Purpose
Ensure material environmental, social, ethical and governance risks and opportunities are considered in enterprise risk management and significant decisions, embedding sustainability considerations into investment decisions, product development, and operational strategies.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Define proportionate ESG screening criteria for products, investments, suppliers, partnerships and material changes | Incorporate ESG criteria into investment, product development, and business decisions. | ESG screening and risk assessments |
| 2 | Identify affected stakeholders, potential adverse impacts, opportunities, legal duties and reputational considerations | Engage stakeholders, including customers, regulators, employees, and partners, in ESG discussions and initiatives. | Stakeholder and impact analysis |
| 3 | Identify and assess ESG-related risks regularly (e.g., environmental impacts, reputational risks, regulatory changes) | Assess likelihood, impact, existing controls, residual risk and alignment with risk appetite. | ESG screening and risk assessments |
| 4 | Integrate ESG considerations into the overall enterprise risk management framework | Define mitigation, monitoring, consultation and approval conditions. | Risk register entries, monitoring and reassessments |
| 5 | Ensure compliance with AML/CFT regulations, data protection laws, and other applicable legislation | Establish incident reporting, escalation, and remediation protocols. | Incident reports, escalation and remediation records |
| 6 | Encourage innovation in digital assets and blockchain applications that support sustainable finance and inclusion | Submit material or out-of-appetite matters to the appropriate management or Board authority. | Decision papers, approvals and conditions |
| 7 | Record the assessment, decision, dissent, conditions and evidence | Monitor approved conditions and reassess after incidents, stakeholder concerns or material change. | Decision papers, approvals and conditions |
Proportionality Considerations
- ESG, governance, and ethical measures are prioritized according to their materiality and impact (risk-based application).
- Areas with higher exposure, such as data protection, governance integrity, or social equity, receive more structured oversight than lower-risk operational domains.
- Processes rely on lean documentation, integrated roles, and digital tools, with clear pathways for future scalability.
Records
- ESG screening and risk assessments
- Stakeholder and impact analysis
- Decision papers, approvals and conditions
- Risk register entries, monitoring and reassessments
- Incident reports, escalation and remediation records
Relationships
- Policy: POL-ESG-001 Governance Ethics and ESG Manual
- Process: PRC-GRO-001 Governance Risk and Outsourcing
- Control: CTRL-ESG-006 Ensure ESG Risk Is Integrated Into Material Decisions
History
- 2026-07-26: Created from sections 4.2 and 4.3 of the approved ESG Manual.