Environmental, Social and Governance Policy

Policy Scope

This Policy applies to all individuals working for Multiverse Group Limited (Multiverse, our), including directors, temporary and permanent employees.

This Policy covers our corporate approach to Environmental, Social and Corporate Governance (ESG) issues as driven by the company directly, and sets out the way in which Multiverse ensures that all of its activities positively affect society as a whole.

Objectives

Our ESG objectives have been defined based on our current knowledge and ambition for incorporating ESG across our business, both in the near and longer term.

We believe in learning from experience and sharing insights within the business and with the wider community. Therefore, these objectives will evolve as better knowledge, data and research becomes available, particularly in the area of carbon emissions. We are committed to developing our ESG Policy and integration in line with internationally established guidelines and conventions for responsible consultancy and current industry best practices.

This Policy aims to demonstrate how Multiverse works ethically, considering human rights as well as the social, economic and environmental impacts of what we do as a business.

Multiverse is committed to ensuring that any business undertakings are conducted as ethically as possible by following this Policy.

Overall definition of ESG

The three main areas of focus in this Policy relate to the environmental and social impact of any business’s activity, and the manner in which a business is managed. Together, these factors are known as ESG.

ESG processes and procedures focus on non-financial performance indicators that address a company’s approach towards sustainability, its impact on society and the environment, as well as other ethical and corporate governance considerations.

Table 1 below provides examples of the ESG topics. These are a broad overview, and Multiverse will analyse the business’ systematic and idiosyncratic ESG risks.

Multiverse is committed to supporting the goals of the Paris Agreement and supports the recommendations of the Task Force on Climate related Financial Disclosure (“TCFD”). Multiverse also supports the 10 principles of the UN Global Compact outlined in Table 2.

Examples of ESG topics considered

Environmental

1. Climate change
   
2. Natural resources
3. Pollution and waste
   
4. Environment opportunity
   

Social

1. Human Capital
   
2. Product liability
   
3. Stakeholder opposition
   
4. Social opportunity

Governance

1. Corporate governance
2. Corporate behaviour

Principles of the UN Global Compact

Human Rights

1. Businesses should support and respect the protection of internationally proclaimed human rights; and
   
2. make sure that they are not complicit in human rights abuses.

Labour

1. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
   
2. the elimination of all forms of forced and compulsory labour;
   
3. the effective abolition of child labour; and
   
4. the elimination of discrimination in respect of employment and occupation.
   
   

Environment

1. Businesses should support a precautionary approach to environmental challenges;
   
2. undertake initiatives to promote greater environmental responsibility; and
   
3. encourage the development and diffusion of environmentally friendly technologies.
   

Anti-Corruption

1. Businesses should work against corruption in all its forms, including extortion and bribery.
   

The three pillars of ESG

Each element of the ESG framework has been developed from a significant body of thinking which, over time, has resulted in the increased standardisation of terms used to define and describe those individual elements. In this section, we set out our broad interpretation of what those definitions currently include.

Environmental

The depletion of natural resources and the threat of climate change have raised concerns about the environment and the potential financial impact on businesses. Sustainable options are increasingly being considered as part of investment and technological solution choices. The issues are diverse, but the main areas are:

1. Factors contributing to climate change
2. Efficient energy consumption
3. Sustainability of resources
4. The impact of climate change on businesses

Social

Everybody deserves a chance at a life of learning and a top career. That applies to Multiverse’s own people as much as the apprentices we support.

As we build a better system, we're committed to ensuring diversity, equity and inclusion are driving forces in all that we do – from the design and delivery of our programmes, to our recruitment, culture, learning and development.

The main areas of consideration are:

1. Preservation of human rights, and avoidance of any complicity in human rights abuses
2. Equality and diversity amongst employees
3. Non-discriminatory employment practices
4. Ensuring there is no exploitation of child labour or indentured servitude
5. Health and safety
   

Corporate governance

Corporate governance covers the rights and responsibilities of the management of a company – its structures, corporate values, and accountability processes. This relates to the following areas:

1. Robust anti-corruption measures and controls
2. Robust company financials
3. Strong compliant company culture
4. Security & data privacy

ESG core principles

We believe that a responsible approach towards our clients, stakeholders, employees, suppliers, and local communities as well as the environment and society more broadly is an essential part of our business’ success.

We believe that responsible ownership and business success go hand in hand and, as such, Multiverse has embedded consideration of ESG factors throughout its systems and processes.

Our core ESG principles are:

1. Always comply with both the letter and the spirit of the law, wherever it applies.
2. Ensure that all investments using the Multiverse brand take a responsible approach to investing.
3. Ensure that we and our assets always respect human rights and ensure no exploitation of child or slave labour.
4. Ensure there is no bribery or corruption in any of our transactions.
5. Act with integrity at all times in all our business dealings.
6. Always be non-discriminatory (whether on grounds of gender, race, or disability), and adopt equality and diversity in our employment practices.
7. Maintain a culture and policy framework that encourages whistleblowing.
8. Act responsibly with respect to the environment, aiming for a sustainable approach to the use of energy and resources.
9. Ensure that our management structures and policies reflect the need for transparency, accountability, equality, and probity in the management of our business and assets and our oversight of third parties.
10. Comply with industry standard ESG guidelines and best practices, and actively manage ESG considerations and risks effectively.
11. Incorporate ESG issues into our decision-making processes.
12. Be active owners and incorporate ESG issues into our ownership policies and practices – seek appropriate disclosure on ESG issues by the third parties with whom we deal.
13. Promote acceptance and implementation of ESG principles within the industry – work together to enhance our effectiveness in implementing the Principles.
14. Report on our activities and progress towards implementing the Principles.

ESG pillars in detail

This section explores each of the ESG pillars in more detail, including best practice, our current position, and our forward-looking endeavours to enhance our position.

Environmental

How Multiverse’s behaviour impacts or affects the environment: climate change, pollution and waste are prominent considerations.

These are the areas that we consider most pivotal to our ESG compliance and culture and are reviewed and discussed regularly. In particular, the person responsible for this is [Jenny Watson].

Remote Working

Best practice: Fully remote (or hybrid, flexible working policy offering remote working as an option) workforce with tech enabled meetings to be as carbon neutral as possible and support diversity in our workforce.

What we do:

1. Multiverse operates on a Hybrid working model
2. Fully Zoom enabled which allows us to video conference rather than travel to meetings
3. E-bike (Lime) discount scheme available globally for apprentices and staff for improved mobility options as well as further location specific benefits to incentive green commuting
4. Utilise hot desking to ensure employees make best use of our building infrastructure.
   

Paper free

Best practice: completely paper free

What we do: Paperless processes and systems:

1. Electronic systems are used by the finance department
2. Cloud storage is used by all staff as appropriate
3. Use of e-signature software
4. Support technology and paper free workflow processes.

Recycling

Best practice: Recycling all waste

What we do:

1. Recycling bins for paper, cans and plastics
2. All end of life hardware is recycled by third party vendors.

Carbon footprint

Best practice: Low carbon footprint and the use of renewable energy

What we do: Currently working on a Net Zero plan for Multiverse

Development steps to be considered: Multiverse Net Zero Plan

Social

The social pillar refers to Multiverse’s social licence, i.e., a sustainable business should have the support and approval of its employees, stakeholders and the community in which it operates. For example, treating employees fairly and being a good neighbour and community member, both locally and globally.

Equal Opportunity Employer

Best practice: We are an equal opportunity employer, with a mission to create the change we want to see in the world inside and outside of Multiverse.

What we do:

1. Performance management framework
2. Appraisal system
3. Diversity and inclusion policy
4. Collecting information about Multiverse’s culture through employee engagement surveys quarterly
5. Robust staff DEI monitoring in relation to ethnicity, gender, age, disability, neurodiversity, sexuality & socioeconomic background
6. Gender pay gap reporting
7. We have a calendar of DEI events, resources and training for the year
8. We are committed to building a workforce that is representative of the communities we serve. Creating equitable opportunities for progression through a number of Leadership Development Programmes that we offer.
9. Collect equal opportunities data during the recruitment process
10. Consideration of job roles and potential reasonable adjustments that can be made to open the roles to a wider pool of talent
11. Inclusive Recruitment Training to all staff involved in the hiring

Development steps to be considered:

1. Continuing to build on and evaluate our training programmes and events.
   We're committed to improving the diversity of our workforce, at all levels.
2. We continue to invest in early talent through our in-house apprenticeship scheme – something we know is a fantastic route into our organization for exceptional talent from a diversity of backgrounds.

Financial Health

Best practice: Consider the best financial health of our employees

What we do:

1. Pay above the living wage and above £NMW for all employees (including apprentices)
2. Health benefit offered to all staff, including discounts on gym memberships

Development steps to be considered:

1. Review salaries annually in line with the living wage recommendations for the localities in which we operate

Financial support

Best practice: Support employees financially in times of personal stress / hardship

What we do:

1. EAPs available through Bupa cover including access to specialist legal and financial helplines.
   
2. All employees are given the option to enrol onto medical insurance schemes, and further financial support schemes to help with the ongoing cost of healthcare.
   
3. All employees are enrolled into a company life insurance scheme

Physical and mental health

Best practice: Ensure the physical and mental health and wellbeing of all employees

What we do:

1. Access to Health Insurance
   Life Insurance
   Access to Mental Health Support
   
2. UK - Cashback on everyday appointments (eg opticians, dentist, physiotherapy etc).
3. US - Dental and Vision Plans.
   
4. All employees have access to up to 6 free therapy sessions via Spill.
   Retirement offering
   
5. GymPass, Access to free or discounted Gym Memberships. Also have access to premium apps such as MyFitnessPal(Nutrition), Headspace (Mental wellbeing), Strava (Fitness App)
   
6. Access to discounted Lime Bikes
   
7. 6 months free to Blinkist (Book reading)
   
8. 3 months free of Pergola (e-book platform)
   
9. 12 months free of Tortoise (newsroom platform)

Anti-slavery and human trafficking

Best practice: Multiverse is absolutely committed to preventing modern slavery and human trafficking in its corporate activities and to ensuring that our supply chains are free from modern slavery and human trafficking

What we do:

1. Anti-slavery and human trafficking policy
   
2. Regular training
   
3. Clear routes to report issues

Governance

Governance includes Multiverse’s leadership, executive pay, audits, internal control and the interests of our clients and stakeholders.

Anti-corruption

Best practice: Robust anti-corruption measures and controls

What we do:

1. Anti-bribery policy
   
2. Background Checks ensuring all staff and Board members are fit and proper

Company finances

Best practice: Robust company financials

What we do:

1. Strong audit processes
2. 
   Strong balance sheet

Culture

Best practice: Strong compliant company culture

What we do: Company values incorporated from induction, through to appraisals to embed good culture

Security & Data Privacy

Best practice: Security & Data Privacy

What we do:

1. Annual data privacy training
   
2. Annual cyber training of staff
   
3. Independent Data Protection Officer and Privacy lead
4. Operate Jumpcloud central identity management
   
5. Cyber related policies: IT Acceptable Use,
   Information Risk,
   Information Security,
   Passwords,
   Data Protection,
   IT Governance & Risk, Record Retention
   
6. Phishing awareness program
   
7. Regular vulnerability monitoring
   
8. Planned preventive maintenance schedule which includes regular security checks and activities (including patching)
9. 
   Office IT resources have offsite backups
   
10. Full end-point protection including antivirus, firewalls and Mobile Device Management across all sites and user hardware
11. 
    Email protection services
    
12. Multi factor authentication through JumpCloud SSO
    
13. Regular account reviews including privileged accounts
14. Annual pen test of infrastructure
    
    
    
    
    
    

Monitoring

Multiverse seeks to ensure that we maintain appropriate levels of oversight in the areas of audit, risk management and conflicts of interest, and will commission independent due diligence where appropriate. The companies’ financial and reputational risks are frequently assessed throughout Multiverse’s robust monitoring process.

Multiverse will monitor and assess the progress towards the objectives outlined in section 3. This will be discussed in executive committees, form part of our management information and also be taken to board once a year for review.

Approval, Review and Version Control

The Policy will be reviewed annually by [Tara Haig], [General Counsel], as the authorised person responsible for the Policy. The Policy may, however, also be updated following any material changes by other members of the business.

Revision control

1. Version number: 1.0
2. Author: Izzy Duffy
3. Amendments made/ Reason for change: Creation of policy
4. Approved by: [Tara Haig]
5. Date approved: 21.06.2023