Environment, Social and Governance Policy (Dec25)

Introduction

ESG is a set of principles adopted by organisations to promote a long-term sustainable and ethically responsible approach to conducting business. It has similarities with corporate social responsibility but is on a larger and more measurable scale.

We recognise that the legal sector, being of a considerable size and influence, has a duty to prioritise ESG practices to contribute to a more equitable and sustainable future for all. As a firm, we are committed to being climate and socially conscious by improving our sustainability practices and reducing our environmental footprint, understanding the impact our business has on the world and ensuring that effective governance standards are in place. This policy outlines our firm-wide approach to integrating ESG in our business activities.

Purpose

The purpose of this policy is to provide information about ESG factors and to encourage the business and its staff to better understand what can be done on a collective and individual level. It outlines what the firm is doing in each area and how individual staff members can support the firm’s overriding objectives. It does not form part of any contract of employment or other contract to provide services. We may amend it at any time.

Scope

This policy applies to all staff, including managers, consultants and any third-party that we work with.

Responsibility

Nicola Robinson (COFA/Director) has overall responsibility for the effective operation of this policy and any suggestions for change should be reported to them.

Our ESG commitment

We strive to build a sustainable, equitable, healthy, and diverse business culture through a combination of innovative business practices and exemplary ESG performance. We aim to be a good corporate citizen and this commitment informs every aspect of our business, including how we operate, work with clients, support our local community and report progress.

At the heart of this policy is a culture which has sustainability embedded in all our business operations and values.

Our statement on climate change and the environment

We understand that human-induced climate change is one of the greatest threats to our natural world and societies that the world has ever experienced. We do not interpret sustainability simply as ‘doing something green;’ we are committed to doing what we can to be effective by minimising the energy, carbon, water, and waste products which we generate and encouraging our staff to take action on an individual level.

As is highlighted in the Law Society Guidance on climate change, climate-related risks will affect most clients and nearly all areas of legal practice (see Part B, section 2). This includes physical risks (such as extreme weather which may impact the build environment and agriculture) and new climate-related legislation or regulation.

Net zero is a commitment to reduce carbon emissions in line with the 2015 Paris Agreement treaty on climate change.

 Practical steps

As part of our commitment to being a green business, to embed climate awareness into our firm’s culture and help our staff to act responsibly, we have the following initiatives in place:

• Re-usable cups and utensils are provided in the kitchen, rather than single use plastic.
• we aim to be a paperless office by 2028 and currently printing only when necessary,
• All our waste is currently sorted and recycled by our waste management company.
• the use of sustainable office supplies.
• minimise our use of electricity by encouraging all staff to turn off all lights and equipment when not in use and
• ESG/climate change training is mandatory for all staff to educate on the impact of climate change and what net zero is and to empower the making of responsible choices at work and at home.

Please see the section headed ‘Your individual role to play in ESG’ below for details on action you can take on a personal level to be more climate conscious.

Our statement on social responsibility

We are committed to engaging with staff to provide a stimulating, rewarding, dynamic, inclusive, and diverse work environment which supports their professional development as well as their mental health and wellbeing and where all talents can thrive.

To support our commitment to treating our staff well, we have the following priorities:

• Equality, diversity, and inclusion: we are committed to promoting equality, diversity and inclusion towards our colleagues, clients and relevant third parties – see our Equality, Diversity, and Inclusion Policy.
• Flexible working: we have developed flexible and family-friendly employment practices – see our Flexible, Remote and Hybrid Working Policy.
• Health and safety: we are committed to providing safe working conditions and safeguarding the health and safety of our staff and visitors to our premises – see our Health and Safety Policy.
• Mental health and wellbeing: we foster a positive working culture and promote a good work-life balance for staff which prioritises their overall health and wellbeing – see our Mental Health and Wellbeing Policy; and
• Whistleblowing: we have a transparent and confidential process in place for staff to report internal wrongdoing/malpractice which poses a risk to others, without fear of retribution – see our Whistleblowing Policy.

We are also committed to treating our suppliers, clients, and community well. To this end, we:

• support initiatives that benefit the environment, our local community, mental health wellbeing and education
• support local charities.
• sponsorship of local clubs & events

Please see the section headed ‘Your individual role to play in ESG,’ below, for details on action you can take on a personal level to be more socially conscious.

Our statement on ethical governance

We consider governance practices to be essential to creating and preserving value for our staff and clients. This includes a sound approach to corporate governance which aims to go beyond ‘box-ticking’ and embed compliance into the heart of our business.

Our directors and all staff are expected to conduct themselves in accordance with the highest moral and ethical standards. We are committed to ensuring a fair workplace for our staff as well as third parties with whom we work. We have an Equality, Diversity and Inclusion Policy in place to protect against unlawful discrimination and harassment.

We encourage honest and direct communication to resolve issues and concerns in an expeditious manner. We also have an anonymous internal reporting channel which provides an alternative method of reporting suspected compliance breaches, unlawful or unethical behaviour or fraud.

Please see the section headed ‘Your individual role to play in ESG’ below for details on action you can take on a personal level to promote a healthy governance structure in the workplace.

ESG and our reputation

EGS is fundamental to our reputation as a business. We want our staff, clients, and suppliers to be proud to be a part of our business. Part of that pride is understanding how our business makes a positive contribution to the world.

To safeguard against any claims of misrepresentation or greenwashing, we are mindful to accurately state our firm’s targets, progress made against them and climate change credentials in all marketing materials and public communications.

Our responsibility to our clients

We have an obligation to our clients to offer them a competent service. They are at the heart of our business, and, without them, our business would not exist. Part of that commitment is about responding to their needs, hearing their concerns, and committing to high levels of client satisfaction.

Implicit within the need to providing a competent service is compliance with the SRA’s continuing competence obligations. You may need to be able to discuss climate-related legal issues, competently, with clients and potentially encourage clients to engage with climate issues where they are relevant/material to them or their matter.

Where you do not have the relevant knowledge of the impact of climate change on the area you are advising on, you should not advise and should, instead, consult with the client about seeking specialist third-party assistance. Any such agreement to exclude climate legal risks from the retainer, which are/could be material, should be confirmed in writing and informed consent to such exclusions obtained from the client.

Going forward, it may be sensible to consider professional training to develop expertise in that area so that relevant climate change advice can be offered in the future. This would align with the SRA Principle on acting in a way that upholds public trust and confidence in the profession.

The Law Society Guidance on climate change highlights that within property law, in particular, lawyers’ professional duties extend further, to include:

• A duty to exercise reasonable care and skill – to look beyond the narrow scope of a client’s instruction and consider whether and to what extent climate change risks are relevant.
• A duty to warn a client about potential risks – by pointing out risks and liabilities which may arise from action/inaction that negatively contributes to the climate crisis, which should be obvious to the lawyer (they may for example show up in a climate search report), but the client may not appreciate. The character and experience of the client should be considered to determine the extent of the duty to offer advice/information/warnings which are reasonably incidental to the work being carried out; and
• A duty to disclose – to your client all information material to the matter on which you have actual knowledge. In the context of climate change, this means that a lawyer who becomes aware that there are climate legal risks which might impact the client’s interests in the scope of the retainer should disclose these risks to the client in a clear and understandable way.

In property matters, we require advice on all climate change risks to be clearly recorded in writing in the Report on Title.

Client selection

Many clients are increasingly focused on ESG issues and looking to instruct a firm which cares about improving the world around us. It is, therefore, important for our staff to have an awareness of ESG issues, their impact and what it means for our firm. We want our staff to feel proud of being part of our business and the positive impact we have on the world and for this message to filter through to our clients.

Nevertheless, we are aware that not all clients/potential clients prioritise ESG matters. With this in mind, we view this as a positive opportunity to influence change/encourage them to adopt a forward-thinking approach and aim to share skills and experience.

Where individual fee earners do not wish to act for particular clients, on ethical grounds, we ask that they consult with Nicola Robinson before making a decision as to whether to accept instructions/continue to act.

Your individual role to play in ESG

Although we aim to embed climate awareness into our firm’s culture, we all have a role to play and cannot do this alone; all staff play a key role in supporting our ESG objectives on an individual level. Some of the ways you can do this include:

Environmental

• Make it a priority to become carbon literate – have an awareness of the carbon dioxide costs and impact of everyday activities, the ability and motivation to reduce emissions, on an individual, community and organisational basis. See the Carbon Literacy Project website for more information.
• Consider the choices you make and the environmental impact. The Law Society climate change resolution urges solicitors to take the lead in developing a “climate-conscious approach” to legal practice by mainstreaming climate change throughout their daily practice, in so far as it is compatible with their professional duties and the administration of justice. Similarly, the Law Society’s guidance on climate change refers to considering whether climate legal risks may be material to your advice when presented with a new instruction. Where climate-related legal issues are marginal to the subject matter of the instruction, good practice may involve ensuring the client understands how such issues may be relevant. Ensure that you are clear about what advice falls within and outside your retainer and how this relates to your proposed fees.
• Consider whether some meetings can be held remotely instead of travelling. When travel is necessary, consider whether there are there more environmentally friendly options to take.
• Think before you print and turn off appliances when not in use.
• Make use of the energy saving measures in the office.
• Volunteer with a local environmental charity or litter picking group and support environmental awareness days.

Social

• Challenge and report discriminatory or offensive behaviour.
• Treat colleagues fairly and with respect and, if you are a manager, challenge behaviour that does not meet this standard.
• Familiarise yourself with our Equality, Diversity and Inclusion and Ethical Values Policies.
• Be an active ally for groups who are underrepresented.
• Lead by example in how you approach your work.

Governance

• Embed compliance in your day-to-day work – e.g. complete training allocated to you, on time, actively understand how regulations affect your work and commit to acting ethically.
• Be aware of red flags for compliance failures and risks in your area of work.
• Do not be afraid to call out poor behaviour or report failures.

ESG and our supply chain

We have moved away from solely focusing on the traditional risks in supply chains of quality, cost effectiveness and reliability and now also consider the holistic nature of third parties, from how they source raw materials to how they treat workers and comply with accepted standards.

Ethical procurement within the context of ESG means paying attention to the carbon impacts of a supplier, and the labour practises of an end-user.

Monitoring and enforcement

We seek to proactively prevent and mitigate instances of non-compliance with this ESG policy.

Any breaches or concerns, including ethical concerns or potential breaches in our commitment to high ethical standards should be reported as soon as possible through our confidential whistleblowing process.

Active participation and engagement at all levels of the business is of significant importance as we are all working, collectively, to meet our ESG objectives.

Review of this policy

This policy will be reviewed at least annually by Nicola Robinson COFA/Director.

Dec 2025