1. Introduction

We believe in taking care of our people, creating positive outcomes for our customers, and minimising our environmental impact. These beliefs are ingrained in our culture and core values. They are also key to our mission of becoming an enduring business of consequence.

Our Articles of Association‍—‌the official document that establishes our business‍—‌were updated in February 2024 to cement that Griffin’s core purpose is “through its business and operations, to have a material positive impact on: (i) society and (ii) the environment.”

This policy outlines how we implement these commitments in practice, including how we measure success and hold ourselves accountable.

2. About this policy

2.1. Who owns this document?

The Chief Executive Officer (CEO) owns this policy and delegates implementation to the Head of Sustainability.

2.2. Who does this policy apply to?

This policy applies to all people working for us, or on our behalf, in the following capacities: employees, directors of our Board, agency workers, contractors, interns, or secondees. For the purposes of this policy, we refer to all these people as “employees”. It also applies to our customers, partners, and suppliers.

3. What is sustainability?

At Griffin, we use the term “sustainability” to talk about how we manage environmental and social responsibilities across our business, ranging from how we treat our people, the outcomes we create for our customers, our environmental impact, and more.

3.1. Definitions

4. How we manage sustainability

Sustainability at Griffin is divided into two main areas.

Sustainable operations supports our business, disclosure and reporting, and is overseen by the Sustainability Steering Group. Members of the Sustainability Steering Group comprise the CEO, Chief People Officer, Chief of Staff and CRO.

Environmental, Social and Governance (ESG) risk management provides the framework, policies, guidance, oversight and challenge to integrate the environmental and social standards in alignment with our Enterprise Risk Management Framework (ERMF). This is detailed in Appendix 3 of the ERMF: Application of the risk management framework to principal risks. The CEO has prescribed responsibility for all ESG risks with the exception of climate risk. The CRO has the prescribed responsibility for the oversight of climate risk. The CEO and CRO delegate the oversight of all ESG risks to the Head of Sustainability.

Our Board, Board People and Governance Committees, and Executive Committee provide oversight on sustainable operations and ESG risk management. The Board Risk Committee and Executive Risk Committee monitor ESG risk in line with other level 1 risks defined in our ERMF.

4.1. Our principles

Do no harm. Ensure that we operate with safeguards for human rights, our customers, team, community and partners.

Sustainability at scale. We have the potential to reach millions of individuals and to provide financing and support for others to build and scale their businesses with sustainability in mind.

Progress, not perfection. Perfection is the enemy of the good. Rather than being overcome by analysis paralysis, we are committed to constant improvement and learning.

Transparency. We are clear about what we are doing, why we think it is in pursuit of our objectives, and how we measure success or failure. We are honest about what is and isn’t working, and open to feedback.

Walk before we talk. While transparency and progress are core principles, we will establish credibility through action first and foremost, and also by being aware and honest about our limitations.

First principles, always. When in doubt, we go back to why we’re doing what we’re doing and start from there.

5. Sustainability goals

Our sustainability goals are to:

• Build sustainability into our corporate operating system
• Measure and reduce our climate impact
• Ensure Griffin remains a place where people can thrive and do their best work

5.1. Environmental commitments

• Meet our regulatory requirements, including integrating climate-related financial risk into our business strategy.
• Support the shift towards a low-carbon, net zero economy by aligning our operations, business strategy and investments towards an ambitious net zero target; publish our net zero transition plan.
• Measure and minimise environmental impacts of our business across our value chain, from our own operations to our suppliers and partners, customers and end users.
• Publish an annual report on our commitments and our progress.
• Promote environmental best practices to our employees, customers, partners and suppliers, and industry to build understanding for environmental impacts and how to improve them.

5.2. Social commitments

• Build a People strategy centred around inclusion and belonging.
• Set a diversity and inclusion strategy, with metrics and targets that are measured, monitored and reported regularly.
• Review and share our gender pay gap annually, voluntarily, ahead of any legal requirements.
• Ensure fair working conditions, secure and flexible work, and reasonable adjustments in the workplace.
• Share our Anti-Bribery and Corruption policy against human rights violations publicly and ensure our people know how to recognise and report human rights violations.
• Drive positive outcomes that deliver good value for our customers and society.

5.3. Governance commitments

• Follow national laws and regulations on environmental and social issues.
• Provide ongoing and timely updates to our Board and senior leaders on key sustainability metrics (detailed in Appendix 1).
• Share our environmental and social standards with anyone who requests them..
• Review our Sustainability Policy annually, based on progress, challenges, and changes to our context and external environment, standards and reporting requirements.
• Educate our team, partners and stakeholders on our standards and they can support our sustainability goals.
• Share our progress, including areas for further development, in an annual impact report.

6. Minimum standards

Our minimum standards for our people and operations are:

• do no significant harm to the environment.
• protect essential human rights and prevent violations.

We will continue to review and update our standards as part of our policy review.

6.1. Employee, customer and supplier standards summary

We have developed initial customer and supplier sustainability standards, which are available on request by emailing sustainability@griffin.com and shared during our contracting process. These will evolve over time.

6.2. Policies, procedures and processes

We have a range of policies that align and detail our standards across specific business areas, including, but not limited to, those listed below. For employees, our policies live in Minerva and our procedures directory is documented in Notion.

• Code of Conduct
• Anti-Bribery and Corruption Policy
• Enterprise Risk Management Framework
• Diversity, Equity, Inclusion and Belonging Policy
• ICAAP and ILAAP Scenario Analysis and Stress Testing
• Third Party Arrangements and Vendor Selection Policy
• Speak Up and Whistleblowing Policy
• Customer Eligibility Standards
• New Product Policy
• Economic Crime Policy
• Privacy Policy
• Data Security and Use Policy
• Business Continuity and Disaster Recovery Policy
• ESG Questionnaire
• Customer and Supplier Sustainability Standard
• Employee Environmental Sustainability Standard

6.3. Feedback procedure

Any questions, comments or concerns related to this policy should be directed to sustainability@griffin.com.

Appendix 1. Sustainability metrics

Ongoing reporting

As part of due diligence, pre-onboarding and monitoring processes, we track the number and percentage of customers and suppliers with:

• Sustainability policy and/or goals
• Net zero commitment and/or targets
• Reported human rights issues
• Environment Agency actions against them

We regularly assess and report our:

• Carbon footprint across Scopes 1, 2, and 3
• Carbon intensity (tonnes/employee)
• Annual carbon reduction from our 2022-2023 baseline‍—‌absolute and intensity-based
• % minority gender at Griffin (all employees and Board level)

By the end of 2024, we plan to assess:

• % minority gender for managers and executive team
• % minority ethnicity (all employees, managers, executive team and Board)
• % gender pay gap

We will produce an annual impact report on our environmental and social progress‍—‌either as a standalone report or as part of our annual financial report.