Our ESG Policy

ISSUE DATE: november 2022

POLICY BRIEF AND PURPOSE

Environmental, social and governance (“ESG”) considerations are core to AAB Group including, all stakeholders and shareholders.

This ESG Policy sets out AAB Group’s commitment to responsible ESG practices. The Group shall issue this Policy to each Team Member so that each Team Member is fully aware of the Policy and its aims.

THE PRINCIPLES

AAB Group shall ensure that its business operations comply with the following principles:

HUMAN RIGHTS

  • support and respect the protection of internationally proclaimed human rights; and
  • not be complicit in human rights

LABOUR

  • uphold the freedom of association and the effective recognition of the right to collective bargaining;
  • uphold the elimination of all forms of forced and compulsory labour and freedom for Employees to terminate employment whenever they wish, provided reasonable periods of notice are given;
  • pay wages regularly, on time, and without unlawful deduction;
  • maintain safe and healthy working conditions;
  • not engage in discrimination of any kind on any basis including but not limited to age, disability, race, caste, nationality, gender or gender reassignment, sex, sexual orientation, union membership, religion or belief, disease, disability, pregnancy, ethnicity, or political affiliation and will ensure that Team Members comply the Group’s Equal Opportunities and Dignity at Work Policy; and
  • commit to complying with relevant standards in respect of child labour;
  • commit to not employing forced labour (this includes any work or service that is executed under threat, force, or penalty) or bonded labour where a person works to repay a debt of other Where applicable, the Group will publish an annual Modern Slavery Act statement and will comply with the UK Modern Slavery Act principles; and
  • recognise the importance of equity, diversity, and inclusion and, where applicable, comply with gender pay gap reporting requirements.

ENVIRONMENT

Set and comply with an Environmental Policy which will:

  • support a precautionary approach to environmental challenges;
  • encourage the development and use of environmentally friendly technologies;
  • have regard to the impact of its operations on the environment and wider community and, where appropriate, undertake initiatives to promote greater environmental responsibility; and
  • ensure that it procures and maintains all relevant environment permits and licences for any relevant operations and to handle waste and chemicals properly, safely and in accordance with relevant law.

ANTI-CORRUPTION

  • work against corruption in all its forms, directly or through third parties, whether or not explicitly prohibited by this Policy, including but not limited to extortion, money laundering and bribery as detailed in the Group’s Anti- Fraud, Anti-Bribery and Corruption Policy.

SOCIAL RESPONSIBILITY AND LOCAL COMMUNITY

  • comply with any laws, regulations or conventions in any jurisdiction related to the relationship between an employer and its employees, any potential employee or any trade union, or the health and safety of employees;
  • be aware of the Group’s role in local communities in which it maintains a presence and create stakeholder engagement plans where necessary to measure the impact of the Group’s operations on the communities in which they operate.

GOVERNANCE – OPERATIONAL PROCEDURES

ANTI-CORRUPTION

Team members must comply with the Group’s Anti Fraud, Anti-Bribery and Corruption Policy, Anti-Money Laundering and Prevention of Tax Evasion Policy, and Sanctions Policy in all regards.

SUPPLIERS AND AGENTS

The Group shall use reasonable endeavours to ensure that each Supplier and Agent shall comply with the standards contained within this Policy by undertaking reasonable due diligence in respect of the identity and business practices of each Supplier and Agent.

PAYMENTS AND RECORDS

The Group shall maintain books and records that, in reasonable detail, accurately and fairly reflect the Group’s transactions.

In particular, Team members must ensure that the Group maintains books and records that substantiate that (i) all invoices and other charges submitted to the Group for payment were valid and proper and (ii) no improper payments have been made, directly or indirectly, by or on behalf of the Group to or for the benefit of any person (including a Government Official).

All such books and records must be maintained in accordance with generally accepted accounting principles and applicable sanctions, Anti-Corruption, Anti-Terrorism and Anti-Money Laundering Laws.

No undisclosed or unrecorded funds or assets shall be established for any purpose.

No false or artificial entries shall be made in such books and records for any reason, such as mischaracterising the purpose or recipient of a payment.

No payment shall be approved or made with the agreement or understanding that any part of such payment is to be used for any purpose other than that described by documents supporting the payment.

CONCLUSION

The Group and each Team member must not take any action, directly or indirectly which would cause the Group to fail to comply with any of this Policy. Additionally, each Team member must proactively seek assistance if they become aware of a possible Policy violation. Team members will not be penalised for diminished productivity attributable to their refusal to violate this Policy or for their good faith reporting of a suspected or actual violation of this Policy.

Any failure by Team members to comply with this Policy will result in formal action which may result in dismissal and/or referral for prosecution. If any Team member is in any doubt as to whether any act or omission is proper, they must seek guidance from their line manager. Should this not resolve the issue the Team member should take steps in accordance with AAB Group’s Whistleblowing Policy.

DOCUMENT OWNER AND APPROVAL

The Information Security Manager is the owner of this document and is responsible for ensuring that this procedure is reviewed in line with all other AAB Group Policies.

A current version of this document is available to all team members via the Group document sharing portal.

This policy was approved by the Group Risk & Procurement Director and is issued on a version-controlled basis under his signature.

ESG policy signature

CHANGE HISTORY RECORD

Issue Description of Change Approval Date of Issue
1.0 Initial issue Alan Paterson 1st November 2022
1.0 Annual Review, no changes Alan Paterson 30th November 2023
1.0 Annual Review, no changes Alan Paterson 30th November 2024