Environmental, Social & Governance (ESG) - Difference Made in action

1. Carbon neutrality through utility associated emissions by 2025

By the end of 2025, The Marlborough Group will achieve carbon neutrality for emissions associated with its utility consumption. This commitment targets greenhouse gas emissions arising from electricity and heating used in our operations.

Our strategy includes:

• Reducing utility-based emissions through energy efficiency improvements and operational optimisation.

• Using REGO-backed electricity with a small proportion of direct renewable supply, ensuring our electricity consumption is matched by certified renewable generation under the UK’s Renewable Energy Guarantees of Origin (REGO) scheme.

This initiative focuses specifically on utility-related emissions and forms a key milestone in our broader sustainability roadmap toward full net zero across all operations by 2050.

2. ISO 14001

We’re excited to announce that Marlborough Group has officially begun its ISO 14001 journey an internationally recognised standard for environmental management systems. This marks a key milestone in our commitment to sustainability, helping us systematically reduce our environmental impact, improve resource efficiency, and embed responsible practices across our operations.

3. Diversity & inclusion

The Marlborough Group is committed to providing equal opportunities for all. To support this, we carry out monitoring to provide information about current and prospective employees.

This includes:

• Collecting information about the group’s culture through employee engagement surveys

• Analysing data about our staff in relation to race, gender, age, health, and religion

• Collecting equal opportunities data during the recruitment process

• Monitoring the gender gap and the strategy to increase the number of women in senior roles

• Inclusiveness training for hiring managers.

• Consideration of job roles and potential reasonable adjustments that can be made to open the roles to a wider pool of talent.

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4. Community & charity

We want our staff to be able to make a difference to the charities and causes they believe in. We help them do this by making it simple to contribute regular donations through the Charities Trust payroll giving scheme.

Each year, our Corporate Social Responsibility (CSR) Committee selects a Group charity, enabling us to focus our collective efforts on making a meaningful difference.

Our charity committee organises multiple events throughout the year—from bake sales and runs to quizzes and dress-down days. These events support a wide variety of charitable organisations, particularly those tackling hunger and homelessness in our communities.

In addition, the Marlborough Group supports a number of charitable organisations.

Through the CSR Forum, colleagues come together to share ideas, collaborate, and explore innovative initiatives that strengthen our corporate social responsibility. These efforts reflect our ongoing commitment to creating a positive social impact and driving change that matters.

5. Developing talent

The Marlborough Group is committed to nurturing talent across our teams, wherever they are based, through hybrid and where appropriate remote working. We empower individuals to take ownership of their learning and development and support them as they build their careers.

We actively encourage our people to pursue professional qualifications and apprenticeships, providing financial support and study leave where appropriate. This enables our teams to grow their expertise, gain industry-recognised credentials, and progress confidently in their careers.

Our apprenticeship programme offers a range of industry-specific learning pathways designed to build practical skills and knowledge aligned with career goals. We continue to expand these opportunities to meet the evolving needs of our business and our people.

We believe that investing in our people’s development not only strengthens our business but also fosters a culture of continuous learning, innovation, and personal growth.

6. Modern slavery

The Marlborough Group is absolutely committed to preventing modern slavery and human trafficking in its corporate activities and to ensuring that our supply chains are free from modern slavery and human trafficking.

To read our modern slavery policy click here

7. Corporate governance

The Marlborough Group has devoted considerable time and resources to arriving at an operating model where Marlborough, our investment management business, and Investment Fund Services, which provides Authorised Corporate Director services, can operate with an appropriate degree of separation, while still dovetailing in a highly effective manner.

The two companies have a clear separation of their main boards, committees, executive committees and independent non-executive directors (iNEDs). We have an iNED Chair on each of our regulated boards across the business.

An extra layer of governance and oversight is provided by the Group Audit, Risk and Compliance committee. This committee is comprised entirely of iNEDs. We also have an internal audit department which reports into the Group Audit, Risk and Compliance Committee.

Marlborough’s Remuneration Policy is designed to ensure that remuneration practices are consistent with and promote sound and effective risk management, do not encourage risk taking that is inconsistent with the risk profile and prospectuses of the company’s funds, do not impair our duty to act in the best interest of the funds and includes measures to avoid conflicts of interest.

8. Financial stability

Marlborough Group is a financially stable business and holds prudent levels of capital and liquidity within all regulated entities, at levels comfortably in excess of their regulatory requirements. Surplus capital is also retained within the group for business growth. Financial stability is effectively managed through regular financial reporting to the relevant boards and committees within the group. including capital and liquidity forecasting, and regular assessment of risk appetite.

9. Business model

One of the great strengths of the Marlborough Group is that across the business, we compete on the quality of the service we provide. This is rather than competing purely on price, which could lead to an unsatisfactory ‘race to the bottom’ based on cost rather than the value achieved for our clients.

10. Corporate behaviour

The Marlborough Group is committed to high standards of corporate behaviour and acting responsibly and ethically on behalf of our clients, staff and other stakeholders.

This is underpinned by:

• A strong business continuity plan.

• Multiple policies embedded within the group, including anti-bribery, anti-money laundering, best execution, whistleblowing, market abuse, fraud and personal account dealing (PAD).

• Ethics training for at least one hour per year for all members of staff.

• Company values incorporated from induction through to appraisals to embed a positive culture.

• A ‘no-blame’ compliance culture, to encourage people to raise any issue.