ESG Invest – Code of Conduct

ESG Invest maintains governance structures that support consistent application of this Code. Responsibilities for methodology oversight, analytical execution, data controls and rating approval are clearly assigned. These processes are supported by compliance, risk management and Board-level supervision. Importantly, ESG Invest operates independently from Sustainability Excellence's consulting activities. This independence is reflected in separate management teams, information systems, remuneration structures and decision-making processes.

ESG Invest applies written procedures and review mechanisms to safeguard analytical quality. Ratings and research are grounded primarily in publicly disclosed information, reflecting traceability and equal treatment. Analysts follow documented methodologies that are applied systematically and reviewed periodically. Prior to publication, outputs undergo internal quality assurance checks that validate evidential coherence and interpretation. Analysts receive professional training to ensure consistent methodology application and are supported by ongoing learning frameworks.

Independence is the foundation of ESG Invest's credibility and analytical integrity. The organisation operates structured systems to identify, prevent, manage and disclose any circumstance that could compromise impartiality. This Code embeds our long-standing conflict management framework first formalised in 2014, which continues to shape the ethical expectations applied to all analysts and decision-makers.

The principles underpinning that framework remain central today. Analysts are expected to conduct their work with objectivity by interpreting evidence solely through established methodological requirements; neutrality by resisting any form of external inducement, pressure or influence; equality by applying identical analytical treatment to all entities irrespective of location, profile, stakeholder relationship or client status; and confidentiality by safeguarding any non-public or commercially sensitive information obtained during the analytical process.

Analytical judgement must remain free from commercial, relational or personal bias. Personal beliefs, preferences or affiliations must never interfere with scoring or interpretation. Analysts are prohibited from working on any assessment where a real or perceived conflict exists — including situations involving financial interests in a rated entity, recent employment or business relationships with that entity, or close family links to its management or staff. Where such situations arise, they must be disclosed immediately and the analyst must be recused from the relevant work.

Similarly, gifts, hospitality or in-kind benefits from organisations covered by ESG Invest's work are either refused outright or reported formally to management. Any personal ties or circumstances that could reasonably give rise to a perceived or actual conflict must be disclosed to senior leadership so that appropriate safeguards can be enacted.

To reinforce independence, ESG Invest does not link analyst remuneration to the commercial performance of rated entities or to any commercial outcomes arising from ratings activity.

ESG Invest is committed to explaining the basis and meaning of its ratings and data products. Methodology architecture, scoring principles, data use hierarchy, treatment of limited disclosure and interpretation of rating outcomes are explained in rating reports and supporting materials. While proprietary calibration remains confidential to protect intellectual property, stakeholders are enabled to understand how results were reached and how methodologies may evolve. Significant methodology changes are communicated in advance to give affected stakeholders time to understand potential impacts.

ESG Invest protects non-public information shared during engagement with assessed entities. Confidential materials are used solely for analytical purposes, stored securely and accessed only by authorised personnel. These protections are embedded in internal processes, reinforced through contractual terms and supported by staff training.

ESG Invest engages with rated companies in a structured, fair and independent manner. After completion of an assessment, each company receives a complimentary copy of its ESG Rating Report. This allows visibility into the factors contributing to the rating and highlights disclosure strengths and gaps. Because our assessments rely exclusively on publicly available information, issuance of a draft report enables companies to review factual content. A reasonable review period is provided for companies to verify factual accuracy.

ESG Invest welcomes factual clarification because it strengthens analytical accuracy. Verified factual corrections are incorporated into rating files through a documented quality assurance process. Engagement does not include negotiation of scores or reconsideration of methodology application. The accuracy review mechanism functions as a validation step without influencing analytical judgment or overriding the application of scoring criteria. Issuer engagement is governed by transparency and equal treatment.