ESG & CSR Policy

Sunfish Online is committed to integrating Environmental, Social and Governance (ESG) principles with Corporate Social Responsibility (CSR) initiatives across all areas of our operations.

This policy applies to all employees, contractors and stakeholders engaged with the Company.

Sunfish Online is dedicated to sustainable business practices that create long term value for stakeholders while contributing positively to society and the environment.

We align our CSR activities with recognised ESG standards to promote transparency, accountability and measurable impact. Our objective is to operate responsibly, ethically and sustainably in everything we do.

We are committed to minimising our environmental footprint through responsible and sustainable practices, including:

• Energy Efficiency – Using energy efficient technologies and reducing travel through digital collaboration tools.
• Sustainable Procurement – Partnering with suppliers who prioritise responsible e waste management and sustainable sourcing practices.
• Waste Reduction – Promoting paperless processes, recycling electronic devices and disposing of obsolete equipment responsibly.
• Carbon Reduction – Encouraging remote working, virtual meetings and low carbon commuting options.

We aim to foster an inclusive, ethical and supportive working environment by focusing on:

• Diversity, Equity and Inclusion (DEI) – Ensuring equal opportunities regardless of gender, ethnicity, age, disability or background.
• Employee Wellbeing – Maintaining safe, healthy and flexible working conditions.
• Learning and Development – Providing continuous training and knowledge sharing opportunities to support professional growth.
• Community Engagement – Supporting local and global communities through volunteering, mentorship and technology driven initiatives.
• Ethical Client Engagement – Working only with clients and projects that align with responsible and ethical business practices.

We uphold strong governance standards to ensure integrity and accountability throughout the organisation:

• Compliance and Ethics – Adhering to all applicable laws, regulations and industry standards.
• Anti Bribery and Corruption – Maintaining a zero tolerance approach to unethical practices.
• Data Privacy and Security – Protecting client and employee data in line with global privacy laws and cybersecurity best practices.
• Transparency – Ensuring clear and responsible decision making and disclosing ESG performance to relevant stakeholders.
• Whistleblowing – Providing safe and confidential channels for reporting unethical conduct without fear of retaliation.

Our CSR initiatives extend beyond compliance and include:

• Community development programmes
• Educational support initiatives
• Charitable contributions
• Environmental conservation projects

These efforts reinforce our ESG objectives and demonstrate our broader social responsibility.

Directors – Provide oversight of ESG and CSR strategy, performance and accountability.

ESG Committee – Responsible for the implementation and monitoring of ESG and CSR initiatives.

Employees – Expected to actively participate in sustainability and CSR programmes and uphold the standards set out in this policy.

We integrate ESG and CSR objectives into business planning and set measurable targets to assess performance.

Progress is monitored through regular internal reviews, audits and stakeholder feedback to ensure continuous improvement.

We will publish annual sustainability updates outlining ESG metrics and CSR achievements.

This policy will be reviewed annually to ensure it remains relevant, effective and aligned with evolving standards and stakeholder expectations.

Approved by: Gilbert Mackay | Director | 12 November 2025