Environmental, Social and Governance Policy

Introduction

Fishawack Health (Fishawack Limited; the ‘Group’ or ‘Company’) is committed to operating to high ethical standards at all times. The Group understands its responsibility with regards its environmental impact, the wellbeing of its employees and the positive effect we have on the wider world. The Group therefore expects all employees, vendors, suppliers and third parties with whom we engage to comply with all applicable laws and regulations and to adopt the principles within this policy.

 

Group policy statement

1. Fishawack Health shares and maintains its values of respect, positive working relationships, career progression, work-life balance and quality of work through its interactions with its teams and approach to Environmental, Social & Governance (ESG) considerations. As a Group we are committed to conducting business in a transparent, responsible and ethical manner to ensure Fishawack Health meets and, where possible, exceeds the expectations of all our stakeholders.
2. Fishawack Health’s approach to ESG is incorporated into our business decision-making and is based on a Group-wide framework that identifies and addresses key ESG matters relevant to our business and the sector in which we operate. Our People and Places team coordinates and implements policies in tandem with our Executive Leadership Team (ELT). The People and Places team is responsible for overseeing the implementation of this policy on behalf of the Board and the ELT.
3. Within this document we set out our commitment to integrating the ESG framework into our business practices and how we intend to apply best practices consistently across all our business units and locations.
4. It is to be understood that this policy is a live document and subject to changes commensurate with our commitment to continual improvement.
5. We have established internal processes, oversight and reporting with ESG is reviewed and discussed at ELT and Board level. The Board reviews ESG policies and performance at least annually to ensure the framework is appropriate and that progress is being made against key initiatives and KPIs. Through this approach we seek to ensure that we conduct business in a way which is consistent with our values whilst maintaining growth and strong financial performance.
6. The Chief Operating Officer (COO) is ultimately responsible for the implementation of the ESG policy and has overall responsibility for maintaining an organisation that ensures that all requirements of the policy and associated statutory obligations are met by all employees and visitors/contractors to all sites or other premises under the control of the Group.
7. Fishawack Health is committed to ensuring that the conditions and requirements of the ESG policy are understood and implemented and that all necessary liability is covered by insurance, as well as advising the extent to which risks are acceptable.
8. Fishawack Health will continue to ensure that adequate financial resources are made available such that the aims of the ESG policy can be achieved.
9. The Company ensures we offer opportunities for our employees to partner in our ESG aims.
10. The Board approves and take ownership of the company ESG policy and ensures that there are procedures in place for the policy statement to be adhered to in all aspects.
11. All employees are responsible for working towards the objectives contained within this policy.

Environmental

Fishawack Health recognises that day-to-day operations can impact the environment both directly and indirectly. We aim to protect and improve the environment, whether in our use of our facilities, the communities in which they are based or the wider ecosphere, through good management and by adopting best practices wherever possible. Fishawack Health is working to integrate environmental considerations into our business decisions and consider sustainable alternatives wherever possible throughout our operations.

We aspire to net zero carbon emissions by 2030 and will endeavour to partner with agencies and providers committed to this aim (i.e. World Green Building Council’s Net Zero Carbon). This commitment applies to all our current UK, European and US operations and will be extended to include all future acquisitions.

In all our activities we aspire to:

1. Monitor our landlords, building suppliers, maintenance contractors and agents to ensure our aims align with regards to our Building and Estates policy, including tracking specific initiatives for each office; align all offices to the same set of principles and practices.
2. Monitor suppliers and vendors to ensure compatibility with the aims set out in this policy.
3. Comply fully with all relevant legal requirements, codes of practice and regulations and aspire always to improve.
4. Minimise waste and increase recycling where commercially possible whilst promoting environmentally responsible purchasing.
5. Reduce water and energy use using workable and pragmatic reduction initiatives.
6. Involve customers, partners, clients, suppliers and subcontractors in the implementation of our objectives.
7. Provide suitable training, with measurable outcomes, to ensure employee awareness of environmental impact of our activities.
8. Maximise environmental efficiency of our transport and travel, with specific processes to measure our impact and monitor our progress.
9. Communicate each step and success to the wider Group as appropriate, using internal communications from senior leadership.

Social

Diversity and inclusion

1. Fishawack Health is an equal opportunities employer, treating every one of our teams according to their diverse needs and abilities. We not discriminate against any candidate or employee because of religion, ethnicity, sexual orientation, gender, physical or mental disability, or age.
2. Fishawack Health sponsors and benefits from a Diversity & Inclusion group that meets regularly and maintains its specific policy resultant from relevant monitoring and metrics.
3. As a company whose central mission is health, we have a natural commitment to treating employees fairly and equally, maintaining team wellness and monitoring our diversity and inclusion.
4. We monitor and seek to maintain gender balance within our teams at every level.

Employeee performance and development

1. Fishawack Health has always been committed to the welfare and development of our employees – we have a flat company hierarchy and all members of the ELT have an open-door policy.
2. Staff turnover, absenteeism and growth of headcount are regularly review to understand staff satisfaction and resource needs across the Group.
3. We work to maintain staff engagement through our social clubs and regular events and ensure we reward performance.
4. We run an annual survey to measure engagement and calibrate our values; findings are shared across with all employees.
5. We have a dedicated Professional Development team who seek to ensure employees achieve their goals and maximise their career potential whilst being aware of their wellbeing.
6. We invest in employee development and training and monitor spend in this area.

Philanthropy

1. Whilst as an organisation we decide annual recipients for our charitable donations, each office maintains a culture of giving through bake sales, charity runs and regular events.
2. We utilise our social media channels to promote and celebrate awareness days commensurate with our healthcare objectives.

Health and safety

1. Fishawack Health’s People and Places Team is responsible for overseeing the Group’s health and safety. This includes coordinating monthly planning meetings, regular appropriate training and implementation of ongoing live standard operating procedures to ensure a safe working environment for our teams and locations.
2. We use third party suppliers to maintain and measure our adherence to the latest legislation in an ever-changing landscape.

Governance

Compliance with legal policies and ethical code of conduct

1. Fishawack Health shares and maintains its values of respect, positive working relationships, career progression, work-life balance and quality of work in how it conducts business activities with our staff and our clients.
2. Fishawack Health has put in place the necessary governance and organizational structures to provide appropriate levels of oversight in audits, risk management and potential conflicts of interest. This is supported by a dedicated compliance function which helps to enhance the review and governance of our operations.
3. Appropriate teams comprising specialists have been appointed to establish policies that underpin our values and reflect our commitment to conducting our affairs with honesty and integrity. Policies include but are not limited to:
   • Labour Practices and Staff Welfare
   • Environmental
   • Employee Code of Conduct
   • Supplier Code of Conduct
   • Data Protection
   • Group Expenses and Travel
   • Buildings and Estates
   • Modern slavery
   • Anti-bribery and Corruption
   • Prevention of the Criminal Facilitation of Tax Evasion Policy
4. All employees are trained on core compliance policies such as anti-bribery and corruption, modern slavery, data protection, tax evasion and whistleblowing upon commencement of employment and then on an annual basis; these policies are reinforced through targeted programmes and regular communication.
5. Fishawack Health commits to timely publication of governance reports on all Group websites.
6. Dedicated Compliance, Diversity & Inclusion and People and Places teams formulate, implement and monitor our progress with oversight from the ELT and Board.

Supply chain and modern slavery

1. We have an ongoing commitment to working with partners and suppliers and others to improve their ESG credentials.
2. Through regular training modules and appropriate governance, Fishawack Health is committed to identifying and tackling modern slavery issues in the supply chain and with vendors.
3. Through our Supplier Code of Conduct, we make clear to our subcontractors, consultants and suppliers that they too must maintain effective systems and controls to ensure modern slavery issues are not connected to their supplies and services provided to Fishawack Health.

Compliance with pharmaceutical industry regulations

1. Fishawack Health understands that the pharmaceutical industry is heavily regulated. We work closely with our clients to understand and follow their policies and our contractual requirements and ensure that will fully support them with all laws and regulations relevant to our operations with them.
2. Fishawack Health has a training programme on core pharmaceutical regulations for all employees directly supporting client business to ensure our understanding and compliance in areas such as adverse event reporting, debarment, healthcare professional disclosure codes and pharmaceutical codes.

Communication of this policy

This policy will be regularly communicated across Group with regular updates via the internal communications channels as well as via employee engagement with the principal aims with all of our ESG initiatives. The Board and the People & Places team will maintain dialogue to allow delivery of projects to fulfil the aims of this policy. This policy will be placed on the Fishawack Health corporate website, and that of any affiliate companies.

Contacts

For any queries regarding the ESG policy, please contact any of these individuals. Employees can also direct any queries through their local HR teams.

Brendan Ferretti
Chief Financial Officer
brendan.ferretti@fishawack.com

Jo Wilkinson
Head of Compliance
joanne.wilkinson@fishawack.com

Dan O’Neill
Internal Communications & Engagement Manager
dan.oneill@fishawack.com

Date of preparation October 2020 Version 8.