ENVIRONMENTAL, SOCIAL, AND GOVERNANCE POLICY

Updated: June 2026


1. Purpose

This policy sets out XYZ Reality Limited’s commitment to responsible environmental management, strong governance, and sustainable business practices. It ensures compliance with UK legislation and supports long-term value creation for stakeholders.

At XYZ Reality Limited, we understand the importance of acting responsibly as a company and of recognising environmental, social, and governance (“ESG”) issues that impact global sustainability, such as climate change and human rights violations. We acknowledge the importance of identifying and considering ESG issues across all of our business activities to drive responsible growth and create lasting value for our employees, society, and stakeholders. ESG factors and sustainable business practices are also important for analysing investment decisions, with suitable ESG practices impacting business risk and financial performance. This policy will be regularly reviewed and updated to ensure we maintain a responsible approach to ESG issues.

2. Scope

This policy applies to:

  • All employees, directors, and contractors;
  • All business operations and locations; and
  • Supply chain partners (where relevant).

3. Policy Statement

XYZ Reality Limited is committed to:

  • Minimising environmental impact;
  • Conducting business ethically and transparently; and
  • Supporting sustainable economic and social outcomes.

We aim to integrate ESG considerations into all strategic and operational decisions.

    4. Guiding Principles

    Our approach to ESG is built on three pillars: environmental responsibility (reducing the impact of our activities and decisions), social responsibility (acting ethically towards employees, communities, and stakeholders), and strong corporate governance (accountability, transparency, and integrity in how we run the business).

    5. Policy Detail

    5.1 The Environment

    XYZ Reality understands the requirement to protect nature and acknowledges that climate change is a serious issue threatening the environment and the global economy. We are committed to reducing the environmental impact of our activities and decisions and, where possible, encourage environmentally friendly ways of working. Specific steps include:

    • Waste Management: we minimise waste where possible and ensure it is disposed of safely; none of our waste ends up in landfill, with all non-recyclable waste helping to generate green energy.
    • Energy Conservation: we are environmentally responsible with our water and energy consumption and encourage employees to switch off lights, heating, and appliances when not in use.
    • Recycling: we support the concept of a paperless office, encouraging employees to go digital and promoting recycling when this is not possible.
    • Legal Requirements: we aim to comply with all relevant environmental legislation and regulations in the UK and in any other countries where we operate.

    We will regularly review ways to combat climate change and reduce our greenhouse gas emissions to continue promoting a sustainable approach to the environment.

    5.2 Social Issues

    XYZ Reality considers social issues and ethics in our decisions in order to have a positive impact on society, employees, and external stakeholders. Key areas include:

    • Human Rights: we promote and respect human rights, ensuring that, directly or indirectly, we avoid the use of human trafficking, forced labour, and child labour in operations and supply chains under the Modern Slavery Act 2015, and will not finance transactions involving any form of modern slavery.
    • Health and Safety: so far as is reasonably practicable, we protect the health and safety of employees and others affected by our actions by monitoring and mitigating risks and promoting a safe working environment.
    • Discrimination and Diversity: we are non-discriminatory and ensure diversity and equality in our employment procedures in line with the Equality Act 2010.
    • Charity and the Local Community: we encourage all staff to participate in voluntary work, donations, and fundraising events that benefit the local and wider community.

    5.3 Corporate Governance

    At XYZ Reality, we believe it is the primary responsibility of the Board of Directors to govern the company’s affairs efficiently and generate long-term benefits for employees, shareholders, and other stakeholders. Areas we continually monitor and act upon include:

    • Business Ethics: we act with honesty, integrity, and fairness in all of our business dealings.
    • Law: we abide by the laws and regulations of the countries in which we operate and strictly oppose any illegal practices.
    • Accountability and Transparency: we maintain high standards of accountability and transparency, ensuring effective communication with shareholders regarding progress and financial reports.
    • Corruption and Bribery: in line with our Anti-Bribery and Corruption Policy, we ensure there is no bribery or corruption in any of our business dealings.
    • Conflicts of Interest: we identify potential conflicts of interest and take appropriate steps to avoid or mitigate them.

    6. Responsibilities

    Board of Directors

    Holds primary responsibility for governing the company’s affairs, integrating ESG into strategic decisions, and overseeing accountability and transparency.

    All Employees and Contractors

    Support the company’s ESG objectives in their day-to-day work and adhere to environmental, social, and governance commitments.

    Supply Chain Partners (where relevant)

    Are expected to operate consistently with XYZ’s ESG commitments, including in relation to human rights and modern slavery.

    7. Non-Compliance

    Conduct that breaches this policy — including unethical, unlawful, or environmentally harmful practices — will be addressed through the relevant disciplinary and related policies, up to and including termination, and may be reported to external authorities where required by law.

    8. Exceptions

    Any exception to this policy must be documented in writing with justification and approved by the policy owner. There are no exceptions to our commitments on human rights, anti-modern-slavery, anti-bribery, and legal compliance.

    9. Related Policies & Documents

    This policy should be read in conjunction with:

    • Anti-Bribery and Corruption Policy
    • Equality, Diversity and Inclusion Policy
    • Health and Safety Policy
    • Code of Conduct