Environmental, Social and Governance Policy

1. About this policy

1.1 Environmental, social and governance issues do not exist in a silo. ESG is about bringing them together under one banner to demonstrate the positive impact Cornerstone is having on the world. ESG is much like corporate social responsibility but on a vastly larger and more measurable scale. 

1.2 This policy will inform our ESG efforts moving forward. This includes, but is not limited to reporting, disclosures (both material and non-material), business practices, policies, procedures, investments, board activities, stakeholder engagement, and investor relations. 

1.3 Nothing in this policy shall be taken or understood to limit or reduce our current committees, both legally and ethically.

2. Purpose of this policy

2.1 The purpose of this policy is to provide information about ESG (Environmental, Social and Governance factors) and to encourage everyone in the Cornerstone family to understand ESG better.

2.2. This policy has been agreed upon by both the Board of Directors of Cornerstone FS PLC and the Senior Management team of our business.

2.3 This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

3. Who is responsible for this policy

3.1 The Chief Executive Officer has overall responsibility for the effective operation of this policy. They have delegated responsibility for overseeing its implementation to the Chief Operating Officer.

3.2 Line managers have day-to-day responsibility for this policy and are the first point of call for any questions about this policy in the first instance.

3.3 This policy is reviewed annually by the Chief Operating Officer. Changes may be made at any time as government guidance develops.

4. Our ESG commitment

4.1 Cornerstone strives to build sustainable, equitable, healthy, and diverse communities through a combination of innovative business practices and exemplary environmental, social and governance (ESG) performance. This commitment informs every aspect of our business, including how we design and build new projects, operate our company, collaborate with stakeholders and report progress. 

4.2 This ESG Policy sets out our approach to sustainability matters. At the heart of the Policy is a corporate culture that has sustainability at the core of all our business operations and values.

5. Our statement on climate change and the environment

5.1 We are committed to driving down our energy and carbon impacts, as we believe that climate change is one of the greatest risks to our world. Our sustainability program is committed to environmentally sustainable initiatives that deliver near-term efficiency, value, and health for our business, our people, and the wider community. 

5.2 We encourage our customers to reduce their impact on the environment by recommending the use of more sustainable materials. We actively promote a paper-free office. We regularly support our clients to avoid printing and we will make all endeavours to be a digital-first business.

5.3 We seek to comply with current environmental legislation and work to minimise the impact of our activities on the environment.

5.4 We support the recommendations of the Taskforce on Climate-related Disclosure (TCFD) and engage with our stakeholders and encourage enhanced disclosure on climate change, biodiversity, and the SDGs, including efforts to advance the underlying goals, such as those of the Paris Agreement.

6. Our statement on social responsibility

6.1 Our focus is to deepen relationships with our key stakeholders by investing in our employees and partnering with our customers, communities, investors and suppliers.

6.2 We are committed to engaging with our employees to provide a dynamic, inclusive and diverse work environment that supports their professional development, as well as promoting a good work-life balance that prioritises their overall health and wellness.

6.3 We will engage employees around safety, health, and wellness.

6.4 We will preserve and promote the protection of human rights and welfare within our own business activities, as well as those of our supply chain, in accordance with our policies.

7. Our statement on ethical governance

7.1 Our focus is to promote strong oversight, transparency and risk management at all levels of our organisation, ensuring the resilience and long-term preservation of value for our business.

7.2 We will maintain strong corporate governance practises through exemplary board stewardship, management accountability, and proactive risk management.

7.3 We will mitigate risk exposure and build the resilience of our business to climate change, earthquakes and other catastrophic events through smart design and sighting.

7.4 We are committed to high ethical standards through a strong Code of Ethics and Business Conduct, ongoing ethics training, and executive leadership that promotes a culture of integrity.

7.5 We cultivate strong stakeholder relationships through transparency, open communications, and responding to stakeholder input.

7.6 We establish clear and effective governance for ESG, set goals and establish accountability. This is set through our ESG committee and reported to our board.

8. Our business and ESG

8.1 ESG is about assessing that net positive impact in the world, and taking concerted, defined and measurable action to improve it. Our value rests in our employees, our communities, and the wider world. Therefore, ESG forms a fundamental part of how our business lives our values in the real world. 

8.2 The ethical and practical values that make up the different parts of ESG  are at the heart of what we as a company stand for. With the growth of ESG and the increased awareness of these factors among our key stakeholders, we have a better opportunity to tell the story of how our business makes a positive impact in the world.

8.3 The drive to assess a broader range of factors in a holistic manner, from environmental and climate change considerations to the social issues and how we invest in our people, to the structure of our business and always reaching for better governance, means we can tell our story better. We welcome opportunities to highlight the positive impact we have on the world.

9. Our duty to the wider world

9.1 As a business, we also have a duty to our people, our customers, and the wider world. ESG gives us an opportunity to bring those impacts together. We value investing in our people as we value protecting our environment and being a good corporate citizen. 

9.2 Fostering openness, sustainability, and respect are our key objectives. We value everyone and strive to work as one team. Our view on ESG is that it is a continuous process of aligning our operations and controls with our values as a company.

9.3 Our commitment to improve our social and environmental performance demonstrates a strong, well-informed management attitude and a values-led culture that is both alert and responsive to the challenges and opportunities of doing business responsibly and sustainably.

10. ESG and our reputation

10.1 ESG is fundamental to our reputation as a business. Reputation is built through frequent and repeated interactions with stakeholders. When those interactions are positive, our business, and our reputation, can thrive. In an uncertain economic climate, positive reputation is one of the key drivers to long term success.

10.2 We want all our stakeholders, from customers to investors to our people, to be proud to be a part of the Cornerstone family.  Part of that pride is understanding how our business makes a positive contribution to the world. 

10.3 Environmental – Environmental sustainability is an ethical and commercial imperative. Managing our carbon footprint goes hand in hand with the strategic necessity to operate efficiently. Our commitment to tackling climate change at a corporate level is fundamental to our strategic objectives. 

10.4 Social – Our people make up our business. Intellectual capital is core to our clients, our business model and our long-term sustainability as a business. We aim to foster an environment that values and nurtures unique talents and contributions from every individual within a culture of inclusivity. While we have progress to make, we are committed to cultivating and empowering change by building an inclusive workplace where all talents can thrive. 

10.5 Governance – Good governance is foundational to our business, and all aspects of ESG. We cannot thrive without paying attention to our compliance obligations. Our business seeks to go beyond the concept of ‘box-ticking’ and embed compliance into the heart of our business.

11. Our responsibility to our customers

11.1 We have an obligation to our customers to offer them the best service. Customers are at the heart of our business, and without these partnerships our business wouldn’t exist. Part of that commitment to customers is about responding to their needs, hearing their concerns and committing ourselves to customer satisfaction.

11.2 The best customers are those who see us as partners in their own enterprise. In turn, those customers reward us with their continued business, and building and maintaining our world-class reputation.

11.3 ESG priorities are drawn not only from investor concerns but customer needs. Customers are asking how we are improving the world around us. How are we protecting our shared natural heritage, investing in our communities and being good corporate citizens? It is imperative on us as a business that all of our interactions with customers are reflective of who they expect us to be. And that is a partner in their own enterprise. A company they are proud to work with and recommend.

11.4 That is why it is important for everyone in the Cornerstone family to understand ESG, its impact and what it means for our company. We want all of our employees to feel proud of being part of our business and the positive impact we have on the world, so that our customers will feel the same.

12. The role team-members play in ESG

12.1. Team members of our business have a vital responsibility to ensure our organisation thrives. When it comes to ESG, this means everyone understands their role in each area of ESG. Each team-member should familiarise themselves with the concept of ESG and also our strategic objectives around ESG. They should know:

  • Our strategic ESG goals
  • How we plan to achieve them and over what time
  • Their individual and team contribution to those goals
  • How to discuss our ESG goals with customers and third parties
  • Where to report potential concerns or actions which go against our policy

12.2 On an individual level, they have an important role to play in meeting our ESG objectives. Here’s how:

12.3 Environmental – We all have a role to play in reducing carbon emissions and getting to net zero. While as a business we are setting organisation-level targets, team members should consider the choices they make and their environmental impact. For instance:

  • When travelling, are there more environmentally friendly options to take?
  • Can some meetings be done remotely instead of travelling?
  • Think before you print
  • Does the office have recycling and energy saving measures?

12.4 Social – Building a diverse and inclusive workforce where everyone feels valued is everyone’s responsibility. Understanding a team-member’s role in bringing people together is critical to our success as a business. From hiring the best talent to encouraging all staff to thrive, we want a workplace where people proactively work to be the best. They can help by:

  • Challenging and reporting discriminatory or offensive behaviour
  • Understanding diversity and inclusion policies
  • Being an active ally for groups often underrepresented
  • Leading by example in your work


12.5 Governance – Good governance goes beyond having the right policies and procedures in place. It’s about embedding compliance in day-to-day work. From completing training on time to actively understanding how regulations affect your work, good governance starts from the individual acting ethically. Team members can take governance to heart by:

  • Being a compliance champion in you their team
  • Referring to policies and procedures instead of shortcuts
  • Being aware of red flags for compliance failures and risks in their area of work
  • Not being afraid to call out poor behaviour or report failures

13. ESG and our value chain

13.1 Our business does not operate in isolation; almost no company does. Value is created through collaboration and partnerships. Similarly, risks can come from not anticipating problems, gatekeeping, and hiding critical information. Traditional risks in supply chains were generally about quality, cost effectiveness and reliability. But seen through an ESG lens, the holistic nature of the third parties, from how they source raw materials to how they treat workers and comply with accepted standards are just as vital.

13.2 A workforce health and safety incident, labour dispute or allegation of corruption can have serious impacts on stakeholders up and down the value chain. The value chain matters, and it is connected. Customers are increasingly voting with their feet and putting pressure on companies to act with ethical decisions in mind. 

13.3 Ethical procurement gets to the heart of the value chain. When we consider the entire value chain, from raw material supplier to end use customer, we can better understand the needs and impacts of our business’s decisions within those relationships. Ethical procurement within the context of ESG means paying attention to the carbon impacts of a supplier, and the labour practises of an end-user. 

13.4 Considering these impacts doesn’t always mean refusing to work with someone in the value chain where there are concerns. Sometimes suppliers are limited, and customers have every right to access our services. It’s about understanding the risks within each relationship and taking concerted action to reduce those risks. 

13.5 For example, if there are concerns about a supplier’s labour practises, we can ensure clauses are inserted into contracts to maintain an adequate standard of employment for those working for the supplier. This can help actively change labour practises, as opposed to simply refusing to work with a supplier. Or when working with a logistics provider, we might ask for emissions reporting so we can then offset the carbon used.

14. Our ESG committee

14.1 Our ESG committee sits directly beneath our board in terms of seniority. The purpose of the committee is to gather and review data from broad parts of the business, then filter and summarise it upwards to the board. The ESG committee is responsible for writing the ESG pages inside the annual report, and producing all information regarding ESG disclosures.

14.2 The aim of the committee is to establish a unified view of ESG, increasing understanding of all three aspects, environmental, social and governance, and to promote robust standards of corporate governance that integrate all these aspects for non-listed real estate vehicles. This will help the industry more effectively integrate ESG factors into the real estate investment decision-making process. 

14.3 The key objectives of the committee are to:

  • Emphasise the importance of environmental measures, sustainability goals and performance, at all levels of the business.
  • Provide best practice on the structure, policies and regulations that impact the business 
  • Increase understanding and awareness of corporate governance and social aspects that impact the industry 
  • Implement and promote common and workable standards of corporate governance for the business

15. Monitoring and enforcement

15.1 We seek to proactively prevent and mitigate instances of non-compliance with this ESG policy. 

15.2 Any breaches or concerns, including ethical concerns or potential breaches in our commitment to high ethical standards should be reported as soon as possible through our whistleblowing channels. 

15.3 Progress on this policy is reported to the Board on a regular basis. Active participation and engagement at all levels of the business is of great importance to ensure ownership of ESG by all staff.