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

How we operate as a business

Every aspect of our business has environmental and social consequences.

This policy shapes our actions as an employer and a member of the communities in which we work.

A summary of how our ESG policy helps to deliver Difference Made is provided below.

This is our commitment to making that difference

1. Carbon neutral by 2025

This means that by 2025 greenhouse gas emissions caused by the Group’s activities will have zero net impact on the climate.

It includes direct emissions caused by, for example, fuel used in vehicles and boilers, and indirect emissions, including those from electricity generation and from our suppliers, service providers and companies distributing Marlborough’s products and services.

We will achieve net zero by reducing these emissions to the lowest possible level and then responsibly offsetting the remainder.

The transition to net zero will involve us engaging with companies in our supply chain to communicate our ambition and then working with them to ensure they are moving to sustainable practices.

2. Waste Reduction

We have reduced waste by using paperless finance, human resources and document management systems.

We recycle confidential waste, batteries and IT equipment and have recycling bins for paper, cans and plastics. We have distributed mugs and water bottles to replace single-use cups, as part of our efforts to reduce waste plastic.

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.

4. Community & Charity

As a Group we are committed to playing a responsible role in society and giving back to our communities.

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 Aid Foundation’s payroll giving scheme.

In addition, the Marlborough Group is a supporter of a number of charities.

We are patrons of Bolton Lads & Girls Club, which supports 3,000 children, providing a safe place to spend their free time, giving them access to training, pastoral support, bereavement support and assisting the wider community with a food bank.  

We have partnered with Bolton Hospice, which has over the years cared for the loved ones of a number of staff members. We have supported numerous fundraising events and been the corporate sponsor of the hospice’s £50 challenge.

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.

5. Developing Talent

The Marlborough Group nurtures talent in our local communities and through hybrid and remote working. We help individuals develop and support them as they build their careers.

We have a successful track record of recruiting through strong relationships with local colleges and universities. We regularly attend job fairs in the communities in which we are based.

We also have an excellent track record in recruiting apprentices and helping them develop their skills. With our apprenticeship partner, we have supported our apprentices to achieve level 3 Investment Operations Technician and Investment Operations certificate qualifications.

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 on each of our regulated boards across the business.

An extra layer of governance and oversight is provided by Audit, Risk and Compliance committees for the UK-regulated boards. These committees are comprised entirely of iNEDs. We also have an internal audit department.

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.

To read the remuneration policy click here [insert link]

8. Financial Stability

Marlborough and Investment Fund Services are prudent and financially stable businesses, with both companies holding surplus capital at levels well in excess of their regulatory requirements. Significant capital is also retained for business growth. The Finance team is split into Financial Accounting and Financial Planning & Analysis, so one side can review the work of the other.

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. 
The coordinated effort and support of our people, partners and customers is essential in helping us deliver Difference Made. If you have feedback, questions or would like to engage more deeply with us in the delivery of our Environmental, Social and Governance Policy we would welcome your involvement.
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