Our internal governance framework includes several key policies, such as the ESG Policy, Code of Ethics and Conduct, Anti-Bribery and Corruption Policy, and Whistleblower Protection Procedure. These policies are reviewed periodically and form part of staff onboarding and ongoing training programs. To support this, and rather than establishing a dedicated ESG team, the company adopts a cross-functional approach where each department—Compliance, Operations, HR, and Technology—contributes to implementing and monitoring ESG practices relevant to their functions. The Compliance department coordinates the tracking of ESG risks and actions across the company. All teams are expected to identify and manage ESG-related considerations in their operations, such as ensuring staff training, monitoring resource use, and upholding ethical practices. This governance model is designed to be practical and scalable while enabling continuous improvement. ESG efforts are periodically reviewed by senior management to ensure relevance and alignment with both business operations and regulatory expectations under VARA.
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