1. Purpose
This Conflict of Interest Policy ensures that ESG Strategy Pty Ltd maintains the highest standards of integrity and objectivity in all client engagements and business relationships. We are committed to identifying, disclosing, and managing any actual or potential conflicts of interest.
2. What is a Conflict of Interest?
A conflict of interest occurs when personal, financial, or other interests could compromise, or appear to compromise, professional judgment or objectivity. This includes:
- Financial interests: Ownership, investments, or financial relationships with clients, competitors, or suppliers.
- Personal relationships: Family or close personal relationships that could influence business decisions.
- Competing interests: Simultaneous engagements with competing organisations in the same market.
- Outside activities: External roles or activities that could conflict with duties to ESG Strategy or its clients.
3. Disclosure Requirements
All team members and contractors must:
- Disclose any actual or potential conflicts of interest promptly
- Complete an annual declaration of interests
- Update disclosures when circumstances change
- Raise concerns about potential conflicts involving colleagues
4. Management of Conflicts
When a conflict of interest is identified, we may take one or more of the following actions:
- Remove the conflicted individual from the relevant engagement or decision
- Establish information barriers between conflicted parties
- Obtain informed consent from affected clients
- Decline the engagement if the conflict cannot be adequately managed
- Document the conflict and management measures taken
5. Client Engagements
Before accepting any client engagement, we assess potential conflicts with existing clients and our own interests. Where conflicts exist, we will disclose them to affected parties and implement appropriate safeguards, or decline the engagement.
In line with our ethical responsibilities, we will not work with companies involved in serious ESG breaches unless there is clear, verifiable evidence of genuine, sustained efforts to address and remediate those issues. We also will not take part in engagements that involve knowing greenwashing or misleading ESG communications.
6. Gifts and Hospitality
Team members may not accept gifts or hospitality that could create an obligation or appear to influence professional judgment. Modest gifts of nominal value and standard business hospitality are acceptable when they do not create a conflict.
7. Reporting Concerns
Any concerns about conflicts of interest should be reported to leadership immediately. We encourage open discussion and will not retaliate against individuals who raise concerns in good faith.
8. Contact
For questions about this policy, please contact us at [email protected]