The design, implementation, and review of this policy will be governed by the following principles:

• Transparency – we are open and honest about our ESG journey with all internal and external stakeholders.
• Measurement – we use data to steer decision-making, demonstrate impact, and drive continuous improvement.
• Sustainability & Growth – we work proactively and mindfully to demonstrate how working ethically leads to sustainable growth.

Our Environmental Responsibility:

• One Standard – we will align our efforts across locations and revenue streams to identify our most relevant environmental impacts, reduce duplication, avoid confusion, and ensure we are meeting a uniform standard of goals, measurement, and reporting.
• Carbon Net Zero – we will commit to a date by which all our operations will be carbon net zero, ahead of the legal standard of 2050, and build an action plan to meet this commitment.
• Advocacy – we will share best practice with our industry peers, our clients, and our supply chain to encourage wider adoption of environmentally responsible working practices.

• Diversity, Inclusion, Equity & Progression – we will develop a coherent colleague experience across all locations and all levels of the business, which promotes Environmental, Social & Governance Policy 3 engagement, empowerment, and ownership for all our stakeholders, and demonstrates equity of outcomes for colleagues and customers alike.
• Financial Inclusion – we will measure and monitor our impact on the communities we serve, to ensure equity of outcomes for all customers.
• Responsible Use of Data – we will utilise technology to support our drive for financial inclusion, recognising both the capacity and the limit of automation and data to reach the best possible outcomes, and share these insights with our clients.
• Advocacy – we will engage with our industry peers, our regulatory bodies, our clients, and our supply chain to drive standards and create a conduit for cross-sector approaches to build progressive ideas across our industry.

• Embed ESG as a Company Priority – we will involve colleagues from all locations and levels in the development and implementation of our ESG action plan, including ESG perspectives in all projects, planning, and BAU activities.
• Inclusive Design – we will include stakeholders in our product development to ensure our services meet the needs of the broadest possible range of customers and clients, and undertake regular reviews to ensure ongoing accessibility and suitability.
• One Standard – we will develop our Centres of Excellence to drive a high standard of experience for all internal and external stakeholders, and we will encourage innovation and ideas at all levels to continue to raise standards.
• Ethical Business – we will regularly review and update our policies to ensure we remain at the forefront of ethical business practices in our industry and sector, and promote raising standards to competitors, clients, and other businesses.

• Policy Ownership – the policy owner will be Chief Operating Officer.
• Senior Sponsorship – the policy will be represented at Board level by Chief Operating Officer.
• BAU Implementation – the policy will be managed and implemented by Group Social Responsibility & Customer Welfare Manager.

In addition to the roles required for oversight, there will be designated representatives from across different functions within the group. These representatives will be selected on the basis of their interest in ESG, as well as their ability to contribute to their area of expertise as outlined below.