Section A - Introduction

1. Approval Level

This policy is owned by Aura Group and any amendments made will be approved by the Aura Group Audit, Risk and Compliance Committee or the Board. 

2. Scope

This policy is intended for use by employees of Aura Group. The policy sets forth the commitment by Aura Group to consider and incorporate ESG across our organisation. The purpose of this policy is to: 

•    Set out the guidelines for Aura Group’s employees to conduct business in line with our ESG goals, and

•    Provide an overview to all employees on how Aura Group approaches and manages ESG-related issues regarding our day-to-day work practices and our investment process

3. Environmental, Social and Governance Overview

4. Objective

At Aura Group, we recognise the world is facing increasingly related and complex ESG challenges. Failure to act on these issues can have a damaging impact on our organisation, stakeholder trust, and the societies we live in. We are working to better manage ESG risks at Aura Group, with our stakeholders, and to positively influence others to adopt best practices.  Our commitment is about ensuring that we consider the social, community and environmental consequences of our activities. Aura Group seeks to protect the environment, and the wellbeing of our staff, stakeholders, and members of the public we engage with during the conduct of our business. It is a requirement of all Aura Group offices and employees to embrace this ESG Policy and bring it to life across the organisation. 

Section B – Meeting Our Commitment 

5. Aura Group’s Employees

Aura Group is an investment group built on a philosophy of value creation, vision and innovation. We believe that proactively integrating ESG factors into both our investing and day to day operations will contribute to achieve superior long-term financial returns.  

5.1 ESG Environment

Aura Group is committed to good environmental practice as part of our overall approach to corporate and social responsibility. We recognise that we have a responsibility to minimise our impacts on the environment as much as possible. Whilst we are a private company, we do not seek to make a profit at the cost of environmental quality.   Aura Group staff members are made aware of Aura Group’s environmental position as part of the induction process, and regular updates are provided via internal staff communications. All employees are encouraged to identify opportunities to minimise negative environmental impacts, including when dealing with sub-contractors, suppliers and other stakeholders where relevant. 

5.1.1 Environmental Opportunities

Environmental opportunities for improvements within our direct business operations currently include: 

• Reducing the use of water and power in our offices, including lighting, computers, etc; 
• Minimising the production of waste products, including wastepaper and toner cartridges;
• Reducing Aura Group staff travel to face-to-face meetings and consultations with stakeholders (eg auditors, agencies) and switching to video conferencing where possible;
• Supporting staff to minimise private car use for commuting (temporarily on hold due to Covid-19); and,
• Compliance with environmental regulations.

5.1.2 Environmental Action

Specific ways in which we support environmental action include:

• Energy efficiency e.g. keeping electrical equipment and lights switched off when not in use, ensuring our premises are well insulated and employing other energy saving initiatives;
• Maintaining staff awareness and where necessary, implementing training in relation to energy efficiency;
• Recycling of waste wherever possible e.g., toner cartridges, paper and office consumables;
• Liaison with the waste collection and disposal authorities to ensure we are maximising recycling opportunities;
• Undertaking internal meetings and client meetings via video conference or telephone where appropriate to reduce the need for travel;
• The use of local suppliers for office products where possible, minimising the environmental impacts of transporting goods.

We shall continue to work in partnership with our stakeholders towards the promotion of environmental protection and improvement, and the minimisation of environmental damage.  

5.1.3 Monitoring Environmental Performance

We have set targets where possible to minimise our impacts on the environment. Examples include:

• Sourcing office supplies from local suppliers; 
• Setting minimum standards for office supplies, for example, switching from single-use to highly recyclable products;
• Monitoring the proportion of internal meetings and external consultations undertaken by telephone or video conferencing to minimise the need to travel; and,
• Promoting walking, cycling or use of public transport for travelling to work as viable alternatives to car use (temporarily on hold due to Covid-19).

5.2 ESG Social

Aura Group seeks to create measurable social impact by investing in the health and wellbeing of our employees. Aura Group understands the importance of giving back by investing in the community, through programs managed by Opportunity International and B1G1. 

5.2.1 Human Resources

We educate all employees to live the Aura Group corporate values by:

• Creating conducive workplace conditions that help all employees be aware of protecting the environment by promoting application of this policy, both in the workplace as well as at home;
• Ensuring Aura Group’s Code of Conduct and sustainability is covered as part of relevant training and meetings to raise awareness and commitment of our employees, investee companies, stakeholders and the wider community;
• A strong culture of continuous improvement ensures all employees have the opportunity to improve, and positively impact Aura Group’s financial performance;
• Encouraging discussion and recognition of behaviours that support and represent our values via ongoing management feedback.

Our commitment to valuing equality and diversity provides the opportunity for employment, career and personal development on the basis of ability, qualifications and suitability for the work, as well as the potential to be developed for a particular role. This is supported by Aura Group’s Equal Opportunity and Diversity Policy. 

5.2.2 Employee Commitment

We are investing in the health and wellbeing of our employees and will continue to build a diverse and inclusive workplace within the constraints of the size and scale of our organisation. In addition to competitive remuneration packages and rewarding career opportunities, we provide a range of benefits to support employees and their families. These benefits aim to enhance financial security, work/life balance and the health and well-being of our employees. Some examples are included below: 

• Company contributions and encouragement of personal financial planning where possible in each jurisdiction via pension, retirement, superannuation and other related funds;
• A comprehensive leave program including Maternity, Paternity, Adoption and Compassionate leave, including at or above statutory entitlements for annual holiday leave to encourage a healthy work-life balance and recognise family and other personal commitments outside of work; 
• The potential for flexible working arrangements including part time hours and work from home options to support staff fitness, health and childcare commitments;
• Access to study assistance (leave and financial) for relevant courses of study to support the ongoing learning and development of all employees. Assistance is on a discretionary basis and must be requested and approved through an Aura Group Director before study commitments are undertaken; and,
• Access to an employee health program through CU Health. This program is available to all employees of Aura Group and provides access to GP services, mental health services, specialist consultation services and general well being services.

5.3 ESG Governance 

Aura Group’s governance structure promotes accountability, fairness and transparency across the organisation.  Aura Group’s material ESG risks are reviewed annually for relevance and prioritisation. To ensure these material ESG risks are managed effectively, Aura Group seeks to perform the following: 

• Identify risks that may impact the execution of our strategy, considering input from all relevant stakeholders;
• Prioritise risks that most significantly impact our ability to successfully deliver long-term value, and influence the decisions of key stakeholders on mitigating these risks; and,
• Integrate the mitigation strategies of material risks across all areas of the organisation. This integration can take place by factoring these strategies into our approach for setting objectives, driving behaviours, measuring performance, and determining the remuneration of employees.

5.3.1 Corporate Communication

The topic of ESG is becoming an increasingly important part of Aura Group’s corporate communication strategy. A strategic priority for Aura Group is to engage our stakeholders and develop key partnerships. We will also seek to nurture any constructive relationships with organisations that may highlight any ESG shortcomings of Aura Group. 

5.3.2 Regulation

To promote an effective regulatory system with respect to ESG, we:

• Support internationally recognised standards and voluntary initiatives;
• Encourage our investee companies to adhere to relevant laws, regulatory and compliance requirements; and
• Oppose discriminatory measures

5.3.3 Code of Conduct

We are committed to providing a robust Code of Conduct for Aura Group, which covers a number of items including: 

• Conflicts of Interest
• Gifts, Entertainment & Hospitality
• Market Abuse
• Tax
• Anti-bribery & Corruption
• Financial Promotions
• Complaints
• Whistleblowing