2022 Communication on Progress

Adamantem Capital Holdings Pty Ltd

Published date

June 28, 2022

No. of questions

64

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    Optional comment
    This COP is prepared as at 30 April 2022, reflecting the position in our business at that point in time. For any questions requiring specific measurements undertaken during a reporting period, we have adopted our financial year and include the data collated from 1 July 2020 to 30 June 2021. For the purposes of the responses in this COP 'Company' is taken to mean Adamantem Capital Holdings Pty Limited (Adamantem Holdings) and/or its key operating subsidiaries Adamantem Capital Management Pty Ltd (Adamantem Capital) and Melior Investment Management Pty Ltd (Melior) (together, the Adamantem Group). Where appropriate, additional explanation will be included detailing the actions undertaken by the respective entities of the Adamantem Group. The Adamantem Group considers our stakeholders to be our employees, investors, investee businesses and our suppliers (as appropriate) (Stakeholders). Adamantem Capital and Melior each issue an annual statement in the form of the Adamantem Capital Responsible Investing Report (Adamantem RI Report) and Melior Impact Report (Melior IR Report), that address their respective approaches to achieve the Adamantem Group's goal of delivering outstanding financial returns alongside positive social and environmental impacts, contributing to sustainable change and a better future beyond our stewardship through our approach to responsible and impact investing. Organisational sustainability targets and environmental, social and governance reporting is overseen and signed-off by the Boards of each of Adamantem Holdings, Adamantem Capital and Melior (as applicable). The Board Charters for each board specifically include a responsibility to oversee and approve organisational sustainability initiatives throughout the Adamantem Group, which include reporting obligations and action plans, emissions reduction targets, diversity and other sustainability targets. At an investment level, Adamantem Capital's and Melior's investment activities are conducted in accordance with their respective Responsible Investing Policies. The Adamantem Investment Committee is responsible for overseeing and implementing sustainability targets for Adamantem Capital's investment portfolio companies (Portfolio Companies), in line with its Responsible Investing Policy. The Boards are regularly informed about sustainability risks through the Adamantem Group Risk Management Framework, which is aligned to the principles of Australian Standard ISO 31000:2018 and includes a range of sustainability related risks.

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Adamantem Group commitments to sustainability within our own operations include: - Human rights and labour rights - the Adamantem Group has a comprehensive suite of employment related policies. The Adamantem Group also voluntarily reports under the Modern Slavery Act. - Environment - Adamantem Capital has in place a Climate Policy, which sets out our approach to climate action and is publicly available on the Adamantem Capital website. Adamantem Capital and Melior are public supporters of Task Force for Climate Related Financial Disclosures and the goals of the Paris Agreement - see https://www.fsb-tcfd.org/supporters/ and https://www.adamantem.com.au/about-private-equity/. Each of Adamantem Capital and Melior also undertake annual Carbon Neutral certification by Climate Active. - Anti-Corruption - the Adamantem Group has policies and procedures in place to monitor and manage the risks of corruption however, it does not currently make these publicly available. The Adamantem Group demonstrates commitment to sustainability in our supply chain through the Adamantem Group Responsible Procurement Policy, applicable to all new material suppliers doing business with the Adamantem Group, which mandates a Supplier Code of Conduct that addresses ESG issues (including human rights, labour standards, Indigenous rights, anti-corruption, privacy and modern slavery). Each of Adamantem Capital and Melior consider human rights, labour rights, environment and anti-corruption issues more broadly as part of the ESG risks and opportunities integrated into investment decision-making and active corporate stewardship in accordance with the Adamantem Capital and Melior Responsible Investing Policies.

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Adamantem Group's Policies and Procedures manual has been developed in compliance with all legal and regulatory requirements in Australia, and contains a number of policies regulating employee codes of conduct with respect to sustainability topics, including: Acceptable Workplace Behaviour Policy that outlines the code of conduct applicable to all staff, based on principles of fairness and respect; and provisions encouraging employee action with respect to the environment and sustainability. Additionally, Anti-Corruption conduct is addressed by the Anti-Bribery Policy and Conflicts of Interests Policy (included in the Adamantem Group Compliance Manual), as well as the requirement to maintain the Gifts and Entertainment Register. With respect to our suppliers, the Adamantem Group has in place a Responsible Procurement Policy that is applicable to all new material suppliers doing business with the Adamantem Group, which mandates a Supplier Code of Conduct that addresses ESG issues (including human rights, labour standards, Indigenous rights, anti-corruption, privacy and modern slavery).

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Adamantem Group employs a dedicated responsible investing professional, the Managing Director, Responsibility and Impact, whose role specifically includes assessing and managing sustainability related risks and opportunities with respect to both our internal operations and our investment businesses. The Managing Director, Responsibility and Impact is responsible for identifying, monitoring and reporting on certain sustainability risks and opportunities to the relevant Adamantem Group Boards and Risk Committees, and overseeing the implementation of the risk controls specified in the Adamantem Group Risk Management Framework. The Managing Director, Responsibility and Impact oversees the Adamantem RI Report and the Melior CEO oversees the associated Melior IR Report, which cover progress on sustainability topics in relation to our investments. The Adamantem General Counsel is responsible for Anti-Corruption and maintains the Adamantem Compliance Manual, AML/CTF Program and Anti-Bribery policies and their implementation.

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    Each of these sustainability topics are formally addressed in the Adamantem Group Risk Management Framework which is considered by the Adamantem Capital and Melior Risk and Compliance Committees which report to the Adamantem Capital and Melior Boards, respectively. The Board Charters for each of these Boards specifically include a responsibility to oversee and approve organisational sustainability risks and initiatives throughout the Adamantem Group. At an investment level, the Adamantem Capital Investment Committee is responsible for investment decision making in line with our mandate for ESG, as outlined in the Adamantem Responsible Investing Policy.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The Adamantem Group identifies, analyses, evaluates, monitors and reports on risks arising in its businesses in accordance with the processes set out in its ISO 31000:2018 aligned Risk Management Framework. This Framework accommodates the Adamantem Group’s organisational and governance structures and the appetite for certain risks that the Group is willing to accept to achieve its strategy. To identify business risks, the Adamantem Group analyses all of its business processes and events that could impact these processes. Each risk is assigned a risk owner, who leads the relevant department within the Group. A controls self-assessment is performed to identify appropriate controls to mitigate each business risk. A likelihood and impact analysis is performed in respect of each identified risk, both before and after the application of risk controls. Key Risk Indicators are metrics identified and used to provide early warning as to where a risk may be likely to eventuate or where a control may not been effective. All of these matters are maintained in a risk register. Reporting on the risks, effectiveness of the controls and the occurrence of any key risk indicators occurs quarterly, by each risk owner. The Adamantem Group Risk Management Framework has specific risks to address: unethical supply chain risks, modern slavery risks, workplace physical and mental health risks, climate change risks (including transition risks and physical risks) and compliance with Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) Laws.

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The Adamantem Group Risk Management Framework requires ongoing assessments of material outsourced service providers as well as an outward consideration of reputational risk and any other business relationships that may impact this. The Adamantem Group's Responsible Procurement Policy and associated Supplier Checklist process facilitates an initial assessment of all new material suppliers (all contracts in excess of specified monetary thresholds).

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    In addition to the Adamantem Group's Risk Management Framework processes (see G6), at an operational level, the Adamantem Group has a number of processes in place to identify, prevent and mitigate negative sustainability impacts: - Human and Labour Rights - The Adamantem Group's Modern Slavery Effectiveness Framework requires regular assessment of the effectiveness of the Group's actions to identify, prevent and mitigate the risks of modern slavery. - Environment - Annual carbon footprinting as part of Climate Active Carbon Neutral certification for Adamantem Capital and Melior allows the Group to identify climate risks and implement climate initiatives. - Corruption - The Adamantem Group addresses risks of corruption and bribery through its AML/CTF Processes and Risk Management Framework. With respect to our supply chain, the Adamantem Group's Responsible Procurement Policy requires an active consideration that our purchase of goods and services minimise negative and enhance positive impacts on the environment and society. This includes a consideration of responsibility and sustainability credentials of suppliers. The Policy stipulates that all new material suppliers must agree to the Supplier Code of Conduct, which contains specific obligations with respect to ESG issues (including human rights, labour standards, Indigenous rights, anti-corruption, privacy and modern slavery). At an investment level, Adamantem Capital and Melior each conduct sustainability due diligence with respect to investments in line with the Adamantem Capital Responsible Investing Policy and the Melior Responsible Investing Policy.

    7.1. During the due diligence process, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Optional comment
    The Adamantem Group's Responsible Procurement Policy and associated Supplier Checklist process facilitates an initial assessment of all new material suppliers (all contracts in excess of specified monetary thresholds). ESG due diligence conducted by Adamantem Capital and Melior on all potential investments takes into account ESG risks and opportunities both within the Portfolio Company and Melior investee businesses' (Investee) own operations as well as its supply chain and other relevant stakeholder groups.

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    The Adamantem Group's Acceptable Workplace Behaviour Policy sets out specific grievance reporting processes with respect to discrimination, harassment and bullying complaints, in addition to informal supervisor processes in place. The Adamantem Group has engaged an external provider of whistleblower and ethics service and support and appointed two internal whistleblowing protection officers.

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    The external whistleblower services are available to all Adamantem Group employees and the employees of the Adamantem Capital Portfolio Companies. Complaints can be raised with respect to discrimination, sexual harassment and bullying within the Adamantem Group or any Portfolio Company. The services are confidential. Additionally, the Adamantem Group's Acceptable Workplace Behaviour Policy contains confidentiality provisions to maintain the confidentiality of complainants as far as possible, including with respect to informal processes. Complainants are protected from retaliation through these confidentiality obligations, the ability to make complaints through external service providers, as well as specific victimisation provisions in the Policy.

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Adamantem Group provides operational level grievance mechanisms and processes to all staff and Adamantem Capital Portfolio Company employees (see G8). With respect to specific remedies, to date, any issues have been dealt with on a case-by-case basis.

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    The Adamantem Group conducts annual reviews of its Risk Register, employment policies, Responsible Procurement Policy, Responsible Investing Policies and the Adamantem Capital Climate Policy, which includes a consideration of whether sustainability risks have been adequately addressed, whether controls are effective, or need amendment based on issues arising, changes in laws and regulations, market best practice or lessons learned. Specifically, with respect to material human rights issues, the Adamantem Group takes the following steps to review and capture lessons learned: - Human and Labour Rights - Progress and lessons are captured in the Adamantem Group's Modern Slavery Effectiveness Framework and People and Culture reviews to the Boards. - Environmental Rights - The Adamantem Group conducts an annual review of its carbon footprint as part of the Carbon Neutral certification for each of Adamantem Capital and Melior and tracking progress against the Adamantem Group's Emissions Reduction Plan. - Corruption - The Adamantem Group conducts ongoing monitoring of suppliers through its Responsible Procurement Policy and Supplier Checklist. The Adamantem RI Report and Melior IR Report, allow the Group to share our reflections on lessons learned and progress made by the Group and its Portfolio Companies and Investees against various sustainability goals on an annual basis.

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    We are currently in the process of reviewing our performance incentives to be more explicit in the way they include ESG metrics.

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    2

    Male (%)

    100

    Female (%)

    0

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    0

    Above 50 years old (%)

    100

    From minority or vulnerable groups (%)

    0

    Executive (%)

    100

    Independent (%)

    0
    Optional comment
    The operations and management of the Adamantem Group is run by the Extended Leadership Team which, for the reporting period of 1 July 2020 to 30 June 2021 was composed of 56% women. The Adamantem Group has a Diversity Policy as part of its Policies and Procedures Manual under which it has set Gender Diversity Targets to achieve and maintain 40:40:20 ratios in both employees and the Extended Leadership Team.

    13. Do you produce sustainability reporting according to:

    The Adamantem Group produces annual sustainability reports through the Adamantem RI Report and the Melior IR Report and Melior Proxy Voting Report. Specific sustainability reporting is also produced according to: National/ Local regulation on sustainability - Adamantem Group voluntary Modern Slavery Reporting in accordance with the Modern Slavery Act 2018 (Cth) Task Force on Climate-related Financial Disclosures - Adamantem RI Report climate disclosures with respect to the Adamantem Capital private equity business - Adamantem Group climate metrics and targets in our Climate Policy designed to align with the recommendations of the TCFD Other voluntary frameworks - Adamantem Capital and Melior reporting under United Nations Principles for Responsible Investing - Climate Active Carbon Neutral certification for each of Adamantem Capital and Melior - Adamantem Group Reconciliation Action Plan in accordance with the requirements of Reconciliation Australia to enable our business to sustainably and strategically take meaningful action to advance reconciliation with Indigenous Australians.

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

    Our GHG emissions are certified by an external external emissions auditor in relation to Climate Active Carbon Neutral certification.

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    The Adamantem Group has selected these material human rights issues based on the potential for these issues to be connected with its direct operations, as well as the areas in which it considers it is able to take action or use leverage to create change. No specific incidences of these human rights issues have been identified with respect to the Adamantem Group business. Adamantem Capital and Melior consider a far wider range of human rights issues in their investment decision making processes and active corporate stewardship, based on a materiality assessment in relation to each investment on a case-by-case basis.

    Commitment

    2. Does the company have a policy commitment in relation to the following human rights issues?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Rights of women and/or girls

    2021

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    2022

    Rights of indigenous peoples

    2022

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    The Adamantem Group's policy commitments to human rights issues within our own operations include: - Digital security/ privacy is addressed through the Adamantem Group Privacy Policy, which is drafted in accordance with the Privacy Act 1988 (Cth), as well as the IT Policy which is contained within Adamantem Group Policies and Procedures Manual. - Rights of women and girls are addressed through the Adamantem Group Diversity Policy and Diversity and Inclusion framework, which specify requirements for non-discrimination, equal opportunity and gender diversity targets. The Adamantem Group Acceptable Workplace Behaviour Policy also outlines obligations with respect to discrimination and harassment. - Rights of indigenous people are addressed through the Adamantem Group Reflect Reconciliation Action Plan (RAP), which has been endorsed by Reconciliation Australia. The Adamantem Group demonstrates its commitment to human rights issues in its supply chain through the Adamantem Group Responsible Procurement Policy and Supplier Code of Conduct, which specifically outline requirements for suppliers with respect to privacy and security, non-discrimination and the rights of Indigenous peoples, as well as through our commitment to voluntary modern slavery reporting. Each of Adamantem Capital and Melior consider human rights issues more broadly as part of the ESG risks and opportunities we integrate in our investment decision making and active corporate stewardship in accordance with the Adamantem Capital and Melior Responsible Investing Policies.

    2.1. For each human rights policy, is it:

    Aligned with international human rights standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving human rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of expression

    Digital security / privacy

    The Adamantem Group Privacy Policy has been developed to meet the requirements of the Privacy Act 1988 (Cth), and applies with respect to personal information received by the Adamantem Capital or Melior businesses. The policy was developed with external legal input and is publicly available through the Adamantem Capital and Melior websites.

    Rights of women and/or girls

    The Adamantem Group Diversity Policy and Diversity & Inclusion Framework have been developed to ensure that the Group maintains a diverse workforce and inclusive culture, this necessarily requires respecting and promoting the rights of women. A Diversity Action Plan has been developed with a focus on commitments across the Adamantem Group in the following areas: Attraction and Recruitment; Retention; Training and Development; Recognition and Promotion; Leadership; and Culture. This includes a gender diversity target of 40:40:20 for all employees and the Extended Leadership Team. It was developed with external expert input. The Adamantem Group Diversity Policy and Diversity & Inclusion Framework and Diversity Action Plan have been approved by the Board but arenot publicly available at this stage.

    Access to culture

    Rights of indigenous peoples

    The Adamantem Group Reflect RAP has been developed by a working group with representatives from throughout the Group and approved by the Board. The RAP is developed in conjunction with an Indigenous consultant and in consultation with Reconciliation Australia. The RAP is publicly available on the Adamantem Capital and Melior websites and the website of Reconciliation Australia. The Adamantem Group Responsible Procurement Policy has been approved by the Board but is not publicly available at this stage.

    Free, prior and informed consent

    Rights of refugees and migrants

    Access to water and sanitation

    Optional comment
    These human rights issues are also addressed through the Adamantem Capital and Melior Responsible Investing Policies (see above) which are publicly available on their respective websites.

    Prevention

    3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing /mitigating the risks/impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    The Adamantem Group conducts stakeholder engagement with our investors, suppliers, and investee businesses with respect to human rights issues as follows: - Investors - The Adamantem Group, through its Investor Relations Team and Managing Director, Responsibility and Impact, conducts regular investor engagement specifically on the topic of responsible investing to understand investors' preferences and approaches, and uses the feedback from this process to inform our responsible investing and sustainability initiatives. Members of the Adamantem Capital and Melior Boards also regularly engage with investors on a range of topics, including responsible investing and sustainability. Adamantem Capital is also a member of the RIAA Human Rights Working Group. This contributes to broader industry collaboration on the prevention and mitigation of risks. - Suppliers - The Adamantem Group engages with its suppliers on human rights topics through its Responsible Procurement Process and Supplier Checklist, and regular risk reviews. This assists us to better understand risks. With respect to the rights of Indigenous peoples, the Adamantem Group has engaged Indigenous consultants and collaborated with Reconciliation Action Australia to better understand the risks and impacts and means of addressing them. - Investee businesses - Adamantem Capital engages with its Portfolio Companies to conduct human rights assessments, cyber security assessments and diversity and inclusion initiatives (including gender pay gap assessments). Both Adamantem Capital and Melior engage in public advocacy and direct Portfolio Company / Investee engagement with a view to enhancing action on a range of sustainability topics, including human rights. This allows us to better understand and discuss potential ways to prevent or mitigate the risks/ impacts in question.

    4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Throughout the reporting period, the Adamantem Group has taken the following action to prevent/ mitigate risks: - Training - The Adamantem Group has conducted all staff training on the topics of digital security and privacy, workplace behaviour and diversity and inclusion. The Adamantem Group's RAP process also includes cultural awareness training and staff engagement and capacity building with respect to both our internal operations and the Adamantem Capital Portfolio Companies. - Capacity Building - The Adamantem Group has sought to build capacity in its stakeholders through: (i) engaging with suppliers through our Responsible Procurement process; (ii) engaging with our Portfolio Companies and Investees through our stewardship activities described in the Adamantem RI Report and Melior IR Report; (iii) engaging with the broader investment community through our participation in industry working groups and the publication of sustainability related thought pieces.

    5. Who receives training for the following human rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    Training for digital security and privacy, workplace behaviour, diversity and inclusion, and Indigenous rights are part of the Adamantem Group's annual training and compliance requirements for all staff. Training on these topics is also provided to select employees of Adamantem Capital Portfolio Companies.

    6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    With respect to our own operations, the Adamantem Group takes the following action to assess progress: - Digital Security and Privacy risk is monitored on a quarterly basis through the Adamantem Group Risk Management Framework which outlines Key Risk Indicators and contingent actions to be undertaken in the case of risk occurrence. - Rights of women and girls are assessed through the Adamantem Group Diversity and Inclusion Framework, Diversity Action plan and progress towards diversity targets. - Rights of Indigenous peoples are addressed through the the Adamantem Group Reconciliation Action Plan, which sets targets for actions to be undertaken each year. RAP reporting requires annual review of action plan items and reporting to Reconciliation Australia. External actions taken by the Adamantem Group include: - Progress monitoring with respect to these human rights issues in our supply chain through our Responsible Procurement process and Supplier Checklists and our voluntary modern slavery reporting. - Each of Adamantem Capital and Melior set certain human rights-related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and the Melior IR Report.

    Response

    7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Rights of women and/or girls

    Freedom of expression

    Rights of refugees and migrants

    Digital security / privacy

    Rights of indigenous peoples

    Access to culture

    Free, prior and informed consent

    Access to water and sanitation

    Optional comment
    The Adamantem Group has not identified any human rights issues caused or contributed to requiring remedy during the reporting period.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Please see our responses above and refer to the Adamantem Responsible Investing Report and Melior Impact Report attached to this COP, which outline our policies, initiatives and progress with respect to human rights issues in our investments.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    2021

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    Optional comment
    The Adamantem Group's policy commitments to labour rights principles within our own operations includes our full suite of Employment Policies, which comply with all Australian laws and regulations, including the Adamantem Group Acceptable Workplace Behaviour Policy, which stipulates non-discrimination requirements in respect of employment and occupation for all Adamantem Group employees, and the Adamantem Workplace Health and Safety Policy, which stipulates occupational health and safety requirements. The Adamantem Group demonstrates its commitment to labour rights principles in its supply chain through the Adamantem Group Responsible Procurement Policy and Supplier Code of Conduct, which specifically outline requirements for all purchasing decisions and requirements for suppliers to have commitments with respect to Freedom of Association, Child Labour, Forced Labour, Health and Safety Standards, Working Hours, Wages and Non-Discrimination. Each of Adamantem Capital and Melior consider these labour issues more broadly as part of the ESG risks and opportunities we integrate in our investment decision making and active corporate stewardship in accordance with the Adamantem Capital and Melior Responsible Investing Policies.

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    The Adamantem Group Employment Policies (including our Acceptable Workplace Behaviour Policy and Workplace Health and Safety Policy) are contained within the Adamantem Group Policy and Procedures Manual, which is not publicly available. These policies are applicable to the Adamantem Group operations, were developed with the input of external legal advice and internal legal and responsible investing expertise, and have been approved by the Board. The Adamantem Group Responsible Procurement Policy has been approved by the Board but is not publicly available at this stage. These labour rights issues are also addressed through the Adamantem Capital and Melior Responsible Investing Policies (see above) which are publicly available on their respective websites.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    The Adamantem Group conducts stakeholder engagement with our employees, investors, suppliers, and investee businesses with respect to labour rights issues as follows: - Employees - The Adamantem Group conducts regular staff engagement with respect to Health and Safety issues (in particular mental health in the COVID environment), as well as 360 surveys on leadership, regular supervisor engagement and performance review discussion opportunities. - Investors - The Adamantem Group, through its Investor Relations Team and Managing Director, Responsibility and Impact, conducts regular investor engagement specifically on the topic of responsible investing to understand investors' preferences and approaches, including specifically with respect to our approach to Modern Slavery, and uses the feedback from this process to inform our responsible investing and sustainability initiatives. Members of the Adamantem Capital and Melior Boards also regularly engage with investors on a range of topics, including responsible investing and sustainability. Adamantem Capital is also a member of the RIAA Human Rights Working Group. This allows us to discuss potential ways to prevent and mitigate risks and contribute to broader industry collaboration on the prevention and mitigation of risks. - Suppliers - The Adamantem Group engages with its suppliers on labour rights topics through its Responsible Procurement Process and Supplier Checklist and regular risk reviews. As part of the Adamantem Group's Modern Slavery analysis and reporting, the Group specifically engages with our most material suppliers to assess actions being taken with respect to labour rights within our value chain. This assists us to better understand risks. - Investee businesses - Adamantem Capital engages with its Portfolio Companies to conduct modern slavery assessments and facilitate policy review to ensure compliance with all legal and regulatory requirements with respect to discrimination, OHS and working conditions. Both Adamantem Capital and Melior engage in public advocacy and direct Portfolio Company/ Investee engagement with a view to enhancing action on a range of sustainability topics, including modern slavery and labour rights. This allows us to collaborate in the prevention and mitigation of risks.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Throughout the reporting period, the Adamantem Group has taken the following action to prevent/ mitigate risks: - Training - The Adamantem Group has conducted all staff training on the topics of Modern Slavery (addressing risks of freedom of association, forced labour and child labour), WHS and Mental Health risks. Diversity and Inclusion training was conducted with all staff, as well as select employees of Adamantem Capital Portfolio Companies, addressing non-discrimination and gender pay gap assessments. - Capacity Building - The Adamantem Group has sought to build capacity in its stakeholders through: (i) engaging with suppliers through our Responsible Procurement process; (ii) engaging with our Portfolio Companies and Investees through our stewardship activities described in the Adamantem RI Report and Melior IR Report; (iii) engaging with the broader investment community through our participation in industry working groups and the publication of sustainability related thought pieces.

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    Training for Modern Slavery, Discrimination, WHS and Mental Health are part of the Adamantem Group's annual training and compliance requirements for all staff. Training on these topics is also provided to select employees of Adamantem Capital Portfolio Companies.

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    With respect to our own operations, the Adamantem Group takes the following action to assess progress: - Discrimination and OHS risks are monitored on a quarterly basis as part of the Adamantem Group's Risk Management Framework, which outlines Key Risk Indicators and contingent actions to be undertaken in the case of risk occurrence. - Freedom of Association, Forced Labour and Child Labour are captured by the modern slavery risk assessments on a quarterly basis as part of the Adamantem Group's Risk Management Framework, and are also reviewed bi-annually as part of the Adamantem Group's Modern Slavery Action plan and Annual Statement. Progress is tracked against the Adamantem Group's Modern Slavery Effectiveness Framework. External actions taken by the Adamantem Group include: - Progress monitoring with respect to these labour rights issues in our supply chain through our Responsible Procurement process an Supplier Checklist. - Each of Adamantem Capital and Melior set certain labour rights related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and the Melior IR Report.

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    0

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    0

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    56

    Non-executive board

    0
    Optional comment
    The Adamantem Group does not have a non-executive board. Senior Leadership is determined to be the Extended Leadership Team.

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    38
    Optional comment
    We have conducted a a pay gap analysis at the whole of organisation level, where the gender pay gap is 38% as at 31 March 2022. However, we also conducted a pay gap analysis within each of the five bands of job categories within our organisation. The pay gap within each of these bands ranges from 7% less than men to 15% more than men for job categories with both male and female employees.

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    0

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    The Adamantem Group has not identified any labour rights issues caused or contributed to requiring remedy during the reporting period.

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Please see our responses above and refer to the Adamantem RI Report and Melior IR Report attached to this COP, which outline our policies, initiatives and progress with respect to labour rights issues in our investments.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    Forests / Biodiversity / Land Use

    2021

    Air Pollution

    2021

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2021

    Energy & Resource Use

    2021
    Optional comment
    A key pillar of the Adamantem Group's responsible investing approach is "Environmental Sustainability", which we define as 'responsible involvement with the environment and contribution to climate solutions to avoid deterioration of natural resources'. Environmental sustainability is embedded across our own operations as well as our investment decision making and active corporate stewardship. The Adamantem Group's policy commitment to Climate Action within our own operations include: - the Adamantem Group Emissions Reduction Plan; - Adamantem Capital has a publicly available specific Climate Policy. The Adamantem Group demonstrates its commitment to Climate Action in our supply chain through the Adamantem Group Responsible Procurement Policy and Supplier Code of Conduct, which specifically outline requirements with respect to sustainability and greenhouse gas emissions for suppliers. In relation to those environmental topics for which we have answered "Yes, included within a broader policy", we do not have a specific policy commitment with respect to the Adamantem Group operations however, we consider these as part of the ESG risks and opportunities that we integrate in our investment decision making and active corporate stewardship in accordance with the Adamantem Capital and Melior Responsible Investing Policies.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    The Adamantem Capital Climate Policy has been developed in line with our support for the Paris Agreement and the Task Force on Climate Related Financial Disclosures. It has been approved by the Board and is publicly available on the Adamantem Capital website. It applies to our own operations and investments managed by Adamantem Capital, and was reviewed by an external climate advisory firm. The Adamantem Group's Responsible Procurement Policy has been approved by the Board but is not publicly available at this stage. These environmental topics are addressed as part of the ESG risks and opportunities integrated in our investment decision making and active corporate stewardship through the Adamantem Capital and Melior Responsible Investing Policies, which are publicly available on their websites.

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    The Adamantem Group conducts stakeholder engagement with our investors, suppliers, and investee businesses with respect to environmental issues as follows: - Investors - The Adamantem Group, through its Investor Relations Team and Managing Director, Responsibility and Impact, conducts regular investor engagement specifically on the topic of responsible investing to understand investors' preferences and approaches, and uses the feedback from this process to inform our responsible investing initiatives, including in relation to climate risk and Adamantem Capital's Portfolio Company stewardship environmental activities. Members of the Adamantem Capital and Melior Boards also regularly engage with investors on a range of topics, including responsible investing and sustainability. Both Adamantem Capital and Melior collaborate through support of the goals of the Paris Agreement and Task Force on Climate Related Financial Disclosures - see https://www.fsb-tcfd.org/supporters/ and https://www.adamantem.com.au/about-private-equity/ and Adamantem Capital is a member of Climat International - a private equity collective commitment to emissions reduction, and participated in the AIC campaign to address carbon emissions in the private capital industry. This allows us to discuss potential ways to prevent or mitigate risks and contribute to broader industry collaboration on the prevention and mitigation of risks. - Suppliers - The Adamantem Group engages with its suppliers on environmental topics through its Responsible Procurement Process and Supplier Checklist and regular risk reviews. This assists us to better understand risks. - Investee businesses - Adamantem Capital engages with its Portfolio Companies to facilitate GHG emissions assessments and the development of Net Zero targets. Both Adamantem Capital and Melior engage in public advocacy and direct Portfolio Company/ Investee engagement with a view to enhancing action on a range of sustainability topics, including climate action, biodiversity and emissions reduction. This allows us to collaborate in the prevention and mitigation of risks.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Throughout the reporting period, the Adamantem Group has taken the following action to prevent/ mitigate risks: - Training - The Adamantem Group has conducted Climate Risk training for directors and investment team. - Capacity Building - The Adamantem Group has sought to build capacity in its stakeholders through: (i) engaging with suppliers through our Responsible Procurement process; (ii) engaging with our Portfolio Companies and Investees through our stewardship activities described in our Adamantem RI Report and Melior IR Report; and (iii) engaging with the broader investment community through our participation in industry working groups and the publication of sustainability related thought pieces.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Each of Adamantem Capital and Melior set certain environmental related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and Melior IR Report.

    Air Pollution

    Each of Adamantem Capital and Melior set certain environmental related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and Melior IR Report.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Each of Adamantem Capital and Melior set certain environmental related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and Melior IR Report.

    Energy & Resource Use

    Each of Adamantem Capital and Melior set certain environmental related goals in their investments and tracking, and report on these annually through the Adamantem RI Report and Melior IR Report.
    Optional comment
    Climate Action: The Adamantem Group sets emissions reduction targets in its Emissions Reductions Plan and assesses progress through our annual Climate Active Carbon Neutral certification. Both Adamantem Capital and Melior set specific climate goals for investee companies (see E4.1).

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Adamantem Capital sets Net Zero Scope 1 and Scope 2 emissions targets for its Fund II Portfolio Companies within 10 years of investment. Melior sets the following goals: - 2030 impact goals for its Investees aligned to the SDGs - Science Based Target for its portfolio intensity vs ASX300 in line with a 1.5 degree world (using ClimateWorks 2030 estimates) and tracks this on a quarterly basis

    Energy & Resource Use

    Water

    Melior targets for its portfolio to outperform the ASX300 on water policies and waste reduction policies and tracks this on a quarterly basis

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    Optional comment
    Specific actions to achieve the Adamantem Group's internal Climate Action Targets are outlined in the Adamantem Group's Emissions Reductions Plan, which is reviewed annually by the Board. Environmental risks are tracked in the Adamantem Group Risk Management Framework and reported to the Board. Additionally, the results of the Adamantem Capital and Melior Climate Active Carbon Neutral certifications, including emissions progress are publicly reported. Both Adamantem Capital and Melior report on climate action progress in their investment portfolios in the Adamantem RI Report and the Melior IR Report.

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    As part of the Adamantem Group's Carbon Neutral certification, both Adamantem Capital and Melior purchase high quality carbon offsets to offset any emissions they are responsible for. The Adamantem Group has not identified any other environmental issues caused or contributed to during the reporting period requiring remedy.

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    0

    Scope 2 Emissions

    Emissions (tCO2e)

    3.6

    Scope 3 Emissions

    Emissions (tCO2e)

    184
    Optional comment
    Calculations based on assessments conducted by an external emissions auditor in relation to Climate Active Carbon Neutral certification for the period 1 July 2020 - 30 June 2021.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    Not relevant to the Adamantem business.

    8. Has the organization acted to support climate change adaptation and resilience?

    Optional comment
    To increase operational resilience within our own operations, the Adamantem Group takes the following actions: - adoption of an Emissions Reduction Plan - conducting annual Carbon Neutral certification - other sustainability initiatives. External actions taken by the Adamantem Group include: - the Adamantem Group Responsible Procurement Policy and Supplier Code of Conduct encourage suppliers to take steps to manage the environmental impact of their operations and supply chains - Adamantem Capital has developed a specific Climate Policy and undertaken Climate Scenario Analysis for its Funds to guide investment decisions. - Adamantem Capital includes TCFD reporting as part of its annual RI Report. Each of Adamantem Capital and Melior have processes in place to incorporate climate risk assessment in investment decision making and enhance climate resilience in our investments through active corporate stewardship activities and report on these through the Adamantem Capital RI Report and Melior IR Report.

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    56.67
    Optional comment
    An external emissions auditor calculated the Adamantem Group's renewable energy consumption, based on the electricity usage of each of Adamantem Capital and Melior during the reporting period as part of annual Carbon Neutral calculations. Adamantem Capital purchases 100% Green Power, but the above figure takes into account Base Building electricity usage.

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Not relevant to the Adamantem business.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Please see our responses above and refer to the Adamantem Responsible Investing Report and Melior Impact Report attached to this COP, which outline our policies, initiatives and progress with respect to environmental issues in our investments.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2022
    Optional comment
    The Adamantem Group has in place an Anti-Bribery Policy, Securities Trading Policy, Restricted Trading Protocols, Conflicts of Interest Policy and Gifts and Entertainment Policy to manage the risks of bribery, corruption and insider trading. These are actively managed and monitored as part of the Adamantem Group Risk Management Framework. Quarterly DDQs are sent to all staff to confirm that there are no new interests, conflicts of interests or gifts to be declared. The Adamantem Group also has a sophisticated Anti-Money Laundering (AML) /Counter Terrorism Financing (CTF) Compliance Program in place to address the risk of money laundering through its investment activities.

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    The Adamantem Group has in place an Anti-Bribery Policy, Securities Trading Policy, Restricted Trading Protocols, Conflicts of Interest Policy and Gifts and Entertainment Policy to guide employee behaviour with respect to bribery, corruption and insider trading. Quarterly DDQs are sent to all staff to confirm that there are no new interests, conflicts of interests or gifts to be declared. Any issues identified are discussed directly with the Adamantem General Counsel.

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    Training on anti-corruption topics is part of the Adamantem Group's annual training and compliance requirements for all staff. Training on these topics is also provided to select employees of Adamantem Capital Portfolio Companies.

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    All Adamantem Group employees are required to complete compliance training each year - this includes a variety of Anti-Corruption related topics such as Conflicts of Interest, AML and KYC obligations and Insider Trading - each year, aspects of bribery and corruption are addressed as part of compliance training. Specific AML training is provided for the executive and investment team as required.

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    The Adamantem Group monitors anti-corruption through the Adamantem Group Risk Management Framework, and staff DDQs, which are reported to the Adamantem Capital and Melior Risk and Compliance Committees on a quarterly basis. The AML/CTF Program requires review by the Compliance Officer at least every three years or prior to raising a new fund, whichever is earlier, in addition to review in the case of new law or guidance or a material change to the business.

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    N/A

    Confirmed during the current year, and related to this year

    0
    N/A
    Optional comment
    The Adamantem Group has not identified any incidents of corruption during the reporting period.

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    Adamantem Capital is a member of the Australian Investment Council's Legal & Tax Working Group.

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    Please see our responses above.