Fair Pay & Wages Policy

Introduction

The ESG Institute Limited ("the Company") is committed to fair, equitable and transparent pay practices for every employee, regardless of role, location, gender or any other protected characteristic. This Policy applies to all employees of the Company and sets out the principles that govern how pay is determined, reviewed and communicated. It is issued in accordance with the Equality Act 2017 (Isle of Man), the Employment Act 2006 (Isle of Man) and, where applicable, the Minimum Wage Act 2001 (Isle of Man).

Policy Statement

The Company is committed to:

  • Paying all employees at or above the applicable statutory minimum wage in the jurisdiction in which they are engaged, and, where practicable, benchmarking pay against relevant living-wage reference points.

  • Ensuring equal pay for equal work, irrespective of sex, gender identity, race, nationality, disability, age or any other protected characteristic, in line with the DEI Policy.

  • Setting pay based on objective, role-related criteria, including scope of responsibility, experience, market benchmarking and performance, rather than on individual negotiation strength alone.

  • Reviewing pay structures periodically to identify and correct unjustified pay gaps.

  • Communicating pay terms clearly in employment contracts and ensuring timely, accurate payment in accordance with the Employee Handbook.

Pay Setting and Review

Salaries are benchmarked against comparable roles in the relevant market at the point of hire and reviewed at least annually as part of the Performance Development Review cycle. Any proposed pay change is assessed against objective role and performance criteria. The People & Culture Director monitors aggregate pay data, including by gender, to identify any unexplained disparities, and reports findings to the Executive Leadership Team.

Contractors, Consultants and Global Associates

Where the Company engages contractors, consultants or associates (including trainers and advisors operating across our international network), fees are set with reference to market rates for the relevant jurisdiction, expertise and scope of work, and are documented in the relevant engagement agreement.

Transparency

Employees may raise questions about how their pay has been determined with People & Culture at any time. Concerns about unequal or unfair pay may be raised through the Grievance Procedure or, where appropriate, the Whistleblowing (Disclosure) Policy, without fear of retaliation.

Responsibilities

The Executive Leadership Team is accountable for the overall fairness and sustainability of the Company's pay practices. The People & Culture Director maintains this Policy, conducts periodic pay-equity reviews, and advises managers on its application. Managers must apply pay decisions consistently with this Policy and escalate any proposed exception to People & Culture for review.

Review

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

Latest update: July 2026.

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