Sustainability policy: the operating concept, not an annex.

We commit to operating on principles of good corporate governance aimed at corporate sustainability, creating shared economic, social and environmental value across our business value chain. Business decisions weigh economic, safety, occupational health, environmental and social aspects together; sustainability is the operating concept, not an annex.

We adhere to merit, transparency and compliance with law, regulatory requirements and internationally accepted standards, under our Business ethics policy. We pursue continual improvement across all activities with defined goals, evaluation and monitoring, invest in innovation and technology for long-term value, and promote sustainable development practices across our partners, suppliers and stakeholders.

We embed a culture of safety, environmental protection and social responsibility, with a zero-accident goal and safety measures beyond regulatory minimums; activities without adequate controls, protective equipment and training are prohibited. We treat all employees and workers fairly and equally, without discrimination; we prohibit the employment of persons under 18 and illegal labour, for ourselves and across our suppliers and stakeholders; and we respect the rights, dignity, confidentiality and safety of everyone who works with us. The Health, safety and environment policy sets out our health and safety commitments in full.

As a consultancy, our footprint comes mainly from travel, offices, electricity, devices and paper. We manage it with the same environmental management discipline we implement for clients under ISO 14001:

• Remote delivery where a site visit adds nothing: working sessions, document reviews and much of our training are delivered online, and travel is planned so that one visit covers as much of the work as possible.
• Paperless engagements: management system documents and records are built and kept digitally, in the client's Effivity workspace that comes with every Sterling engagement, rather than printed.
• Offices: energy and resources used responsibly, waste reduced and recycled, and equipment kept in use for its full life.
• Suppliers: preference for suppliers that manage their own environmental and social impacts.

We invest in people, through skills, knowledge and safe workplaces that support creative work, and we operate with care for the communities and environments our work touches. Our largest contribution is through clients: the environmental, energy, occupational health and safety and ESG systems we help organisations build and run, and the sustainability reporting we support. We apply the same discipline to ourselves that we recommend to them.

Sustainability objectives are set by Sterling's management alongside the firm's other business objectives, covering travel, energy and paper in our own operations and the conduct of our supply chain. Progress against them, and this policy, are reviewed regularly in the same management review that covers quality, health and safety and information security, and the objectives are updated as the business and its footprint change. Where we fall short of an objective, the cause is found and corrected in the same way as any other nonconformity in our own work.