Where to report potential concerns or actions which go against our policy
12.2 On an individual level, you have an important role to play in meeting our ESG objectives. Here’s how:
12.3 Environmental – We all have a role to play in reducing carbon emissions and getting to net zero. While as a business we are setting organisation-level targets, consider the choices you make and the environmental impact. For instance:
• When travelling, are there more environmentally friendly options to take?
• Can some meetings be done remotely instead of travelling?
• Think before you print
• Does the office have recycling and energy saving measures?
12.4 Social – Building a diverse and inclusive workforce where everyone feels valued is everyone’s responsibility. Understanding your role in bringing people together is critical to our success as a business. From hiring the best talent to encouraging all staff to thrive, we want a workplace where people proactively work to be the best. You can help by:
• Challenging and reporting discriminatory or offensive behaviour
• Understanding diversity and inclusion policies
• Being an active ally for groups often underrepresented
• Leading by example in your work
12.5 Governance – Good governance goes beyond having the right policies and procedures in place. It’s about embedding compliance in your day-to-day work. From completing training on time to actively understanding how regulations affect your work, good governance starts from the individual acting ethically. Take governance to heart by:
• Be a compliance champion in your team
• Refer to policies and procedures instead of shortcuts
• Be aware of red flags for compliance failures and risks in your area of work
• Don’t be afraid to call out poor behaviour or report failures
13. ESG and Our Value Chain
13. 1 Our business does not operate in isolation; almost no company does. Value is created through collaboration and partnerships. Similarly, risks can come from not anticipating problems, gatekeeping, and hiding critical information. Traditional risks in supply chains were generally about quality, cost effectiveness and reliability. But seen through an ESG lens, the holistic nature of the third parties, from how they source raw materials to how they treat workers and comply with accepted standards are just as vital.
13.2 A workforce health and safety incident, labour dispute or allegation of corruption can have serious impacts on stakeholders up and down the value chain. The value chain matters, and it is connected. Customers are increasingly voting with their feet and putting pressure on companies to act with ethical decisions in mind.
13.3 Ethical procurement gets to the heart of the value chain. When we consider the entire value chain, from raw material supplier to end use customer, we can better understand the needs and impacts of our business’s decisions within those relationships. Ethical procurement within the context of ESG means paying attention to the carbon impacts of a supplier, and the labour practises of an end-user.
13.4 Considering these impacts doesn’t always mean refusing to work with someone in the value chain where there are concerns. Sometimes suppliers are limited, and
customers have every right to access our services. It’s about understanding the risks within each relationship and taking concerted action to reduce those risks.
13.5 For example, if there are concerns about a supplier’s labour practises, we can ensure clauses are inserted into contracts to maintain an adequate standard of employment for those working for the supplier. This can help actively change labour practises, as opposed to simply refusing to work with a supplier. Or when working with a logistics provider, we might ask for emissions reporting so we can then offset the carbon used.
14. How to Procure Ethically
14.1 Risk assessments: Undertake risk assessment of the value chain in order to identify key vulnerabilities based on supplier and customer needs.
14.2 Real-time tracking: Real-time tracking and traceability over suppliers and movements of goods and services.
14.3 Screening, risk-ranking & monitoring: ESG due diligence on suppliers to evaluate and rank them based on their ESG profile and track record, and monitoring for ESG breaches.
14.4 Investigations: Investigate ESG incidents that take place in the value chain, have remediation plans ready and manage financial and reputational damage.
14.5 Incident response management: Build robust internal governance frameworks to respond to ESG issues in the value chain.
15. Our ESG committee
15.1 Our ESG committee sits directly beneath our board in terms of seniority. The purpose of the committee is to gather and review data from broad parts of the business, then filter and summarise it upwards to the board. The ESG committee is responsible for writing the ESG pages inside the annual report, and producing all information regarding ESG disclosures.
15.2 The aim of the committee is to establish a unified view of ESG, increasing understanding of all three aspects, environmental, social and governance, and to promote robust standards of corporate governance that integrate all these aspects for non-listed real estate vehicles. This will help the industry more effectively integrate ESG factors into the real estate investment decision-making process.
15.3 The key objectives of the committee are to:
• Emphasise the importance of environmental measures, sustainability goals and performance, at all levels of the business.
• Provide best practices on the structure, policies and regulations that impact the business
• Increase understanding and awareness of corporate governance and social aspects that impact the industry
• Implement and promote common and workable standards of corporate governance for the business
16. Monitoring and Enforcement
16.1 We seek to proactively prevent and mitigate instances of non-compliance with this ESG policy.
16.2 Any breaches or concerns, including ethical concerns or potential breaches in our commitment to high ethical standards should be reported as soon as possible through our whistleblowing channels.
16.3 Progress on this policy is reported to the Board on a regular basis. Active participation and engagement at all levels of the business is of great importance to ensure ownership of ESG by all staff. At a minimum, we endeavor to maintain compliance with legislative requirements.
