2022 Communication on Progress

DWF Group PLC

Published date

July 27, 2022

No. of questions

59

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

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

    Optional comment
    Following a comprehensive review of business processes and increased engagement on ESG from a variety of stakeholders the need for a global ESG (Sustainability) strategy was identified. A global ESG strategy will ensure the Group can operate in a cohesive manner to achieve the ESG targets and progress can be clearly monitored. The Group can focus it’s resources on achieving the material issues that our stakeholders have deemed most important and measure how are action. The Board considered the feedback from all stakeholders and approved the global ESG strategy noting the increased alignment between the concerns of stakeholders and those of the Group. Targets have been published and commitment to publish a separate ESG report, in addition to disclosures included in the Annual Report and Accounts. The Board oversees and has overall responsibility for ESG and is supported by the Global Head of ESG and our wider ESG Leadership Group, Risk & Sanctions Committee and Conflicts Committee, who together and are responsible for ensuring that ESG risks are embedded into the Group’s overall risk management framework. On a quarterly basis the Global Head of ESG presents an update on ESG matters to the Executive Board. At least annually, this update will include an update on climate-related risks and how the business is working to mitigate the impact of such risks, as well as maximising any opportunities. The Executive Board and PLC Board also receives annual training on sustainability issues.

    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
    Commitment is visible on the sustainability section on company website, DWF Annual Report & Accounts 2021, DWF's Global Code of Business Conduct, Investor Briefings, ESG Statement & UN COP's since 2017. DWF's Annual Report & Accounts 2022 & our inaugural ESG Report will be visible on our website in August 2022.

    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
    Doing the right thing defines who we are as a business and by following the principles and guidance contained within our Code of Business Conduct, we deliver on our Purpose and help sustain a work environment that is open, inclusive and fair for all, keeping integrity at the heart of our culture. Our Code of Conduct describes how we put our values into practice. It helps us to do the right thing, to ask the right questions and make the right decisions every day. While this Code gives you guidance for certain situations there are specific areas where we have a zero tolerance approach: • Unsafe, illegal or unethical working practices • Discrimination, bullying and harassment • Bribery and corruption • Retaliation against anyone who speaks up and does the right thing To help embed our ESG strategy, certain provisions have changed since the last version of the Code was issued back in 2020, so a refreshed Code will be issued imminently.

    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
    Kirsty Rogers appointed as Global Head of ESG, chairs the ESG Leadership Group which oversees and monitors the implementation of the ESG Strategy approved by the PLC Board and identifies and reports to the Executive Board (and PLC Board) on ESG risks and opportunities, and actions needed to improve ESG in line with the ESG Strategy and evolving internal and external stakeholder expectations. Our ESG Operations Board mobilizes the right people, processes and systems to deliver our strategy and meet our measurable targets.

    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
    The ESG issues most important to all stakeholders of the DWF Group are contained in our ESG strategy which has the engagement of and accountability from our PLC and Executive Boards, along with all levels of leadership right across our business. The oversight provided by the Board and its committees, which includes our ESG Leadership Group, ESG Operations Board, Risk & Sanctions Committee is guided by DWF’s Code of Business Conduct, which applies to every DWF Board member and colleague. The Group Head of ESG, reports quarterly to the Executive Board and at least bi-annually to the Plc Board, on progress to date, ESG risks and opportunities and any actions necessary to ensure we are evolving our ESG strategy and continually meeting ESG expectations of both internal and external stakeholders. The Group COO is our PLC Board Sponsor on ESG and part of the ESG Leadership Group and meets fortnightly with the Group Head of ESG as does the Group Director of Risk & Excellence. The Group Head of ESG sits within the Group Risk and Governance function.

    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 Group’s Risk Management Framework outlines the Group’s commitment and approach to good risk management. The framework is reviewed annually to ensure that it aligns to both the internal and external environment, as well as to the Group’s strategy. Its purpose is to ensure that the organisational approach to risk, is clearly understood and effectively managed across all areas of the business. The framework identifies the roles and responsibilities of everyone at the Group and the integral part that they play in the management of risk. Since the launch of our ESG strategy we have applied an ESG lens when assessing our risks; our review for FY22-23 recommends a designated Principal risk for ESG in our Risk Taxonomy. DWF overall maintains a ‘cautious’ risk appetite, this is tempered with an ‘averse’ risk appetite to criminality and non-compliance in the areas of conduct and ethics. As a Group we will only behave in ways that: • Do not conflict with the Group’s values and are aligned with its risk appetite and business strategy; • Do not expose the group’s capital position or the resilience of its services; • Do not conflict with the Group’s ESG strategy and are aligned with the needs to reduce any negative impact we may have on our planet and communities; • Are aligned with the needs of the Group’s clients and ensure that they are treated fairly; and • Are always in accordance with local laws and regulations. The continuation of ESG integration into our risk management is designed to deliver even more robust processes, to ensure we continue to work with law-abiding businesses that demonstrate responsible business in practice, meeting all legal and regulatory requirements, and support clients to improve their ESG performance, whilst we continue to improve ours. DWF operates a three lines of defence model. First line roles provide service excellence to our clients, whilst managing the risks to delivery of that service. Our second line roles provide expertise, support, monitoring and challenge on risk-related matters. The third line roles provide independent and objective assurance and advice on all matters related to the achievement of objectives. In addition to our internal mechanisms, we have external assurance providers who provide reviews and input to our risk management activity.

    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
    We undertake a rolling programme of supplier categorisation and assurance. Our supplier Assurance suite includes, as a minimum, an ESG questionnaire, a Conflicts of Interest Declaration, and a statement of compliance to DWF's Supplier Code of Conduct. The ESG questionnaire spans a range of topics including modern slavery, respect for the individual, care for the environment, bribery & corruption, human trafficking, anti-money laundering, and criminal facilitation of tax evasion (amongst others). Depending upon the nature of goods/services being sourced, a supplier may also receive additional questionnaires pertaining to data protection, information security, and technical architecture. All new supplier requests are issued with the assurance suite and we are simultaneously addressing incumbent suppliers on a progressive basis. The purpose of our new ESG Client Policy is to improve on the quality and consistency of our risk assessment and decision-making to lead to more informed client acceptance, on the basis of our ESG material factors, with decisions taken at a level appropriate to the sensitivity of the issue concerned.

    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
    Our employment policies and pre-employment screening processes make sure that all our employees have the appropriate rights to work and are employed in accordance with local employment legislation. We believe it is important that all employees are appropriately rewarded for the work they do and in the UK, we are accredited as a Living Wage Employer. Expectations of suppliers are grouped into six key areas: • Human Rights • Health & Safety • Responsible Supply Chain Management • Inclusion & Diversity • Business Integrity • Environmental Management Our process includes details of every Request for Proposal (RFP) participant's compliance assessed through a suite of due diligence checks, which includes a statement of compliance with our Supplier Code of Conduct and a mandatory Ethical Sourcing Questionnaire response. The questionnaire assists with identifying potential areas of risk within the supply chain, and aligns to our Ethical Sourcing Policy, draws from the International Labour Organisation and the Ethical Trading Initiative Base Code, and consolidates input from other stakeholders. Our new ESG Client Policy has been designed to ensure all new clients are being assessed against an ESG Risk Matrix which applies a Red, Amber or Green rating in response to each of the ESG risks.The actions required to be taken to comply with this policy are undertaken prior to and in addition to our regulatory obligations under our Anti-Money Laundering Policy. To help colleagues understand ESG risks, the Executive Board has identified some sensitive areas and sectors, including: - Human Rights - Energy/Natural Resources - Defence - Gambling - Adult Entertainment - Animal Welfare. Business will not be declined simply because it is in one of the sensitive areas and sectors but an escalation process is triggered based on a medium or High Risk Rating. The ESG risk matrix will also be used to assess risks for existing clients to anticipate emerging concerns or as part of the client annual review process.

    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
    As detailed above.

    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
    Our Speak Up Policy, dedicated web service, telephone hotline and email address allows colleagues to raise a concern about a genuine suspicion of malpractice or wrongdoing within the DWF Group. Our colleagues in France follow the Procédure d'alerte professionnelle. All disclosures will be investigated and retaliation against employees who raise concerns under this policy will not be tolerated. Circumstances where colleagues might want to raise a concern include: - Behaviour that harms or is likely to harm the reputation or financial well-being of DWF - Breaches of DWF policies and procedures - Breaches of Lead or Local Regulatory Body Codes of Conduct or Rules - Breaches of employment, environmental, health & safety, human rights legislation and obligations - Fraud, wilful or negligent damage, corruption, bribery, theft or misappropriation - Unacceptable/inappropriate actions, conduct or requests of clients - Ineffective DWF process or system controls - Victimisation, harassment, any form of discrimination or bullying of staff.

    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)

    Optional comment
    Whilst our Speak Up policy is primarily aimed at the DWF community, there may be occasions where clients or other third parties may wish to raise a concern. For the most part, we would expect such concerns to be raised in other ways, such as through our complaints process. However if colleagues are made aware of a concern covered by this policy, we encourage them to report it to their line manager, a Director, a HR Business Partner, or to use the Speak Up service. The Speak Up hotline is a dedicated web service or telephone line, which is manned by external, independent and trained call handlers, thereby enabling colleagues to converse confidentially regarding their concern. Anyone using this service will be provided with confidential support and advice on how their concern will be investigated. At all times we ensure the confidential (where possible) and fair treatment of any persons implicated during any information gathering or investigation, and any action taken will be balanced and proportionate.This can be accomplished confidentially (where possible) without fear of victimisation at work, detriment or retribution for reporting genuinely suspected concerns using the guidelines set out in the policy, even if they later turn out to be wrong. If a colleague informs us of their identity, we will maintain confidentiality where possible. In raising a concern about wrongdoing, only those individuals undertaking the investigation will know their identity. We will not reveal their identity outside of this group except for: - Where we are under a legal or regulatory obligation to do so - Where that information is already in the public domain - On a strictly confidential basis to a professionally qualified lawyer for the purposes of obtaining advice. If there are any other circumstances in which we are required to reveal a colleagues identity outside those identified above, we will discuss this with them first. Under no circumstances will we intentionally reveal a colleagues identity outside of the above without their knowledge.

    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

    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 Risk Committee classifies the Group’s principal areas of risk through the Group Risk Taxonomy. This ensures oversight of the Group’s approach to risk management and the development of management and mitigation approaches, to ensure risks remain, or are quickly brought within, the Group’s risk appetite. The Risk Committee also monitors and reviews the effectiveness of the Group’s compliance function, as well as providing oversight and advice to the Board in relation to future risk strategy. All risks are assessed considering the combination of impact and likelihood and, as risk management is an ongoing process that is centred on the identification of the risks and responding to them proportionately, assessments are reviewed quarterly. This allows us to manage risk to a tolerable level. Risks are assessed by using a risk matrix and our defined risk appetite. The appetite itself, which is set by the Board of Directors, is also reviewed annually. Since the launch of our ESG Strategy, we have applied an ESG lens when assessing our risks; our review for FY2022/23 recommends a designated principal risk for ESG in our risk taxonomy. All colleagues with management responsibilities are responsible for ensuring the key risks within the areas of activity under their management are clearly understood, and that appropriate controls are in place to effectively manage and mitigate those risks. Quarterly Divisional Risk Register reviews and those of the support functions include discussions on emerging risks which are, where necessary, escalated to the Group and Strategic Risk Registers. Our monitoring of emerging risks enables the Group to: • identify and monitor a broad range of potential emerging risks; • take a proactive approach to their risk management and reporting; and • present and implement plans to mitigate those emerging risks which could impact the delivery of the Group’s Strategy.

    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
    During the reporting period, factors linked to Executive pay include our performance on colleague engagement (Employee Engagement Index), % of Executive Board roles held by women, % senior leadership positions held by women, % Ethnic Minority representation in senior leadership positions. Changes to the weighting of performance measures in our incentive structure for 2022/23, in particular introduce a specific element of the annual bonus (10%) linked to ESG performance, whilst maintaining our focus on key financial 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 (#)

    10

    Male (%)

    70

    Female (%)

    30

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    30

    Above 50 years old (%)

    70

    From minority or vulnerable groups (%)

    10

    Executive (%)

    60

    Independent (%)

    40
    Optional comment
    The Board and the Executive Board are committed to building a diverse and inclusive environment where our colleagues can bring their whole self to work and enable our diversity to truly flourish. The Board recognises the value diversity brings to the boardroom, and believes the Board will perform better, and gain wider support for its overall objectives and strategy, if it includes the best people available, who also represent a wide range of backgrounds, skills, experience and views. The Company has aimed to appoint a diverse Board of highly talented individuals, from a mixture of gender, ethnicity and social backgrounds, with a view to the Board meeting the recommendations of both the Hampton-Alexander and Parker Reviews. The Nomination Committee recognises the need for development of a diverse pipeline for succession to senior management within the business itself. Our stretch target of 40% female representation on PLC & Executive Boards by 2025 signals our intent to do better. Female representation on the Executive Board stands at 36% against this target.

    13. Do you produce sustainability reporting according to:

    Data Assurance

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

    The majority of metrics contained within this questionnaire mirror data contained within our Annual Report & Accounts 2022 where a reasonable level of assurance has been applied. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists.

  • 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
    To inform our strategic priorities and ESG metrics, we conducted a detailed independent materiality assessment in order to identify the issues that matter most to our stakeholders, and where we have the most potential to create value aligned with our purpose. Based on the internal and external analysis, a long list of 23 material issues was identified including: Ethics, Integrity, Fraud, Bribery and Corruption - Regulatory compliance, quality management, fair and ethical, competition law, corporate criminal offences, anti-bribery and corruption, anti-money laundering, insider dealing, fraud and financial crime, political contributions Human Rights - Modern slavery and human trafficking, employment rights, respect and dignity, discrimination, bullying and harassment. Employee Health and Wellbeing -Employees mental and physical health, occupational health and safety, promotion of good health, wellbeing, post-Covid ways of working, psychological safety. Good Work - Progression, remuneration (board and employees), living wage, flexible working, incentivisation, fair work, freedom of association and collective bargaining. Technology and Data - Advances in legal technology, data security, automation, tailored technology, privacy, environmentally friendly technologies. To increase transparency and accountability we have set ambitious time-bound ESG targets to make it easier for our stakeholders to review and evaluate our performance.

    Response

    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.

    - Updated Human Rights Statement 2022/improved visibility on remediation - Modern Slavery Statement & Training - Colleague & Client Engagement through ESG related surveys - Launch of global D&I Strategy - May 2021 - Launch of ESG Strategy & Targets - December 2021 - Review of company website to increase transparency of reporting - Launch of a new ESG Client Policy - Refreshed our Business Code of Conduct & Ethics Statement - Updated our Supplier Code of Conduct - Improve the tracking and monitoring of our human rights approach and expand the scope of human rights training provided for our colleagues - Publication of our Inaugural ESG Report - August 2022 - Publication of our Annual Report & Accounts - August 2022

  • 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

    2022

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2022

    Occupational safety and health

    2022

    Working conditions (wages, working hours)

    2022
    Optional comment
    Our approach to the above is to communicate internally via Rubix (our Intranet), Town Halls, Training and engagement Sessions and externally - via ARA, Pay Gap Reporting, ESG Report (August 2022) our Employee Value Proposition, website and ESG reporting indices such as FTSE4Good Series, Eco Vadis & Business in the Community's Responsible Business Tracker . Our Remuneration Policy and Fair Pay Principals are published in the ARA annually. Ahead of its launch, the Remuneration Committee undertook a thorough process to determine the Remuneration Policy, as follows: • The Committee reviewed how the existing Policy has worked in practice over the period it has been in force including pay and performance outcomes. • The Committee considered the Group’s strategy and the best way to align the remuneration. • The Committee received advice from its independent remuneration consultant, Deloitte, on the impact of regulations and current investor opinion. • Pay policies and conditions throughout the Group, including considerations around fairness and equality, were reviewed. • The Committee considered previous feedback received from Shareholders and employees. • The Committee also consulted with the CEO, CFO and COO on the Remuneration Policy.

    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)

    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
    As a professional services business, the relationships we build and sustain are critical to delivering our strategy and ensuring the long-term success of our business.We use a range of engagement mechanisms in order to understand and consider stakeholder views in the Board’s decision making and general oversight. Within our Annual Report & Accounts 2022, we set out who our key stakeholder groups are. By illustrating why each stakeholder group is important to us and through the engagement methods we use with them, we are able to demonstrate what is important to each stakeholder group. This ultimately informs the decision making of the Board and the Group as a whole.

    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)

    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)

    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)

    Performance

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

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    0
    Optional comment
    All employees are free to join collective bargaining agreements. In 2019, DWF became a strategic legal partner to BT and a number of staff from BT transferred to DWF. In doing so, DWF recognised Prospect. Current coverage is 0.05%.

    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 (%)

    DWF supports the principles of Human Rights set out in the Universal Declaration of Human Rights and the International Labour Organisation (ILO) core labour standards. In doing so, we also comply with the ETI Base Code, an internationally recognised set of labour standards based on ILO conventions. In 2019, DWF became a strategic legal partner to BT and a number of staff from BT transferred to DWF. In doing so, DWF recognised Prospect. Current coverage is 0.05%.
    Optional comment

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

    Percent of women (%)

    Unknown

    Senior leadership level position

    36

    Non-executive board

    50
    Optional comment
    The Plc Board and the Executive Board are committed to building a diverse and inclusive environment where our people can bring their whole self to work and enable our diversity to truly flourish. We encourage and support our people to take ownership and responsibility for our inclusion agenda. We have achieved and exceeded our target of at least 33% female representation on the Executive Board by 2022 (now 36%), following the commencement of our new Executive Board which took effect on 1 May 2021. Gender representation at senior levels is 39%.

    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 (%)

    Our current mean pay gap is 35%. We reported on our UK gender and ethnicity pay gap for 2021 in March 2022. The figure above is the combined mean figure for both employees and self-employed partners. For both hourly pay rates have been used. The full 2021 Gender and Ethnicity Pay Gap Report is available on our website at dwfgroup.com.
    Optional comment
    While we are working hard to speed up the pace of change in our business, there is a gender pay gap due to the fact that we have more men at senior levels in higher-paid roles. We are taking targeted and sustained action where there is currently under-representation, and we are making positive progress. We know that changing decades of imbalance in our business and sector is going to take time, but we are committed to addressing it. This sustained focus on meaningful actions will result in a more diverse workforce, supported and empowered through our inclusive culture and values.

    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

    2
    Optional comment
    2 injuries during the reporting period. Both incidents occurred due to illness - fainting & allergic reaction (not work related). There have been no accidents reported from 1 January 2022 to date. There have been no reporting of Injuries, Diseases, dangerous Occurrences Regulations (RIDDOR) between 2019 to date and no environmental incidents. Whilst the provision of HS&E accountability is with the Director of Workplace and Property, the Group HS&E Manager has overall responsibility for Health, Safety and Environmental provisions within DWF as well as Business Continuity Planning. The HS&E Team also currently compromises of a HS&E Adviser.

    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
    Optional comment
    Only 2 injuries reported as above. No working days lost. Since August 2021, health & safety audits have taken place across our Leeds, Glasgow, Bristol, Birmingham, Edinburgh, Manchester and Newcastle offices.

    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)

    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.

    Globally, we are proud as a signatory to the UN Global Compact to have continued to participate in Target Gender Equality, to help implement the Women’s Empowerment Principles and strengthen our contribution to Sustainable Development Goal 5, which aims to achieve gender equality in terms of representation, participation and leadership in business globally. In the UK, we are proud to be recognised as: • a Times Top 50 Employer for Women 2021 & 2022 • a Stonewall Diversity Champion • a Top 30 Employer for Working Families; • a Top 75 Employer in the Social Mobility Index; • a Disability Confident Leader; • Gold Standard in the Employer Network for Equality & Inclusion’s TIDE (Talent Inclusion & Diversity Evaluation) benchmark; and • a UK Living Wage Employer. In March 2022, we published our fifth gender pay gap report and marked the second time we voluntarily included details of our ethnicity pay gap. We continue to implement a global Diversity & Inclusion strategy which includes a commitment to initiate global gender pay gap reporting by the end of 2022 and, in addition to ethnicity, to publish UK pay data by disability & LGBT+ by 2023. The positive trajectory is a strong indicator that consistent application of our guiding pay principles, coupled with the evolving good practice across recruitment, succession planning and promotions is having an impact and we will continue to ensure that everyone at DWF is valued and rewarded fairly for the work they do. However, the issue remains that our pay gap is largely the result of having more men at senior levels in higher paid roles and a higher proportion of women relative to men in roles that fall within our lower pay quartiles. The representation of females in our upper pay quartile has fallen by 7 percentage points and more men than women received a bonus. The new D&I targets signal our intent to do better to accelerate the pace of change. In 2021, we launched our employee value proposition (EVP) to position DWF an employer of choice in a competitive labour market, and to make our brand accessible to new talent. Our business thrives on empowering each other to share experiences, ideas and where our colleagues feel valued, recognised and can be themselves. DWF Life brings together all of the essential elements of what it means to be a part of DWF, ensuring that together all of our colleagues continue to make DWF a great place to work. We continued to develop and support our internal talent, so that everyone has an opportunity to contribute more and grow their career - Total training hours 20,694. Total training days 862. During 2021, the annual promotion process positively impacted 224 colleagues - gender split, 54% female/46% male. As a future focused business, we continue to embrace flexible and agile ways of hybrid working to sustain a high performing, inclusive workplace. Responding to colleague feedback and in keeping with our purpose and the principles of DWF Life, we are making significant improvements to our family friendly policies. From May 1, 2022, our UK colleagues will benefit from an increase in Maternity Pay and Adoption Leave to 100% full salary for 26 weeks. Paternity Leave will increase from 2 to 4 weeks at full pay and Shared Parental Leave from full salary for the first two weeks to 8 weeks of full salary.

  • 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

    2022

    Water

    2022

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    2022

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

    2022

    Energy & Resource Use

    2021
    Optional comment
    Our Environmental Management System ("EMS") is based on the International Standard EN ISO 14001:2015 requirement. By working to this standard, it ensures that we manage our environmental impacts efficiently and thoroughly comply with relevant environmental legislation and regulations, and minimise our environmental impacts wherever possible. The EMS demonstrates a strong leadership and commitment to managing our environmental impacts and a commitment to continual improvement. Whilst certification is for our offices within the UK (excluding Belfast), we expect all our colleagues to follow our environmental policies and procedures. DWF, in common with the rest of the legal sector, has significant direct impacts on the environment resulting from operational activities. These include: • air pollution; • waste management/recycling; • energy management, construction and buildings; • water; • nuisance; • hazardous materials. Whilst the environmental impacts of our operational activities are much less than that of other business sectors, e.g. manufacturing, mining, transport, electricity, water, construction; they are nonetheless significant. Whilst we do not manufacture a product we do consider the lifecycle perspective of our aspects. An example of this would be, procurement and products purchased, in that the paper purchased is FSC paper and stationery and packaging is reused as much as possible in consideration of the waste hierarchy (cradle to grave).

    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
    We are working with our supply chain to develop ways to reduce environmental impacts. Reviewing the environmental credentials of suppliers as part of the on-boarding process and then throughout the tem of the contract, undertake audits and review the provisions in place ensuring their appropriateness throughout the term of the contract. Examples include minimising delivery packaging and optimising recovery, and ensuring where possible that products purchased with a recognised certification (e.g. MSC and FSC certified).

    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
    We promote environmental awareness and responsibility across the Group through information, initiatives and community projects.We ensure our people have the knowledge and tools to enable good environmental practices both within the workplace and at home which in turn will reduce CO2 emissions. We have recently trialled an employee engagement tool which "harnesses the energy employees already have to fight climate change and channels it towards their organisation’s climate targets". The outcome of the trial was a positive one with significant CO2 savings and habits formed. The direct and indirect benefits are currently being assessed with a view to rolling this out across our business globally during FY 22/23. In the interim we are encouraging our people to utilise the App from a personal perspective. Carbon Literacy is relevant climate change learning that catalyses action to reduce greenhouse gas emissions. During 2021, our training course was created and approved by the Carbon Literacy Project. Shortly after we began to roll out the training and we now have over 20 people certified as Carbon Literate. We are committed to undertake further training throughout FY22/23 with the aim to have at least a further 50 people certified as Carbon Literate and for the Business to achieve Bronze status and be recognised as a Carbon Literate Organisation.

    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

    Like most other businesses, COVID-19 resulted in our people working from home for the majority of 2020/21. Whilst we had a couple of small phased returns, further lockdowns meant homeworking was necessary for the majority of time except for those people whose role dictated that they needed to be in the office. However, during this period and for the foreseeable, Covid-19 impacted and will continue to impact our energy usage as there is a requirement for HVAC systems needing to provide 100% fresh air even with few people in the office, to negate the risk of transmission of the virus.

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

    Energy & Resource Use

    Optional comment
    One of the most significant environmental impacts is reliance on energy to run the buildings. We have committed to work with Building Management to encourage the procurement of Renewable Green Energy across those sites that do not currently have this and to look at whether water conservation methods can be introduced; including any future property expansion whether that be an office move or office space acquired during M&A activity to assist with our Scope 1 and 2 Targets. Future office space will take into consideration the EPC Rating as well as BREEAM properties. At present, there is a small amount of gas (Scope 1) used across 44% of our estate. The target is to reduce this usage, if not to eliminate where possible, by at least 50% by 2030. In terms of electricity (Scope 2), 61% of our estate is currently utilising renewable energy. Our aim is to reduce this consumption by 50% by 2030.

    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

    Air Pollution

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

    Energy & Resource Use

    Optional comment
    As a responsible business we have determined its risks and opportunities arising from our environmental aspects, compliance obligations and other issues and requirements. By determining such risks, ensures the management system can achieve its intended outcomes, prevent or reduce undesired effects, including the potential for external environmental conditions to affect the business and achieve continual improvement. Also considered within the scope of the EMS, the business determines potential emergency situations, including those that can have an environmental impact. These risk and opportunities are reviewed at least annually. We will report on the governance, strategy, risk management, metrics and targets in respect of climate-related risks in the TCFD section of our Annual Report Accounts later this year. The Board, supported by the ESG Leadership Group, have committed to continually integrate new, and refresh existing processes into the Group’s overall risk management framework to identify, assess, and manage climate-related risks and opportunities over the short, medium, and long term. Consideration will continue to be given to the impact of climate-related risks and opportunities on the Group’s businesses, strategy and financial planning; and the resilience of the Group’s strategy in different climate related scenarios. We have recently considered the risks and opportunities of both 1.5C and 4C scenarios which in turn allows us to improve our performance and provided enhanced reporting supporting the transmission to a more sustainable, low-carbon economy.

    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

    Our focus is primarily on reducing our energy usage/CO2 emissions and have committed to reduce in line with the 1.5C pathway. We sent our commitment to the 1.5C pathway with the Science-Based Targets Initiative in May 2021and, in December 2021, committed to a 50% reduction across our Scopes 1, 2 and 3 by 2030.

    Energy & Resource Use

    At present, there is a small amount of gas (Scope 1) used across 44% of our estate. The target is to reduce this usage, if not to eliminate where possible, by at least 50% by 2030. In terms of electricity (Scope 2), 61% of our estate is currently utilising renewable energy. Our aim is to reduce this consumption by 50% by 2030.

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

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

    • Re-use and Recycle – follow the waste hierarchy at all times. • Recycle, on average, 90% of the waste produced. • Reducing reliance on single-use disposables.

    Oceans

    Optional comment
    In addition to our Science Based targets, we will consider at least one large project or several smaller projects, which provide an option for additional emission reductions/emission removals from the atmosphere beyond our science-based targets, which further enhances our commitment to a net zero-carbon economy by 2030.

    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
    Through our Environmental Management System and Road Map to Net Zero by 2030. Data is tracked and reported quarterly to our Executive Board and Bi-annually to our PLC Board. We are participating in

    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

    Climate Action

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

    Scope 1 Emissions

    Emissions (tCO2e)

    298.337

    Scope 2 Emissions

    Emissions (tCO2e)

    552.735

    Scope 3 Emissions

    Emissions (tCO2e)

    787.246
    Optional comment
    Data publicly available within Annual Report & Accounts

    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 (%)

    Optional comment
    We are committed to our role in supporting the global transition to a sustainable low-carbon economy and our ambition is to achieve Net Zero GHG emissions ahead of the UK Government’s target of 2050, to achieve the goals of the Paris Agreement. This in turn enables us to mitigate the climate-related risks noted above through contributing to global action to lessen the impact of climate change on society. Our key metrics are therefore the Group’s GHG emissions and in setting targets we have committed to the 1.5C pathway with the Science-Based Targets Initiative (SBTi).

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

    Optional comment
    DWF is responding to an urgent call-to-action for companies to set emissions reduction targets in line with a 1.5°C future, backed by a global network of UN agencies, business and industry leaders. In May 2021, we signed the Business Ambition for 1.5°C commitment, a campaign led by the Science Based Targets initiative (SBTi) in partnership with the UN Global Compact, the Carbon Disclosure Project (CDP), World Resources Institute (WRI), the World Wide Fund for Nature (WWF) and the We Mean Business Coalition, demonstrating the highest level of ambition on climate and paving the way to a Net Zero future. In December 2021 we submitted our carbon reduction targets for validation by the SBTi. DWF Group PLC commits to reduce absolute scope 1 and 2 GHG emissions 50% by 2030 from a 2019 base year. DWF Group PLC also commits to reduce absolute scope 3 GHG emissions 50% within the same timeframe. The SBTi’s Target Validation Team has classified our scope1 and 2 target ambition and has determined that it is in line with a 1.5°C trajectory. The pandemic brought about the opportunity to transform the way we work which has had a positive impact on our emissions. We have been able to reduce some of our floor space due to having a transient workforce and have brought in a more stringent travel policy. Our key focus is ensure our portfolio of commercial property is using renewable energy with the aim that all UK offices will use 100% green energy by 2030 at the latest. At present, there is a small amount of gas Scope 1) used across 44% of our entire estate. The target is to reduce this usage, if not to eliminate where possible, by at least 50% by 2030. In terms of electricity (Scope 2), 61% of our estate is currently utilising renewable energy (over 80% UK only). Our aim is to reduce this consumption by 50% by 2030. Internationally, we will ensure our estate is also transitioning to renewable energy insofar as possible. Our energy reduction plan will also ensure that we continually assess how we can reduce energy consumption through heating and cooling set points, LED/PIR lighting and automatic computer power downs for example. Proactive management of both business travel and commuting will bring about travel reductions which in turn will reduce our emissions and well as being financially beneficial. We further embedded our digitalisation programme, which in turn will reduce the requirement for stationary items i.e. paper, envelopes etc. We are working with our supply chain to develop ways to reduce environmental impacts. Reviewing the environmental credentials of suppliers as part of the on-boarding process and then throughout the term of the contract, undertake audits and review the provisions in place ensuring their appropriateness throughout the term of the contract. Colleagues invested 207 hours in environmental/sustainability related volunteering projects during the reporting period. Environment/Sustainability made up 6% of the total grants awarded to charities by the DWF Foundation during the reporting period £19, 063).

    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

    61
    Optional comment
    At present, there is a small amount of gas (Scope 1) used across 44% of our estate. The target is to reduce this usage, if not to eliminate where possible, by at least 50% by 2030. In terms of electricity (Scope 2), 61% of our estate is currently utilising renewable energy. Our aim is to reduce this consumption by 50% by 2030.

    Technology

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

    Percent of total revenue (%)

    Sector-specific Questions

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

    Optional comment
    To support achievement of the DWF Purpose, our ESG Client Policy applies a risk-based approach and an ESG lens to where, what and with whom DWF does business. Therefore, all new clients are assessed against our ESG matrix and escalation process. The above ESG risk matrix can also be used to assess risks for existing clients to anticipate emerging concerns or as part of the client annual review process. Our Executive Board has identified the following sensitive sectors where RAG ratings are applied.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    5136

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Optional comment
    Water usage within buildings is for general purpose. Our SDG ambition is a net water impact and we

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    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.

    In 2020/21 DWF participated in SDG Ambition, the UN's global accelerator initiative that aims to challenge and support Global Compact companies to set ambitious corporate targets into its core business management. This programme ran from October 2020 to July 2021 and a key outcome was aligning our decarbonisation goals with science-based targets and embedding a set of material sustainability goals delivered by 2030 to accelerate our contribution to the SDGs. Our key focus is on actual reductions in our emissions by cutting energy use, transitioning to renewables, significantly reducing the frequency and carbon intensity of commuting and business travel and once we have reduced our carbon emissions to lowest level possible, investing in solutions that remove carbon from the atmosphere. We have continued to Re-use and Recycle – following the waste hierarchy at all times. We recycle, on average, 90% of the waste produced and have reduced reliance on single-use disposables. We have submitted carbon reduction targets to SBti and are awaiting validation (June 2022). While we are ahead of target in terms of Scope 1, 2& 3 (primarily due to the impact of the pandemic), the lack of availability of renewables is impacting Scope 1 across some of our sites. The impact of Covid-19 has meant that the business has adapted successfully to a hybrid working model such that any short-term disruption resulting from climate change to our offices, can be mitigated by the ability of our colleagues to work from home. As a people led business, whilst we are not as reliant on our supply chain as other sectors, it still contributes significantly to the Group’s carbon emissions. Increasing emphasis on supply chain resilience will continue to be built into our sourcing strategy, working with key suppliers to ascertain their approach. From an engagement perspective, we recently trialled the Pawprint App across our offices in Scotland. This App is an employee engagement tool which helps people measure, understand and reduce their carbon footprint. It empowers employees to fight climate change at work, home and beyond. The benefits of using an App like Pawprint are that it allows us to: • Engage our colleagues to drive sustainability initiatives. • See our impact; Transform ESG from a box-ticking exercise into measurable impact. • Futureproof; Protect the future of our business, and our planet. • Results were positive with significant carbon savings; many habits formed which means people will continue to take action to reduce their climate impacts; and lots of engagement and the sharing of ideas! The Business are currently considering the results of the trial and then a decision will be made as to whether the Pawprint App is rolled out further across the business.

  • Anti-corruption

    Commitment

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

    2022
    Optional comment
    DWF Group PLC (DWF), being a listed entity, is fully committed to maintaining the highest level of integrity in all dealings and to conduct business in an ethical and honest manner. Our Anti-Bribery and Corruption Policy (Policy) applies to all persons associated with DWF, including its partners and employees. DWF takes a zero tolerance approach to bribery and corruption. This Policy aims to protect the integrity, independence and objectivity of DWF, and to clarify the position of partners and employees in giving or receiving such gifts, invitations or hospitality, and thereby to ensure compliance with all applicable laws and regulations. This Policy acts as an important reference document to be used by all DWF and associated persons in dealings with clients, contacts, associated persons and third parties. The Policy reflects the key outcomes of a risk assessment conducted into our business practices, and focuses on specific forms of potentially unlawful bribes, corruption and other unethical activity, such as gifts, invitations and hospitality. The message from the DWF Board, our Chairman & CEO is clear - DWF Group PLC’s (DWF) position on the issues of bribery and corruption is clear. The offer, payment, authorising, soliciting and acceptance of bribes are practices unacceptable to DWF. We are committed to honest, ethical behaviour wherever we do business. Ethical standards must be a part of our everyday business. Alongside our communicated Code of Conduct, we have carried out a thorough review of all our policies to ensure that they follow industry best practice, can be applied across the globe and satisfy legal and regulatory requirements. An ABC Training Module and competency assessment forms part of our required learning.

    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
    It is important that we act in a way that is transparent. We have a responsibility to ensure that an audit trail exists for all offers of gifts, invitations and corporate hospitality. Disclosable gifts must also be entered into the register of Disclosable gifts (held by the Group Risk Director). Individual discretion is applied, even when a gift appears not to be disclosable, and guidance should be sought from the Group Risk Director. Any offer of an unlawful bribe or corrupt act must be refused and reported immediately to the Group Risk Director. DWF will report an unlawful bribe or corrupt act to the police and/or regulatory authorities.DWF will support anyone who refuses to offer, pay or accept a bribe or who raises genuine concerns in good faith under our Policy or under our Speak Up Policy.

    Prevention

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

    Optional comment
    Enhancements to our learning platform include individual and Team Dashboards to monitor and review all required and mandatory learning including confirmation that colleagues have read and understood our global Code of Conduct. In 2021, DWF acquired Zing365, a specialist provider of compliance training to the Insurance and Financial Services sectors, delivering training through in-person and virtual live training, as well as digital, platform based e-learning. Compliance training offered to clients includes The Bribery Act.

    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

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

    Internal Audit
    Optional comment
    The My Learning Dashboard on the DWF Training Academy enables colleagues to: - View what mandatory Certifications and Programs of training they have completed or need to complete - View a detailed record of learning. The My Team Dashboard enables line managers to review and track completion of learning for their team of direct and indirect reports. Self-disclosure of completion of mandatory training is also now required at half- and full-year performance check-ins, to ensure that they are understood and embedded.

    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
    Our Speak Up Policy, dedicated web service, telephone hotline and email address allows colleagues to raise a concern about a genuine suspicion of malpractice or wrongdoing within the DWF Group. On at least an annual basis Internal Audit submit a report to the Audit Committee of DWF Group PLC. The report includes details of the: - Annual policy review - Number and types of concerns - Outcomes of investigations maintaining employee confidentiality -Feedback from individuals who have used the arrangements maintaining employee confidentiality - Complaints of victimisation or any failure to maintain confidentiality - Staff awareness/trust/confidence in arrangements This Policy also provides for the reporting of more serious cases to the Audit Committee of DWF Group PLC immediately on receipt of such report

    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?

    Through Regulatory Bodies & as a UNGC member operationalising & reporting against the ten business principles. The Group maintains an active dialogue, and strong relationships, across all its key regulators. This ensures awareness of changing legal and regulatory landscapes, allowing a proactive approach in ensuring compliance. The Group’s Risk & Sanctions Committee ensures we comply with changing sanctions globally.

    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.

    - Review & Communication of Expenses Policy - Enhancements to our Learning Platform which has increased visibility of all required/mandatory training completed - December 2021 launched internally & externally, our new ESG Strategy to 2030 including internal awareness sessions on why it matters. The ESG strategy was rolled out to employees and partners via Virtual Town Halls and announcements on the Group's Intranet. Acting with Integrity in everything we do & Building trust and increasing transparency are two of our six ESG pillars. - Imminent communication of our refreshed global Code of Conduct.