Corporate &
Social Responsibility

---

COWELL GROUP (“CG”) CORPORATE RESPONSIBILITY

CG’s corporate responsibility encompasses the way we do business, our people, our clients, our community and charitable support and the environment around us and sustainability issues.

Our commitment to corporate responsibility is underpinned by our core values of agility, integrity, and innovation and through our aim for continuous improvement in our economic, social and environmental performance.

Our people and our clients

We will foster a responsible culture amongst our employees and all those that work with us and aim for the highest standards of corporate behaviour and integrity. This requires strong leadership, clear governance and effective communication to staff of the expectations we have of them and their contribution to these aims.

The shareholders meet with their in-house legal counsel and discuss the corporate responsibility strategy annually and the senior team receives regular quarterly updates. The managing partner receives regular updates on corporate responsibility performance, assesses future risks and opportunities, develops our strategy in this area and is responsible for disseminating this to all employees. Accountability for managing operating risks is clearly assigned to line management.

Formal risk assessments are carried out routinely within our offices. Significant risks are escalated to the senior team, as necessary.

Corporate responsibility leadership is provided by our senior team, chaired by our in house legal counsel, which ensures that corporate responsibility is at the heart of our daily operations and this is communicated effectively across the CG.

Our remit includes:

• assessing risks
• developing corporate responsibility strategy
• reviewing our social, ethical and environmental policies and practices
• encouraging best practice throughout the business
• identifying opportunities to improve the effectiveness and sustainability of the business
• reviewing, agreeing, monitoring and reporting on our corporate social responsibility
• increasing internal awareness of corporate responsibility
• improving stakeholder communication and engagement
• charitable and community support.

Cowell Group believes that the property industry has a responsibility that extends beyond caring for buildings, project partners and occupiers to looking out for vulnerable groups and people in our wider society.
As such, Cowell Group is proud to support a number of charitable causes, including the Variety Club of Great Britain’s work with sick, disabled or disadvantaged children, Fight for Life, University College London Hospital, Side by Side and The Amy Winehouse Foundation.

Our community support is equally varied and diverse. Partners and staff are actively engaged in a wide-ranging programme of community support for schools, professional bodies and where we can use our expertise to contribute to the efforts and livelihood of others.

Environmental sustainability

CG has a clear and comprehensive environmental policy, which includes our commitments to:

- comply with the spirit, as well as the letter of all applicable environmental legislation, approved codes of practice and any other requirements not codified by law to which we subscribe

- co-operate fully and maintain open relationships with all regulatory authorities

- comply with all of the environmental requirements of CGs client base

- continually improve the environmental sustainability of our operations by reducing negative environmental impacts and enhancing positive impacts wherever reasonably practicable

These commitments will be achieved, wherever practicable, by:

• minimising our contribution to climate change by reducing the use of all raw materials, energy, water, and supplies
• preventing pollution of the environment including minimising releases to air, land, and water
• implementing a waste management hierarchy to minimise the quantity of waste produced
• reducing the need for business travel and otherwise encouraging the use of more sustainable forms of transport
• providing environmental progress and performance updates to employees and clients
• ensuring that all employees, persons, and organisations working on our behalf are familiar with our policy
• expecting similar environmental standards from all suppliers and contractors
• Our commitment to sustainable development is underpinned by our core values mentioned above and is reflected in the specific objectives we seek to achieve in our corporate responsibility programme.

CG complies fully with all legal obligations regarding our operation. Our aim is to ensure that projects under our control are managed in a way that incorporates and assesses their impact on the environment. We are committed to increasing staff awareness through training and regular updates.

CG’s corporate responsibility policy statement:

CG is committed to achieving and maintaining high standards of corporate responsibility in its business activities.

Objectives:

• aim for the highest standard of corporate behaviour
• carry out our business according to high ethical standards
• provide our clients with a high standard of service
• become an employer of choice
• improve our environmental performance
• positively contribute to the communities in which we operate

Procedures:

• establish processes for managing our corporate responsibilities
• establish targets, monitor and measure performance
• engage and report back to senior team
• review annually.

---

COWELL GROUP (“CG”) ENVIRONMENTAL POLICY

CG is the trading name of a group of property companies offering a wide range of professional property management, agency and consultancy services for investors and occupiers in the UK. At CG, we recognise our operations impact upon the environment. We are committed to improving the environmental sustainability of our operations by reducing negative environmental impacts, preventing pollution, protecting the environment and enhancing positive impacts wherever reasonably practicable.

We measure and/or monitor our significant environmental impacts, where we have the ability, and set objectives and targets for their reduction. Environmental performance is reviewed annually and against our objectives and targets. Regular updates are presented to the shareholders and senior team by their in-house legal counsel.

We commit to the continual improvement of our environmental management system to enhance environmental performance and protect the environment. To the best of our ability our commitment to this principle extends to the services we provide to our clients.

In accordance with our key principle of improving the environmental sustainability of our business, CG will:

• Comply with all applicable environmental legislation, approved codes of practice and any other requirements to which we subscribe;
• Minimise our contribution to climate change by reducing energy, water and other resource consumption;
• Implement a waste management hierarchy to minimise the quantity of waste produced, and maintain a zero to landfill waste policy at our offices;
• Promote the use of IT communications to reduce the need for business travel and encourage the use of more sustainable forms of transport;
• Ensure environmental responsibility throughout our supply chain by implementing supplier and contractor checks through our procurement procedure.
• Incorporate environmental best practice for procurement including that of paper, stationery and other office equipment;
• and provide environmental progress and performance updates to employees and other interested parties where appropriate.

This policy is reviewed annually, or as circumstances change significantly and is updated as necessary.

---

COWELL GROUP (“CG”) SUSTAINABILITY POLICY

CG is the trading name of a group of property companies offering a wide range of professional property management, agency and consultancy services for investors and occupiers in the UK. We aim to follow and to promote good sustainability practices; to comply with relevant legislation; to understand and minimise the environmental impacts of our business activities and wherever possible help our staff, clients and partners to do the same.

Our Policy aims:

• to comply with all pertinent environmentally related legislation.
• to monitor all forms of our energy consumption to ensure that it remains realistic to our activities, and wherever possible, reduce our energy needs
• to understand our waste streams and hence ensure that we can take steps to positively review our waste
• create targets and programmes to ensure that the waste hierarchy is always used to practical advantage for our office
• to maintain a commitment that no waste is diverted to landfill
• to encourage a sustainable travel − by the promotion of public transport use and electric vehicles; the use of IT systems for meetings − to remove the need to travel for face-to-face appointments
• to recognise our community by pro-actively liaising with local charities and promoting their aims within the business through the use of charitable support that allows staff to participate; by organising office charitable activities that all staff can participate in
• to take steps to ensure, as far as is reasonably practicable, that our supply chain has good environmental credentials, both upstream and downstream. In addition, to ensure that our subcontractors are reviewed annually to ensure that they have an Environmental Policy
• Seeking wherever possible to improve performance, working systems and practices by ensuring that we always seek to reduce the environmental impacts of our business activities through the use of up-to-date technologies and modern working practices
• to integrate sustainability into our business decisions
• to cascade this Policy to all staff.

Health & Safety Statement

In accordance with our key principle of improving the health and safety of our business, CG will commit to provide safe and healthy working conditions for the prevention of work related injury and/ or ill health by; Providing adequate control of the health and safety risks arising from our work activities; Providing and maintaining safe plant and equipment; Ensuring safe handling and use of substances; Providing information, instruction and supervision for employees; Ensuring all employees are competent to do their tasks, and give them adequate training.

Comply with all applicable health and safety legislation, approved codes of practice and any other requirements to which we subscribe; Eliminate hazards and reduce risks; Consult and facilitate participation of our workers in the design and implementation of our health and safety management system; Strive to continually improvement our health and safety management system and review this policy as necessary at regular intervals.

Slavery & Human Trafficking Statement

This statement is made on behalf of CG pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our slavery and human trafficking statement. Our approach as a professional property company is that we always work to the highest of professional standards and comply with all laws and regulations applicable to our business. We expect the same high standards from those parties we engage with and we are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or within any part of our operations.

Our senior team works as a unit to ensure that our Anti- Slavery Policy is complied with and to manage any concerns or breaches. Supplier due diligence Our procurement process includes the verification of every new supplier’s compliance programme. All our suppliers are expected to comply with all laws and regulations and we request information concerning, amongst other things, health & safety, environmental, equality, anticorruption and insurance protection. Supplier responses are verified, and we revert to the supplier in the event of ambiguity or non-compliance. Improvements and monitoring We are review our supply chain protocols and introduce where necessary specific measures to ensure that our obligations under the Act are passed through our supply chain.

These include our efforts to:

• Obtain contractual warranties in new engagements which describe that no slavery is used anywhere in the supplier’s business or by any of the suppliers in its own supply chain and that all necessary policies and processes have been implemented to ensure that this continues to be the case;
• Obtain a contractual right to request compliance-related information and the right to second party audit of suppliers at our discretion;
• Add indemnity provisions and rights to terminate engagements in the event of breach of our Anti-Slavery Policy;
• Ensure risk areas are documented, monitored and taken into consideration in any future contract renewals;
• Train staff on the impact of the Act.