Environmental, Social and Governance (ESG) Policy

Environmental:

We recognise our business has an impact on the environment. The depletion of natural resources and the threat of climate change have raised concerns about the environment and the potential financial impact on businesses. Sustainable options are increasingly being considered as part of investment choices.

We comply with environmental protection laws, including recycling and waste disposal requirements and seek to minimise any detrimental effects our activities may have on the environment. Wherever possible, employees are strongly encouraged to use the lowest form of carbon-emission transport for the many meetings they attend and to maximise the use of video-conferencing rather than travel. A high proportion of our mediations are now carried out via Zoom or Teams. We are a very low user of paper and advocate the reduction of paper use by all personnel. Our marketing materials (for example, our sector wide monthly newsletter) are online resources wherever possible. If reducing consumption is not a viable option, we use materials derived from renewable or sustainable sources.

Social:

Access to Justice
Manolete has innovated a new business model and approach to insolvency litigation. The vast majority of insolvency claims were traditionally financed using lawyer Conditional Fee Arrangements and Adverse Cost Insurance policies and resulted in small returns for creditors - where monies were absorbed by various costs and owing to long average case durations. Manolete settles cases, in the main, much more rapidly allowing for a higher proportion of returns to be given back to the creditors. We make clear in presentations, meetings and on our website that our ethos is to deliver greater justice to creditors.

We also ensure the monetary returns are paid to the insolvent estate very promptly once the case is settled. We have built a very strong rapport with hundreds of Insolvency Practitioners who approve of our ethos, our conduct and promise to deliver efficient returns to the estate. Every Insolvency Practitioner we have worked with has returned with additional cases.

Invariably the most substantial creditor is HMRC. We are very mindful of the significance of delivering value to HMRC and have done so in a great many cases, returning millions of pounds to the public finances through HM Treasury. Consequently we have fostered a strong working relationship with HMRC who see we can achieve much greater and quicker returns.

Diversity and Inclusion
We believe our employees are central to the success of our business, are committed to their development and providing recognition based on success and achievement. We are an equal opportunities employer and it is our policy to ensure all job applicants and employees are treated fairly and on merit regardless of their race, gender, marital status, age, disability, religious belief or sexual orientation. We recognise the importance of being a diverse and inclusive place to work where everyone has an equal opportunity to build their career and succeed.

We are committed to creating a safe and healthy environment for all employees and contractors. We promote diversity, fairness and respect in our working environment and do not tolerate any improper behaviour or harassment. The Board’s remuneration committee reviews all pay levels to ensure all awards and bonuses are given fairly and on merit. We believe in achieving a gender balance across the company and 45% of our senior legal team is female including our Head of Legal. We have created strong lines of management accountability and we invest in the development of our employees in taking training courses to enhance their skills and widen their experience.

Communities
We contribute to the communities in which we operate including local and national charities (including Great Ormand Street Hospital for Children) and operating work experience programmes.

Governance:

Corporate Governance Code
Details of Manolete’s corporate governance code and how we apply it can be found at:
https://investors.manolete-partners.com/company-information/corporate-governance

Code of Conduct
The Manolete Board requires the highest standards of corporate governance, operational excellence and financial reporting throughout the Company and from all directors and employees. In turn this demands that the Company, its directors and its employees operate in an honest, professional and ethical manner which is essential for our reputation as well as building trust and respect with our key stakeholders including customers, business associates, employees, communities and shareholders.

This Code of Conduct contains the fundamental business principles that set these standards and guides our conduct across the Company and in our business dealings. The Company expects all business associates to follow the principles set out in the Code. We trade lawfully and properly at all times and, as a minimum, comply with all laws and regulations.

Integrity
Our reputation is built on our values as a Company, the values of our employees and our collective commitment to acting with integrity throughout our organisation. Accordingly no director or employee may:

  • pursue any personal or business interests which could interfere or be seen to interfere with the business or interests of any member of the Company; or
  • accept or provide gifts or entertainment which cause inappropriate influence over the recipient, or give the appearance of doing so.

In particular, all directors and employees are required to disclose any substantial interest they or their immediate family might have in our suppliers, customers or competitors. We do not tolerate any form of bribery in our business or in those we do business with and the Company has in place an anti-bribery and corruption policy reflecting the standards that we expect of our staff and those who perform services for us.

Slavery and Human Trafficking
Manolete has a zero tolerance approach to any form of slavery and human trafficking within our business and is committed to taking appropriate steps to ensure compliance with the legislation. During the last fiscal year, we continued to review our business associates to ensure compliance with the latest legislation including pursuing the necessary policies to protect against modern slavery and human trafficking within their businesses.

The Manolete Chief Executive annually reviews the Company’s effectiveness in measuring the risk of slavery and human trafficking and presents its findings to the Board, who approve its effectiveness and the Company’s Modern Slavery Statement, and/or make recommendations for improvement in the processes and management within the Company. To ensure all staff are aware of and have a clear understanding of the risk of modern slavery and human trafficking within our business, we request all staff and directors confirm they have read and understood the Company’s Modern Slavery Statement. Training will be provided for all staff members on modern slavery and human trafficking to raise awareness of the legislation and be more vigilant generally.

Customers
We are committed to treating our customers in an open, honest and fair manner (including selling products and services that fulfil their needs and meet the appropriate quality criteria in accordance with regulatory and legal requirements) as well as operating an effective complaints process to address any issues that may arise.

Competition
We are committed to fair and competitive sales practices and to treating our business associates properly and fairly and in accordance with relevant competition laws. We do not engage in or be party to practices or agreements that would unfairly limit trade or exclude competitors from the market place.

Information
We ensure the recording of all business transactions is complete and accurate and we protect against inappropriate access or use of confidential and privileged information relating to the Company. We provide accurate and timely information to external stakeholders in compliance with relevant laws and regulations. We give regular presentations to investors and make every attempt to share as much relevant data with them as possible to ensure the company’s financial position is clear to the market.

Crime prevention
The matter of fraud and financial crime is core to our business and we have measures in place for detecting, preventing, reporting, investigating and prosecuting suspected fraud and financial crime. We have effective anti-fraud and anti-money laundering systems and controls as well as an anti-bribery and corruption policy in place in addition to effective claims management and counter-fraud capabilities. We also share data with appropriate industry bodies and government agencies.

Regulators
We are committed to engaging with our Regulators in an open, honest and transparent manner which is essential in order to build trust and promote the regulatory framework in which we operate.

Reporting
Any questions, concerns or alleged breaches in respect of this Code or any other matter may be raised by employees through line management or the Company’s Board of Directors, Whistleblowing Policy or Grievance Procedure. Business associates may also raise questions or issues through their relationship manager at the Company. All reports are treated confidentially and investigated promptly and properly.