ESG Policy

ESG Environmental, Social, Governance

Introduction

ESG stands for Environmental, Social, and Governance. 

It is a framework used to measure an organization’s impact on society and the environment, as well as its corporate governance practices. 

Environmental

This aspect considers how a company performs as a steward of nature. It includes the management of environmental challenges such as climate change, resource depletion, waste, and pollution.

Social

This pillar examines how a company manages relationships with employees, suppliers, customers, and the communities where it operates. It also looks at the company’s social impact and labor practices.

Governance

This part assesses a company’s leadership, executive pay, audits, internal controls, and shareholder rights.

In addition the 

Code Of Ethics for Information Technology:
  • Data security
    IT professionals should prioritize data security and implement appropriate measures to protect sensitive information and systems.
  • Privacy
    IT professionals must respect users’ privacy and comply with relevant data protection laws and regulations.
  • Intellectual property
    IT professionals should respect the intellectual property rights of others, including software licenses, copyrights, and patents.
  • Ethical development
    IT professionals should consider the ethical implications of their work, ensuring that technologies are developed and deployed responsibly and do not harm individuals or society.

ESG criteria are increasingly important for investors who want to ensure their investments align with their ethical beliefs and support sustainable and socially responsible business practices.

It is also a way for companies to be more transparent about the risks and opportunities they face related to sustainability.

ENVIRONMENTAL

Policy Objective

The objective of this policy is to ensure that nfoldROI conducts its business in full compliance with relevant ESG standards and regulations, thereby supporting sustainable development, ethical business practices, and corporate accountability. This policy guides our efforts to achieve positive ESG outcomes and enhance our ESG scorecard performance.

Scope

This policy applies to all employees, contractors, and business partners of nfoldROI, across all levels and locations of our operations in the utilities and telecommunications sectors.

Environmental Stewardship

  • Implement sustainable practices to minimize our environmental footprint.
  • Comply with all environmental laws and regulations relevant to our operations and products.
  • Engage in initiatives that contribute to environmental conservation and promote the use of renewable energy sources.

Social Responsibility

  • Foster a diverse, inclusive, and equitable workplace, ensuring equal opportunities and fair treatment for all employees.
  • Uphold the highest standards of labor rights, prohibiting any form of discrimination, harassment, or forced labor.
  • Commit to community engagement and development, particularly in areas where we operate, through educational, health, and infrastructure initiatives.

Compliance Management and Reporting

  • Designate an ESG Compliance Officer responsible for overseeing the implementation of this policy and reporting on ESG matters.
  • Conduct regular training for employees on ESG principles and compliance requirements.
  • Perform periodic internal audits and risk assessments to ensure adherence to ESG standards and identify areas for improvement.
  • Report transparently on our ESG performance and compliance efforts in our annual sustainability report.

Stakeholder Engagement

Actively engage with stakeholders, including customers, investors, and community representatives, to gather feedback on our ESG practices and performance.

Policy Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in ESG standards, regulatory requirements, and our business operations. We are committed to continuous improvement in our ESG performance.

Emissions

Policy Overview

Our emission reduction and sustainability policy is designed to align with global sustainability goals and environmental best practices. This policy applies to all aspects of our operations, from remote work environments to our physical office in India.

Remote Work and Emission Reduction

Work From Home Model:

To reduce transportation-related emissions, nfoldROI encourages a remote work model for our employees globally. This initiative significantly cuts down on daily commutes, thereby reducing greenhouse gas emissions.

Energy-Efficient Home Offices:

We support our employees in setting up energy-efficient home offices by offering green office equipment, including energy-saving computers, and encouraging LED lighting, activation of power-saving features on computers and monitors when not in use and lowering the screen brightness to reduce energy consumption.

Remote & Cloud Computing:

Leveraging remote and cloud computing, our company actively reduces emissions by partnering with Microsoft Azure. Azure employs cutting-edge, energy-efficient technologies that significantly lower power consumption while boosting processing capabilities.

India Office Operations

Green Office Practices:

Our office in India is equipped with energy-efficient lighting, HVAC systems, and appliances to minimize our carbon footprint. We also implement strict waste management practices, emphasizing recycling and the reduction of single-use plastics.

Digital-First Approach:

To further reduce our paper usage and waste, nfoldROI adopts a digital-first approach across all operations. This includes digital documentation, cloud-based services, and virtual meetings to minimize the need for physical resources.

Continuous Improvement and Community Engagement

Sustainability Training:

All employees receive training on sustainability practices and are encouraged to contribute ideas for further emission reduction.

Monitoring and Reporting

Annual Sustainability Report:

nfoldROI commits to transparency by publishing an annual sustainability report detailing our emission reduction efforts, energy usage, and future sustainability goals.

Water Use

Policy Scope and Objective

This policy outlines our commitment to minimizing water usage, reducing wastage, and promoting water stewardship within our office in India and among our remote workforce. The objective is to foster an organizational culture that prioritizes water conservation both professionally and personally.

Water Conservation Measures in the India Office

Efficient Fixtures:

Lobby the landlord to install water-efficient fixtures, including low-flow faucets, toilets, and urinals, to reduce water consumption in our office facilities.

Guidelines for Remote Workers

  • Water-Saving Tips:
    Distributing water-saving tips and best practices to our remote workforce to encourage conservation efforts in home offices and daily life.
  • Encouraging Reporting of Water Issues:
    Urging employees to report leaks or water wastage to Management.
  • Sustainable Landscaping and Water Use
  • Drought-Tolerant Plants:
    Choosing drought-tolerant plants inside our office to reduce the need for irrigation.
  • Monitoring and Continuous Improvement
  • Feedback Mechanism:
    Establishing a feedback mechanism for employees to suggest improvements to our water conservation practices.

Policy Compliance and Reporting

Compliance:

All employees are expected to comply with this water use and conservation policy as part of their commitment to nfoldROI environmental sustainability goals.

Annual Sustainability Reporting:

Including water usage and conservation efforts in our annual sustainability report to share our progress and future goals with stakeholders.

Energy Use

Policy Objective

The primary objective of this policy is to achieve a sustainable reduction in energy consumption, thereby lowering our carbon footprint and contributing to environmental preservation. We are dedicated to implementing energy-efficient practices, investing in renewable energy sources, and fostering an organizational culture of sustainability.

Scope

This policy applies to all employees, contractors, and operations of nfoldROI, including our corporate offices, remote work settings, and our outsourced workspace membership.

Strategies for Energy Conservation

Energy-Efficient Infrastructure:

Lobby the landlord to design and maintain our office spaces with energy efficiency in mind, utilizing LED lighting, energy-efficient HVAC systems, and implementing smart building technologies to optimize energy use.

Remote Work and Energy Use

Support for Remote Employees:

Provide guidelines and support to remote employees to optimize energy use in their home offices, including recommendations for energy-efficient office equipment and best practices for minimizing energy consumption.

Virtual Meetings:

Encourage the use of virtual meetings to reduce the need for travel, thereby saving energy associated with transportation.

Employee Engagement and Training

Awareness Campaigns:

Launch awareness campaigns to educate employees about the importance of energy conservation and practical steps they can take to reduce energy use both at work and at home.

Energy Champions:

Appoint energy champions within departments to lead by example, monitor energy use, and encourage their peers to adopt energy-saving practices.

Compliance and Policy Review

Continuous Improvement:

Regularly review and update this policy to reflect new technologies, industry best practices, and changes in regulatory requirements.

SOCIAL

Human Rights

Policy Objective

This policy outlines our commitment to conducting our business in a manner that respects the human rights of all our stakeholders, including employees, customers, suppliers, and the communities in which we operate. We aim to identify, prevent, and mitigate any adverse human rights impacts resulting from our business activities.

Scope

This policy applies to all employees, contractors, suppliers, and business partners of nfoldROI across all regions and aspects of our operations.

Commitments

Non-Discrimination and Equality:

We commit to providing an inclusive environment that is free from discrimination based on race, colour, sex, language, religion, political or other opinions, national or social origin, property, birth, or other status.

Labour Rights:

We uphold the freedom of association, recognize the right to collective bargaining, and support the elimination of all forms of forced or compulsory Labor, child labour, and employment discrimination.

Health and Safety:

We are dedicated to ensuring a safe and healthy work environment for all our employees and partners by adhering to international safety standards and best practices.

Privacy and Data Protection:

We respect the privacy rights of individuals and are committed to protecting personal data in accordance with relevant laws and regulations.

Supplier and Partner Expectations:

We expect our suppliers and business partners to uphold similar human rights standards, and we incorporate human rights considerations into our selection and evaluation processes.

Implementation and Governance

Risk Assessments:

Regularly conduct human rights impact assessments across our operations and supply chain to identify risks and implement appropriate mitigation strategies.

Training and Awareness:

Provide ongoing human rights training for our employees, particularly those in decision-making roles, to ensure they understand and can fulfill our human rights commitments.

Grievance Mechanism:

Establish a grievance mechanism for employees and external stakeholders to report human rights concerns or violations without fear of retaliation.

Monitoring and Reporting:

Monitor compliance with this policy and report on our human rights performance and initiatives in our annual sustainability report.

Compliance and Review

This policy will be reviewed annually and updated as necessary to reflect evolving international human rights standards and best practices. We are committed to complying with all applicable laws and regulations relating to human rights in the countries where we operate.

Labor Rights
Policy Objective

This policy outlines our commitment to adhering to international and local labour laws and standards, protecting the rights of our workforce, and implementing comprehensive health and safety practices across our operations. We aim to prevent workplace injuries and illnesses, promote well-being, and ensure that all employees are treated fairly and with dignity.

Scope

This policy applies to all employees, contractors, and subcontractors of nfoldROI across all regions and divisions.

Labour Rights Commitments

Freedom of Association and Collective Bargaining:

We recognize and respect the right of employees to freely associate, organize, and negotiate collectively in a lawful and peaceful manner.

Non-Discrimination:

We are committed to providing an inclusive workplace free from discrimination based on race, colour, religion, sex, national origin, disability, age, sexual orientation, gender identity, or any other characteristic protected by law.

Fair Compensation:

We ensure that all employees receive fair remuneration that complies with or exceeds minimum wage laws and regulations. Compensation will be timely, and clearly detailed in pay statements.

Working Hours:

We adhere to applicable laws and standards regarding working hours, overtime, and rest periods, ensuring that employees have adequate time for rest and leisure.

No Forced or Child Labour:

We strictly prohibit the use of all forms of forced or compulsory labour, as well as the employment of children below the minimum age for employment as defined by law.

Workplace Health and Safety Commitments

Safe Work Environment:

We pledge to maintain a workplace that prioritises health and safety above all, strictly adhering to Australia’s health and safety laws, regulations and industry standards. Our commitment extends to creating an environment where physical and psychological well0beingn is protected, and all employees feel secure and valued.

Risk Management:

Through diligent and regular risk assessments, we actively identify potential workplace hazards. Based on these evaluations, we systematically implement targeted safety measures and robust emergency procedures to mitigate risks. This proactive approach ensures a continuously safe working environment, adapting to new challenges and industry advancements.

Training and Education:

Each employee will undergo comprehensive training tailored to their specific roles within the utility and telecommunications sectors. This training includes the correct usage of safety equipment, emergency response techniques, and routine safety protocol updates to ensure compliance with evolving industry standards and technologies..

Employee Participation:

We champion a participatory approach to health and safety, where every employee is encouraged to contribute their insights and suggestions. This collaborative environment fosters a culture of safety that values employee input, enhancing our collective ability to identify and mitigate risks before they lead to incidents.

Health and Wellness:

Recognizing the integral role of well-being in employee performance and satisfaction, we support our team with various wellness programs. These initiatives include mental health support, fitness programs, flexible working arrangements that accommodate personal health needs and family commitments, fostering a balanced and supportive workplace. Our goal is to promote a holistic approach to health that supports each employee’s physical and mental well-being, contributing to a healthier, more productive workplace.

Implementation and Enforcement

Responsibility:

The HR Department, in collaboration with our WHS Officer, is responsible for implementing, monitoring, and enforcing this policy.

Reporting and Response:

Employees are encouraged to report any labour rights or health and safety concerns without fear of retaliation. All reports will be investigated promptly, and corrective actions will be taken as necessary.

Review and Continuous Improvement:

This policy will be reviewed annually and updated as required to reflect changes in laws, regulations, and best practices.

Gender & Diversity

Policy Objective

This policy aims to eliminate discrimination, promote diversity, and ensure gender equality within nfoldROI. Our goal is to ensure that all employment practices, including hiring, promotion, professional development, and work-life balance initiatives, are conducted in a manner that is fair, equitable, and promotes the well-being of all employees.

Scope

This policy applies to all employees, contractors, interns, and part-time staff at nfoldROI, as well as to all aspects of employment, including recruitment, compensation, benefits, training, promotions, and termination.

Commitments

Equal Opportunities:

We are committed to providing equal employment opportunities to all individuals, ensuring that decisions are based on merit, qualifications, and abilities.

Diversity and Inclusion Training:

All employees, especially management and HR personnel, will receive regular training on diversity and inclusion best practices, unconscious bias, and how to create an inclusive workplace culture.

Gender Equality:

We strive to achieve gender balance at all levels of the organization, including leadership positions, and ensure that gender does not influence career development opportunities.

Flexible Working Arrangements:

To support work-life balance and accommodate diverse needs, we offer flexible working arrangements, including part-time work, telecommuting, and flexible hours where operationally feasible.

Zero Tolerance for Discrimination and Harassment:

We maintain a strict zero-tolerance policy for any form of discrimination or harassment based on gender or any other characteristic. Incidents will be promptly investigated, and appropriate actions will be taken.

Employee Resource Groups:

We encourage the formation of employee resource groups as platforms for support, networking, and advocacy on diversity-related issues.

Monitoring and Reporting:

We will monitor our recruitment, retention, and promotion processes to identify areas for improvement in our diversity and inclusion efforts. Progress will be reported annually in our sustainability or corporate responsibility report.

Implementation and Governance

Responsibility:

The HR Department, supported by the Diversity and Inclusion Committee, is responsible for implementing, monitoring, and periodically reviewing this policy.

Feedback and Suggestions:

Employees are encouraged to provide feedback or suggestions on how nfoldROI can further promote gender equality and diversity within the workplace.

Review:

This policy will be reviewed annually to ensure it remains relevant, effective, and aligned with our organizational goals and societal expectations.

Community & Customer Impact

Policy Objective

The aim of this policy is to guide our actions and decisions in a manner that positively impacts our communities and customers. We are committed to operating responsibly, contributing to the betterment of society, and enhancing the well-being of our customers through ethical business practices, community involvement, and exceptional customer service.

Scope

This policy applies to all employees, contractors, and partners of nfoldROI, encompassing all areas of our business operations, from product development to sales and customer support.

Commitments to Our Communities

Community Engagement and Investment:

Actively engage with community stakeholders to understand their needs and invest in programs that contribute to local development, including education, health, and environmental sustainability.

Volunteerism:

Encourage and support employee participation in volunteer activities that contribute to community welfare, offering paid volunteer time as part of our commitment.

Sustainable Practices:

Implement environmentally sustainable business practices to minimize our ecological footprint and contribute to the health and longevity of the communities we serve.

Commitments to Our Customers

Customer-Centric Innovation:

Ensure our product development processes are informed by and responsive to customer needs, focusing on creating solutions that enhance their lives and businesses.

Transparency and Integrity:

Maintain the highest levels of transparency and integrity in all customer interactions, ensuring that our products and services are represented accurately and ethically.

Exceptional Customer Service:

Provide timely, respectful, and effective customer service, ensuring that all customer feedback is heard, valued, and addressed appropriately.

Privacy and Data Protection:

Uphold strict standards of privacy and data protection, ensuring our customers’ information is secure and used responsibly.

Implementation and Governance

Responsibility:

The HR Department, in collaboration with all business units, is responsible for the implementation and periodic review of this policy.

Performance Measurement:

Establish key performance indicators (KPIs) related to community engagement and customer satisfaction to measure the effectiveness of our initiatives and identify areas for improvement.

Reporting:

Regularly report on our community and customer impact initiatives and outcomes in our annual CSR report, sharing our progress with stakeholders.

Feedback and Continuous Improvement

Stakeholder Feedback:

Actively seek feedback from communities, customers, and employees to inform our community engagement and customer service practices.

Policy Review:

This policy will be reviewed annually to ensure it remains relevant and effective in achieving its objectives.

GOVERNANCE

Board

Policy Objective

The objective of this policy is to ensure effective, transparent, and accountable governance of nfoldROI, enhancing shareholder value and ensuring compliance with applicable laws and regulations. This policy aims to foster a governance environment that supports informed decision-making, risk management, and ethical business practices.

Scope

This policy applies to the Board of Directors and all appointed committees of nfoldROI.

Board Composition and Structure

Composition:

The Board shall consist of a balanced mix of experienced and knowledgeable directors, including both executive and independent non-executive members, to ensure a diversity of perspectives and expertise.

Independence:

A majority of the Board shall be independent directors – if possible – to ensure unbiased oversight and decision-making.

Committees:

The Board shall establish committees, such as Audit, Risk, Compensation, and Nominations, to support its work in key areas of governance, each operating under a written charter.

Roles and Responsibilities

Strategic Oversight:

The Board is responsible for overseeing the company’s strategic direction, ensuring alignment with shareholder interests and market dynamics.

Risk Management:

Oversee the company’s risk management framework, ensuring significant risks are identified, assessed, and managed appropriately.

Succession Planning:

Ensure robust succession planning processes for senior executives and Board members to maintain continuity and stability.

Financial Integrity:

Oversee the integrity of the company’s financial statements and disclosures, ensuring accuracy and transparency in reporting.

Compliance and Ethics:

Ensure the company complies with all applicable laws, regulations, and ethical standards, fostering a culture of integrity and accountability.

Board Performance and Evaluation

Self-Evaluation:

Conduct annual 360 Reviews to assess the Board’s performance and effectiveness, identifying areas for improvement.

Director Education:

Support ongoing education and development opportunities for directors to enhance their skills and knowledge relevant to their roles.

Stakeholder Engagement

Communication:

Maintain open and transparent communication with shareholders and other stakeholders, providing timely and accurate information about the company’s performance and governance practices.

Stakeholder Feedback:

Regularly seek and consider feedback from stakeholders to inform governance practices and decisions.

Policy Review and Updates

This policy will be reviewed annually by the Board to ensure it remains relevant and effective in guiding the governance of nfoldROI. Any amendments will be made in consideration of evolving best practices, regulatory requirements, and the strategic needs of the business.

Independent Director/Chair

Policy Objective

The objective of this policy is to define the roles, responsibilities, and criteria for Independent Directors and the Independent Chair of the Board, ensuring that nfoldROI benefits from unbiased judgment and independent oversight in its governance practices.

Scope

This policy applies to the Board of Directors of nfoldROI, with specific focus on the appointment, roles, and responsibilities of Independent Directors and the Independent Chair.

Definition of Independence

An Independent Director is one who, aside from their directorship, does not have any material or pecuniary relationship with the company or its associated persons, which could, in the opinion of the Board, interfere with exercising independent judgment in carrying out the responsibilities of a director.

Appointment and Criteria

Selection Process:

Independent Directors and the Independent Chair shall be selected through a rigorous and transparent process overseen by the Nominations Committee, ensuring candidates meet the independence criteria established by the company and regulatory bodies.

Criteria:

Candidates for Independent Directors and the Independent Chair must demonstrate significant expertise in the tech services and software industry, leadership experience, and a commitment to upholding the highest standards of governance and ethics.

Roles and Responsibilities

Independent Oversight:

Independent Directors and the Independent Chair are tasked with providing unbiased oversight of the company’s operations, particularly in areas such as strategic planning, risk management, and financial reporting.

Board Committees:

Independent Directors are expected to play a leading role in key committees, such as Audit, Risk, and Compensation Committees, to ensure these committees function with integrity and independence.

Advisory Role:

Serve as advisors to the executive management team, offering independent perspectives and guidance on the company’s strategic direction and policies.

Stakeholder Engagement:

Facilitate communication between the company’s management and its shareholders and other stakeholders, ensuring that their views are considered in the Board’s decision-making process.

Leadership:

The Independent Chair shall lead the Board, ensuring that it functions effectively and cohesively, and that directors fulfill their duties and responsibilities for the benefit of the company and its stakeholders.

Performance Evaluation

Conduct annual evaluations of the performance of Independent Directors and the Independent Chair to assess their contribution to the Board’s effectiveness and their adherence to the independence criteria.

Training and Development

Provide ongoing education and training opportunities for Independent Directors and the Independent Chair to stay abreast of industry trends, regulatory changes, and best practices in governance.

Policy Review and Updates

This policy shall be reviewed annually to ensure it continues to align with regulatory requirements, industry best practices, and the strategic needs of nfoldROI.

Board Systems

Policy Objective

The aim of this policy is to establish clear governance around the digital systems and tools used by our Board of Directors, ensuring that these technologies enhance board efficiency, facilitate informed decision-making, and uphold the highest standards of data security and privacy.

Scope

This policy applies to all digital systems, platforms, and tools utilized by the Board of Directors of nfoldROI, including but not limited to board management software, communication tools, and data storage solutions.

System Selection and Implementation

Adopt digital systems that are reputable, reliable, and tailored to the needs of our Board of Directors, ensuring they facilitate effective governance and strategic oversight.

Implement systems following thorough security and compliance vetting, with regular reviews to ensure they remain aligned with our business and governance needs.

Access Control and Security

Ensure strict access controls are in place for all board systems, granting access based on roles and responsibilities, to safeguard sensitive information and protect against unauthorized access.

Employ advanced security measures, including encryption, multi-factor authentication, and regular security audits, to maintain the integrity and confidentiality of board communications and documents.

Training and Support

Provide comprehensive training for all board members on the use of board systems, focusing on operational functionalities, security practices, and compliance requirements.

Offer ongoing technical support to resolve issues promptly and keep the board’s operations running smoothly.

Data Management and Compliance

Adhere to relevant data protection regulations and corporate policies in managing, storing, and disposing of data within board systems, ensuring compliance and protecting stakeholder privacy.

Establish clear guidelines for data retention, archiving, and deletion to meet legal and regulatory obligations.

System Monitoring and Evaluation

Regularly monitor the use of board systems to ensure they are being used effectively and securely, identifying any areas for improvement.

Conduct annual evaluations of board systems to assess their impact on board governance, efficiency, and strategic decision-making, making adjustments as necessary.

Disaster Recovery and Business Continuity

Implement robust disaster recovery and business continuity plans for board systems to ensure that board operations can continue without interruption in the event of a system failure or cyber incident.

Policy Review and Updates

This policy will be reviewed annually by the Board of Directors, in collaboration with the IT department and legal advisors, to ensure it remains relevant and effective in light of technological advancements and evolving regulatory requirements.

Reporting Pack

Policy Objective

The objective of this policy is to establish a robust governance framework for the production and dissemination of reporting packs, which are essential for internal decision-making and external reporting purposes. This framework aims to ensure consistency, accuracy, and compliance across all reporting activities, enhancing transparency and accountability in our operations.

Scope

This policy applies to all internal and external reporting packs produced by nfoldROI including financial, operational, ESG and other compliance reports. It covers the processes from data collection to report distribution and applies to all employees involved in the reporting process.

Standardization of Reporting Packs

Develop and maintain standardized templates and guidelines for reporting packs to ensure consistency across different types of reports and time periods.

Clearly define the content, format, and frequency of each reporting pack, tailored to the specific needs of the intended audience.

Data Integrity and Accuracy

Implement controls and checks to ensure the accuracy, completeness, and reliability of the data used in reporting packs.

Adopt automated data collection and reporting tools where possible to reduce the risk of human error.

Review and Approval Process

Establish a formal review process for reporting packs, involving cross-functional teams, to ensure the accuracy and completeness of information.

Require final approval from designated senior executives or the Board of Directors, depending on the nature and purpose of the report.

Compliance and Regulatory Reporting

Ensure all reporting packs comply with relevant legal, regulatory, and industry standards, including those specific to the utilities and telecommunications sectors.

Keep abreast of changes in reporting requirements and update reporting packs accordingly.

Security and Confidentiality

Maintain strict controls over the distribution of reporting packs to protect sensitive and confidential information.

Use secure distribution methods and restrict access to authorized recipients only.

Training and Awareness

Provide ongoing training for staff involved in the reporting process to ensure they understand their roles, the company’s reporting standards, and the importance of data accuracy and compliance.

Foster a culture of accountability and excellence in reporting practices.

Audit and Continuous Improvement

Subject reporting processes to regular internal audits to assess compliance with this policy and identify areas for improvement.

Solicit feedback from report users to continuously refine and enhance the quality and usefulness of reporting packs.

Policy Review and Updates

This policy will be reviewed annually or more frequently if significant changes in reporting standards or requirements occur. The Finance and Compliance departments will oversee policy reviews and updates.

Shareholders Agreement

Policy Objective

The objective of this policy is to ensure that all shareholders are provided with comprehensive information about nfoldROI’s performance and governance, and are given opportunities to engage effectively with the company. This policy aims to foster open communication, encourage active participation in shareholder meetings, and uphold high standards of corporate governance.

Scope

This policy applies to all aspects of our interactions with shareholders and covers our approach to shareholder communications, meetings, voting, and feedback.

Principles of Shareholder Engagement

Transparency and Disclosure

Commit to providing timely, accurate, and accessible information about the company’s financial performance, strategic direction, and operational developments.

Ensure that all disclosures comply with relevant securities regulations and meet industry best practices.

Communication Channels

Utilize a variety of channels to communicate with shareholders, including annual reports, quarterly updates, the company website, and social media.

Offer a dedicated section on the company website for shareholder information, including financial data, governance documents, and details on how to contact the company directly with inquiries or concerns.

Shareholder Meetings

Conduct annual general meetings (AGMs) and, where necessary, extraordinary general meetings (EGMs) in a manner that encourages shareholder participation.

Provide comprehensive information about meeting agendas, procedural rules, and voting procedures well in advance of the meetings.

Facilitate remote participation and voting to ensure that shareholders who cannot attend in person are still able to participate.

Equitable Treatment

Ensure that all shareholders, regardless of the size of their holdings, are treated equitably.

Provide all shareholders with the opportunity to consult with the company on issues that significantly affect their interests.

Feedback and Response

Encourage shareholders to provide feedback and raise issues, and commit to addressing such feedback promptly and constructively.

Implement a mechanism for shareholders to communicate directly with the Board, particularly with the Non-Executive Directors or the Chairman, on governance-related matters.

Corporate Governance Oversight

The Board of Directors will have ultimate responsibility for overseeing the implementation of this policy, ensuring that the company’s obligations to shareholders are met.

Regularly review governance practices and this policy to align with evolving best practices and regulatory changes.

Review and Updates:

Conduct an annual review of this policy to ensure its effectiveness and alignment with the latest regulatory requirements and best practices in corporate governance.

Any amendments to this policy will be approved by the Board of Directors and communicated to shareholders in a timely manner.