Environmental, Social & Governance Policy

ESG Policy Commitment

The ESG policy of Elm Capital (“the Firm”) 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, clients and counterparties, 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 Firm’s “ESG Commitment”).

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

Fulfilling the ESG Commitment is the responsibility of the Firm’s Senior Management Team.

General ESG Principles

In fulfilling the ESG Commitment, the Firm 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 Firm employees must, in carrying out their duties, adhere to the principles and objectives of this ESG Policy.
• The Firm expects suppliers of goods and services to the Firm and contractors / consultants working for the Firm (and their suppliers and sub-contractors) to adopt policies and standards fully consistent with those set out in this ESG Policy and to achieve comparable levels of performance.

Environmental

The Firm has produced the following objectives as a framework for the introduction of practices to implement the environmental aspects of the ESG Commitment:

• Identifying and managing environmental risks and hazards.
• Including management procedures on environmental factors in business planning and its implementation.
• Communicating on environmental matters freely with government officials, client, suppliers and  employees.
• Promoting environmental principles by sharing experience with regulatory bodies, other companies, and employees.
• 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 clients, suppliers and consultants / contractors in the implementation of these ESG objectives.
• Continuously looking to implement schemes / initiatives, where possible, to improve its environmental performance.
• Integrating recognised environmental best practice into business operations.
• Measuring, where possible, and acting to reduce, the carbon footprint of business activities.
• Focusing on action to conserve resources and energy, to minimise emission to air, water and land and to increase recycling rates.
• Minimising 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.
• Managing and disposing of all waste in a responsible manner in ways that show concern for the environment.
• Ensuring that as many waste materials as possible are recycled via waste contractors and, wherever possible, sing only registered carriers to dispose of waste.
• Promoting environmentally friendly responsible purchasing.
• 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.
• Using digital software to reduce waste.
• Recycling paper products, ink or toner cartridges.
• Recycling packaging materials including cardboard.
• Where possible, reducing consumption of resources by ensuring that lights are turned off in empty areas.

Social

The Firm has produced the following objectives as a framework for the introduction of practices to implement the social aspects of the ESG Commitment:

• Prohibiting any infringement of civil or human rights by the Firm, its officers and employees, and by those in its goods and services supply chains. In particular, by prohibiting any participation in or connection with any modern slavery, child labour or human trafficking.
• Prohibiting any bribery or corruption of, or by, any of its officers or employees.
• Prohibiting any money laundering by any of its officers or employees.
• Encouraging ethical behaviour and decision making within the Firm.
• Ensuring compliance by the Firm with workplace health and safety laws and standards, and mitigating risks to health and safety in the workplace.
• Maintaining suitable privacy and data security measures.
• Maintaining an inclusive and collaborative workplace where the wellbeing of employees is a high priority.
• Promoting diversity and inclusion amongst the Firm’s workforce.
• Providing and maintaining a working environment free from all forms of discrimination, harassment and bullying under any circumstances, for example gender, gender identity or expression, race, colour, creed, religion, nationality or national origin, ethnicity or ethnic origin, ancestry, age, marital status or sexual preference.
• Ensuring that the Firm does not select, engage, place, promote, transfer or compensate or otherwise treat or deal with any employees on the basis of gender, gender identity or expression, race, colour, creed, religion, nationality or national origin, ethnicity or ethnic origin, ancestry, age, marital status or sexual preference.
• Creating a positive and rewarding workplace for the Firm’s employees and actively encouraging all employees to make suggestions to consciously improve the workplace.
• Providing team building activities for employees.
• Providing a fair and rewarding remuneration policy and practise linked to business and personal performance.
• Encouraging and assisting to provide a work/ life balance with a flexible and considerate approach to employment and working practices, including working from home.
• Pursuing a fair and competitive approach to remuneration, working hours and attendance, leave, sick leave and other aspects of wellbeing.
• Providing subsidised employee benefits, including private medical services.
• Making positive contributions to the community by donating to charities / worthy causes.
• Aiming to hold social activities in each year.
• Encouraging employees to participate in appropriate further education and training, provided in-house, which supports their professional development.
• Including employees in the nomination of charities / worthy causes for donation by the Firm.
• Building relationships with suppliers and clients who uphold the Firm’s ethical, environmental and social responsibility.
• Ensuring that the Firm’s services meet all relevant standards of best practice and quality for the benefit of its clients and endeavouring to provide client satisfaction with a view to retaining clients and maintaining a good relationship with them.
• Paying the Firm’s suppliers properly and on time.

Governance

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

• Ensuring that the Firm complies with 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, promoting the use of best practice, setting goals, and establishing accountability.
• Ensuring that the Firm promotes strong oversight and transparency at all levels of its organization.
• Adopting a remuneration policy.
• Ensuring that the Firm maintains exemplary board stewardship and management accountability.
• Ensuring that the Firm adopts and implements adequate internal controls, processes, procedures and proactive risk management.
• 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.
• 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 Firm.
• Cultivating strong and regular stakeholder relationships through transparency and open communications.
• 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 Firm’s business.
• Ensuring that the Firm mitigates risk exposure and builds the resilience of its business to climate change, earthquakes and other catastrophic events.