Diversity, Equity & Inclusion (DEI) Policy

Introduction

This Policy applies to all employees of The ESG Institute Limited ("the Company") and to any worker, contractor, consultant, intern, volunteer, agency worker or job‑applicant who undertakes work on the Company’s behalf. It is issued pursuant to the Equality Act 2017 (Isle of Man), the Employment Act 2006 (Isle of Man) and all related regulations and statutory codes of practice. Nothing in this document removes or diminishes any right provided by those Acts or by subsequent amendments.

The Company is committed to creating a culture that respects and values individual differences, that promotes dignity, equality and diversity, and that encourages everyone to develop and maximise their true potential. Equal opportunity is integral to good employment practice and to the efficient use of our most valuable asset—our people.

Policy Statement

It is the Company’s policy to treat all employees, prospective employees, customers, suppliers and other stakeholders fairly and equally regardless of sex, sexual orientation, gender identity or gender reassignment, marital or civil‑partnership status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, age, disability, union‑membership status or political opinion. Furthermore, the Company will ensure that no requirement or condition will be imposed without objective justification that could disadvantage individuals purely on any of the above grounds. This Policy applies to recruitment and selection, terms and conditions of employment (including pay), promotion, training, transfer, dismissal and every other aspect of the employment relationship.

The Company is committed to the implementation of this Policy and to a programme of action to ensure that it is—and continues to be—fully effective. All staff are required to comply with the Policy and to act in accordance with its objectives so as to remove any barriers to equal opportunity. Any act of discrimination or any failure to comply with the Policy will result in disciplinary action, up to and including summary dismissal.

Every line‑manager and employee has personal responsibility for the Policy’s implementation. Any instance of doubt about its application, or any request for guidance or training, should be addressed to People & Culture. All employees must ensure that their actions, attitudes and behaviour do not directly or indirectly discriminate against applicants, colleagues or third parties.

Protected Characteristics

The Equality Act 2017 (Isle of Man) defines nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origin), religion or belief, sex and sexual orientation. Protection under this Policy is not limited to these grounds; the Company also rejects unjustified discrimination based on any other personal attribute or circumstance.

Types of Discrimination

Direct discrimination occurs when someone is treated less favourably than another person because of a protected characteristic.  Associative discrimination is direct discrimination against someone because they associate with another person who possesses a protected characteristic.  Perceptive discrimination is direct discrimination because others think an individual possesses a protected characteristic, whether or not that perception is correct.  Indirect discrimination arises when a provision, criterion or practice that applies to everyone particularly disadvantages people who share a protected characteristic and cannot be objectively justified.  Harassment is unwanted conduct related to a protected characteristic—or of a sexual nature—that violates an individual’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment.  Victimisation occurs when an employee is treated unfavourably because they have made or supported a complaint or grievance under the legislation or are suspected of doing so.

Our Commitment

We aim to create and maintain a working environment, terms and conditions—including equal pay for equal work—and people‑management practices that ensure no individual receives less‑favourable treatment on the grounds of sex; race; religion or belief; nationality; colour; ethnic origin; age; marital or parental status; gender (including gender reassignment); sexual orientation; or physical or mental disability. We commit to creating an environment in which individual differences and contributions are recognised and valued; ensuring that every employee works in an atmosphere that promotes dignity and respect; providing training, development and career‑progression opportunities to all; reviewing our employment practices periodically to ensure fairness; and treating breaches of this Policy as misconduct.

Responsibilities and Governance

The ESG Institute has overall responsibility for the effectiveness of this Policy. The Chief Executive and the Executive Leadership Team are accountable for implementation and for ensuring adequate resources. The People & Culture Director maintains the Policy, provides guidance, monitors compliance, collates diversity data in accordance with the Data Protection Act 2018 (Isle of Man) and reports annually to The ESG Institute. Line‑managers must apply fair practices, respond promptly to concerns and foster an inclusive culture. Every employee must act in accordance with the Policy, complete mandatory training and raise concerns in good faith.

Procedure

As an equal‑opportunities employer we recognise the need for continual action to promote equality of opportunity. Recruitment, training and promotion decisions are made solely with reference to the requirements of the position. Managers and anyone involved in recruitment, training or promotion receive appropriate training. Employees who are disabled—or become disabled—should inform the Company of any reasonable adjustment that would assist them; the Company will give careful consideration to such requests in line with the Equality Act 2017.

All employees and applicants will be invited to provide anonymous diversity information. The data are used exclusively for monitoring the effectiveness of this Policy. Workforce composition and recruitment outcomes are reviewed regularly and, where imbalances are identified, positive measures permissible under Isle of Man law may be considered.

Employees who harass or treat others less favourably on any prohibited ground will be subject to the Disciplinary and Dismissal Procedure.

Recruitment and Selection

The Company will not discriminate unlawfully in determining who should be offered employment, on the terms on which employment is offered, or by refusing employment. We advertise vacancies as widely as practicable, stating that we are an equal‑opportunities employer and welcoming applications from all sections of the community. Interviews are confirmed in writing or in an accessible format, and reasonable adjustments are made—for example, holding interviews in accessible rooms or allowing candidates to be accompanied by a sign‑language interpreter. Selection criteria are objective, job‑related and consistently applied.

Promotion, Transfer and Training

All criteria contributing to decisions on promotion or transfer must be objective, justifiable and free from bias. Access to training is provided equitably, based on role requirements, legal or best‑practice obligations and personal development needs identified through performance reviews. The Company maintains a consistent approach to occupational training through its performance‑development and appraisal system.

Working Environment and Communications

We strive to avoid gender‑biased language and oppressive terminology in all communications. Inclusive language and imagery are promoted. Flexible working patterns are considered where business needs permit, particularly to support carers and parents.

Concerns and Reporting

If you have concerns regarding inequality of opportunity or discrimination, you should pursue the matter through the Company’s Grievance Procedure. Alternatively, concerns may be raised under the Whistleblowing (Disclosure) Policy if that is more appropriate. No individual will be penalised for raising a concern in good faith. Malicious or knowingly false allegations may, however, constitute misconduct.

Monitoring and Assessment

The Company monitors workforce composition, recruitment outcomes and the number and result of complaints under this Policy and the Bullying & Harassment Policy. The Policy is reviewed at least every two years—or sooner if required by changes in Isle of Man or relevant UK/EU legislation.

Breaches of the Policy

Any employee who fails to implement or adhere to this Policy will be subject to disciplinary action up to and including summary dismissal.

Review

This policy is to be reviewed every two years, or earlier if there are significant changes in law or our operations.

Latest update: June 30, 2025.

This Policy is non‑contractual and may be amended at the Company’s discretion.