Environmental, Social, and Governance (ESG) Policy

Introduction

Global Reach Group Holdings (Jersey) Limited and its subsidiaries (‘GRG’) believes in behaving as a responsible business and seeks to have a positive impact on society and the environment.

GRG believes that companies have a responsibility to contribute to the effort to fight climate change and care for nature and the environment; that companies should provide good employment conditions and be committed to diversity by creating an inclusive workplace and offering a productive, safe, healthy and harassment-free environment; and that good corporate governance is essential to long-term success and to ensure companies deliver value for all stakeholders, including shareholders.

This policy sets out how GRG addresses Environmental, Social, and Corporate Governance (“ESG”) matters in order to achieve its goal.

Scope

This policy applies to all locations in which GRG operates.

Responsibilities

Management are responsible for:

• Embedding the policy in local procedures and ensuring awareness among their staff; fostering an open environment for employees to comply with the policy and discuss possible violations.
• Tracking compliance with the policy and taking appropriate action when breaches in the policy are identified.

The Legal department is responsible for:

• Ensuring this policy is maintained in line with board, legal and regulatory requirements, and ESG guidelines and best practices.
• Assisting Management with communication and training needs associated with this policy.​​​

ESG Principles

GRG’s Core ESG Principles are set out below. GRG seeks to:

Environmental:

• Comply with all legal and regulatory requirements
• Continually improve and review environmental performance
• Continually improve and reduce environmental impacts
• Incorporate environmental factors into business decisions
• Increase employee awareness and training​

Social:

• Comply with all legal and regulatory requirements
• Offer work-life balance and good employment conditions to its workforce in a productive, safe and harassment-free environment
• Promote equal opportunities and diversity among its workforce
• Pay its staff the real living wage as a minimum
• Give, and encourage its staff to give, to charity
• Encourage staff to be active and look after their health
• Assess suppliers with regards to ESG
• Measure customer satisfaction

Governance:

• Comply with all relevant laws and regulations and provide a whistleblowing platform for raising any concerns
• Have in place a sound corporate governance structure
• Have a zero-tolerance approach to health and safety matters
• Adhere to high ethical standards and operate free from corruption and conflicts of interest
• Have all the necessary measures in place to fight money laundering
• Have all the necessary cyber security measures in place to protect itself against fraud and other types of cyber crime
• Protect the personal data of all data subjects
• Have in place, and regularly test, a Business Continuity Plan

Monitoring and Review of this Policy

This policy is reviewed annually, as well as when required by the legal department. All related company policies must be aligned to reflect the principles laid down by this policy.