Environmental Social and Governance (ESG) Policy
The Calculus Capital Limited (“Calculus”) ESG Policy details our firm-wide commitment to integrate ESG risks into our investment processes, and outlines the foundation, ownership, and oversight mechanisms, which underpin our approach.
ESG integration is the practice of incorporating material ESG information into investment decisions with the objective of improving the long-term financial outcomes of our client’s portfolios.
ESG integration is a core part of the investment process, and as with all other components of the investment process, is the responsibility of our investment team. In turn, it is the responsibility of the Calculus Board to ensure oversight and that all factors detailed in the ESG Policy are considered when making investment decisions, as well as in the management of existing portfolio companies. Investment Directors are accountable for ensuring existing portfolio companies adopt strategies which align with a transition to a more sustainable economy.
Calculus recognises that it has a social and environmental responsibility beyond legal and regulatory requirements. We are committed to making a positive environmental and social impact, alongside continually improving performance and governance. Each of these are integral to our business strategy and operating methods.
The ESG Policy will be reviewed at least annually to reflect changes within Calculus, as well as alterations made regarding ESG considerations, more widely.
The first central factor of Calculus’ ESG Policy relates to environmental considerations, which are detailed below.
• Reduce energy consumption, wherever possible to do so;
• Encourage all employees to turn off lights and other electrical equipment when not in use;
• The use of energy efficient lighting and equipment; and
• Source, where commercially viable to do so, energy requirements from renewable/sustainable sources.
• Limit the amount of business travel, such as using technology including video conferencing and online collaboration software; and
• Reduce the environmental impact of necessary business travel, including limiting air travel, maximising use of other public transport and encouraging cycling, walking or car sharing, if these other options are not available.
• Reduce, reuse, and recycle the waste that is generated; and
• Dispose of all remaining waste appropriately.
• Take all reasonable precautions for the prevention of pollution from activities, whether such pollution may be deliberate, gradual, or sudden and accidental in nature; and
• Carry adequate environmental protection insurance, as may be reasonable, to assist with any clean up, and other remedial actions in the event of an incident.
• Monitor and continuously improve environmental performance; and
• Work with suppliers, contractors, sub-contractors, and other relevant parties to improve environmental performance.
The third central factor of Calculus’ ESG Policy relates to governance considerations, which are detailed below.
The Company shall set clear objectives (including any non-monetary objectives) for the short term (less than two years), mid-term (two to five years) and long term (over five years).
The Company is committed to maintaining a diverse and competent Board of Directors including, where possible, the appointment of a chairperson and one or more independent non-executive directors. Structure The Company shall clearly define the roles and responsibilities of each member of the Company’s team/each Board Committee and shall maintain a transparent organisational structure so that all employees are aware of all direct and indirect reporting lines.
• Ensure that the statutory registers of the Company are maintained at all times; and
• Arrange regular quorate meetings of the Board of Directors (and any Committees of the Board) and ensuring adequate Board/Committee papers are prepared and circulated in good time and that appropriate minutes of each meeting are produced and retained.
The Company is committed to avoiding conflicts of interest and taking appropriate measures to manage any potential conflict of interest that may be identified from time to time.
• Keep up to date with the latest regulatory requirements and other governmental policies; and
• Comply with and seek to exceed all relevant regulatory requirements and applicable government policies.
• Maintain complete, accurate and up to date accounting records;
• Produce management information in a routine and timely manner;
• Produce statutory accounts in a timely manner and filing the same with the Registrar of Companies on time;
• Ensure that statutory accounts are prepared by an independent accountant and, where required by law, audited by a reputable firm of accountants/auditors;
• Take reasonable steps to promptly deal with any items raised by such independent accountant and/or auditor; and
• Ensure good fiscal management including in particular with regard to the working capital management policy to ensure the Company is able to pay debts as they fall due.
Committed to paying duties and taxes on time including, as may be applicable, each of the following:
• Pay As You Earn/National Insurance Contributions;
• Value Added Tax;
• Corporation Tax;
• Stamp Duty and Stamp Duty Land Tax; and
• Any other taxes payable by the Company.
The Company is committed to ensuring compliance with regard to data protection, including under the General Data Protection Regulations (GDPR).
The Company shall apply high standards of business ethics, integrity, and honesty to the business and ensure that no corruption, bribery, fraud, or money laundering is permitted to take place in the business. The Company shall also deal with the relevant stakeholders, regulators, tax authorities, and auditors in an open and co-operative manner.
The Company is committed to providing appropriate reporting, without disclosing matters of a confidential or commercially sensitive nature, to various stakeholders in order to measure the Company’s compliance with the objectives set out in this ESG policy.
• Monitor and continuously improve governance; and
• Work with suppliers, contractors, sub-contractors, and other relevant parties to improve governance.
Calculus shall review this ESG policy at least once per year.
John Glencross, CEO
Richard Moore, Co-Head of Investments
Alexander Crawford, Co-Head of Investments