Pivotal Retail Marketing Ltd - Corporate Social Responsibility Policy (CSR). 1.0 Context 1.1. Pivotal Retail Marketing recognises the importance of its role in managing social, economic and environmental issues. Corporate Social Responsibility (CSR) is the principal way Pivotal Retail Marketing seeks to co-ordinate and manage practices to maximise positive social and economic contribution and minimise the environmental impacts of its business. Engagement with key clients, employees, community, environmental stakeholders, regulators, business partners, suppliers, is central to Pivotal Retail Marketing’s approach to CSR. 1.2. Pivotal Retail Marketing divides CSR into four segments: Marketplace: How we work with our customers and suppliers Workplace: Where we work, how we recruit and how we work with our staff Environment: How we reduce our environmental impact Community: How we engage with the community 1.2. The policy is related to and builds upon the values and standards of ethical behaviour outlined in Pivotal Retail Marketing’s Code of Business Conduct. 2.0 Objectives The objectives of this Policy Statement are to: 2.1. Clarify roles and responsibilities in respect of CSR 2.2. Outline the commitment and requirements for the CSR segments of: Marketplace, workplace, environment and community 3.0 Scope 3.1. This Policy applies to all departments in Pivotal Retail Marketing. 4.0 Policy Requirements 4.1. Roles & responsibilities 4.1.1. Ownership of CSR: The Managing Director is accountable for CSR in the UK. The co-ordination of CSR initiatives and activities will be owned on the Managing Director’s behalf by the nominated Group member who will report regularly on CSR status, progress and issues to the Managing Director. 4.1.2. Department Management: Responsible for ensuring that key strategic and operational decisions in their area take into account CSR considerations, supporting CSR initiatives and practices through role modelling and the allocation of sufficient resources, raising the profile of CSR and overseeing that their area complies with this policy. 4.1.3. Staff: Responsible for behaving in a corporately responsible way, adhering to this policy and enabling Business Environment to make a positive social, economic and environmental contribution. 4.2. Marketplace 4.2.1. Pivotal Retail Marketing will operate in accordance with the values and standards of behaviour set out in its Code of Business Conduct and all applicable laws and regulatory requirements and provide a mechanism and process whereby illegal and/or unethical behaviour can be reported and addressed. 4.2.2. Pivotal Retail Marketing will provide products and services to meet the needs of its clients, while having consideration for the impact on the natural environment and communities where we operate. 4.2.3. Pivotal Retail Marketing will provide high standards of service to clients and have complaints procedures for clients to ensure their concerns are efficiently addressed on those occasions where there is a problem. 4.2.4. Pivotal Retail Marketing will take a partnership approach to supply chain relations, as outlined in our Supplier Code of Conduct, ensuring that payments are made promptly, supplier complaints are reviewed, and that we use fair and transparent procurement methods. 4.2.5. Pivotal Retail Marketing will use its position in the marketplace to raise awareness of CSR with clients and the market and help facilitate change to minimise impact on the natural environment and communities where we operate. 4.3. Workplace 4.3.1. Pivotal Retail Marketing will provide a workplace in which diversity is valued and there are equal opportunities. Pivotal Retail Marketing will provide a mechanism/s by which employees can raise their views and be engaged in change and issues that affect the company. 4.3.2. Pivotal Retail Marketing will provide a safe and secure workplace which is conducive to the health and welfare of employees. 4.3.3. Pivotal Retail Marketing will support employees with learning and development opportunities to help them reach their potential and maximise their contribution to Pivotal Retail Marketing’s strategy. 4.3.4. Pivotal Retail Marketing will recognise and reward individuals on the basis of their own performance and that of the company. Business Environment will appraise performance on both the results that were achieved and how they were achieved. 4.4. Environment 4.4.1. Pivotal Retail Marketing will seek to minimise its energy, water and paper usage, through design, infrastructure and behaviour. 4.4.2. Pivotal Retail Marketing will seek to optimise the recycling of 75%of all waste through providing adequate facilities and behaviour, and limit the use of hazardous material. 4.4.3. Pivotal Retail Marketing will seek to reduce unnecessary travel and encourage the use of alternative means of communication where practicable. 4.4.4. Pivotal Retail Marketing will incorporate environmental considerations into procurement decisions and raise awareness/influence our supply chain to facilitate a reduction in their environment impact. 4.5. Community 4.5.1. Pivotal Retail Marketing will provide benefit to the community though the creation of jobs and the accompanying wealth produced, and through the investment of our money and time in the community. 4.5.2. Pivotal Retail Marketing will provide and support UK-wide employee volunteering opportunities and support corporate fundraising campaigns. 4.5.3. Pivotal Retail Marketing will encourage and support employees in their own community activities and fundraising efforts, through the provision of time and/or financial contribution. 5.0 Definitions The following summarises key terms used in this Policy Statement Code of Business Conduct – Sets out the standards of ethical behaviour required of all employees and officers, as well as all Pivotal Retail Marketing directors and agents whenever they are acting on behalf of the company. Corporate Social Responsibility (CSR) – The overall approach Business Environment takes to contribute to economic development while improving the quality of life of the workforce and their families as well as of the local community and society at large.