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Environmental, Social and Governance (ESG) Policy

1. Purpose and Scope

This ESG Policy sets out the principles and practical commitments of CloudCapcha Limited (the “Company”), a UK‑incorporated private limited company providing professional services to clients in the UK, Australia and the United States.

The policy is designed to be proportionate to the Company’s size, risk profile, and operational footprint, while aligning with the expectations typically applied by large international accounting and professional services firms when assessing suppliers, partners, or counterparties.

This policy applies to all directors, employees, contractors, and key suppliers where relevant.

2. Proportionality Statement

The Company recognises that ESG obligations should be applied in a manner that is:

  • Appropriate to a small, professional‑services organisation
  • Risk‑based rather than compliance‑heavy
  • Focused on actual conduct and outcomes, not reporting volume

Accordingly, the Company does not currently fall within the scope of mandatory UK ESG reporting regimes (including SECR, TCFD, or CSRD‑equivalent requirements), but adopts the principles below on a voluntary and pragmatic basis.

3. Environmental Responsibility

The Company’s environmental impact is limited, as it operates primarily as a digital and office‑based professional services business with no manufacturing or physical supply chain.

The Company commits to:

  • Minimising energy consumption in office and home‑working environments where practicable
  • Encouraging remote and hybrid working to reduce commuting‑related emissions
  • Using cloud‑based systems and digital documentation to reduce paper usage
  • Complying with all applicable environmental laws and regulations in the UK and other relevant jurisdictions

The Company does not currently measure Scope 1, 2, or 3 emissions due to scale and materiality, but will keep this position under periodic review.

4. Social Responsibility

4.1 People and Workplace

The Company is committed to maintaining a fair, inclusive, and respectful working environment.

Key principles include:

  • Compliance with UK employment law and applicable local labour standards
  • Zero tolerance for discrimination, harassment, or bullying
  • Commitment to equal opportunity regardless of gender, age, ethnicity, disability, sexual orientation, or religion
  • Fair and transparent remuneration practices appropriate to role and market

4.2 Health, Safety and Wellbeing

Given the nature of the Company’s activities, health and safety risks are low.

The Company commits to:

  • Providing a safe working environment for employees and contractors
  • Supporting reasonable adjustments and flexible working where appropriate
  • Promoting wellbeing through workload management and autonomy

4.3 Clients and Stakeholders

The Company aims to act responsibly and ethically in all client relationships.

This includes:

  • Delivering services with professional competence and integrity
  • Maintaining confidentiality and data protection standards
  • Avoiding conflicts of interest and managing them transparently where they arise

5. Governance

5.1 Ethical Conduct

The Company operates to high standards of business ethics and professional conduct.

The Company commits to:

  • Acting honestly, fairly, and in good faith in all business dealings
  • Complying with all applicable laws and regulations, including UK Companies Act requirements
  • Maintaining appropriate anti‑bribery and anti‑corruption controls proportionate to its size and risk

5.2 Data Protection and Information Security

The Company recognises the importance of data protection, particularly given its international client base.

The Company commits to:

  • Compliance with UK GDPR and applicable data protection laws
  • Maintaining appropriate technical and organisational safeguards for client and employee data
  • Using reputable third‑party systems and vendors

5.3 Oversight and Accountability

  • Ultimate responsibility for ESG matters rests with the Company’s directors
  • ESG considerations are reviewed periodically as part of general business risk management
  • This policy is reviewed at least every two years, or sooner if there is a material change in the Company’s operations or regulatory environment

6. Supply Chain and Third Parties

Given the Company’s limited supply chain, ESG due diligence is applied on a risk‑based basis.

The Company seeks to:

  • Engage suppliers and partners who operate lawfully and ethically
  • Avoid knowingly working with parties involved in illegal or unethical practices
  • Rely on representations and publicly available information where full due diligence would be disproportionate

7. Continuous Improvement

The Company recognises that ESG expectations evolve over time.

Accordingly, the Company will:

  • Monitor relevant ESG developments affecting small professional services firms
  • Enhance its approach where commercially justified or contractually required
  • Respond reasonably to ESG‑related requests from clients, including large international firms, where proportionate