Sustainability Framework

Cromwell’s sustainability framework is implemented to ensure that we remain focused on improving performance through a structured, responsible and balanced pathway to sustained success. The framework comprises five pillars through which we address material Environment, Social and Governance (ESG) risks and opportunities.

Each Pillar is led by a senior leader in the business who is responsible for adopting the sustainability objectives and targets, embedding them into business plans and for delivering activities and initiatives relating to that particular pillar across the entire business.

Cromwell’s sustainability framework has been approved by the Board and responsibility for the framework has in turn been delegated by the Chief Executive Officer (CEO) to the Chief Sustainability Officer (CSO), who chairs the Group Sustainability Committee.

Group Sustainability Committee

The Group Sustainability Committee is responsible for reviewing ESG topics, setting sustainability strategy and overseeing the delivery of Cromwell’s Group Sustainability Policy. Regular progress reports are submitted to the Board as well as to the Audit and Risk Committee. The Group Sustainability Committee is also responsible for communicating with employees and other key stakeholders as well as overseeing production of the annual sustainability report and all sustainability activities.

Materiality Review

Each year Cromwell conducts a materiality review to identify and prioritise the most relevant ESG issues, taking into account the impact each one has on Cromwell and on its stakeholders.

The materiality review has become an increasingly important tool to check that we are responding appropriately to emerging concerns or legislation as well as to identify opportunities to make ongoing improvements. Conducting an annual review helps to ensure our objectives are appropriate and can respond to the fluid and dynamic environment in which we operate.

Results of the review are used to form our sustainability objectives and are subsequently fed into the setting of business plans, targets and performance plans for the financial year.

Material topics and sustainability objectives are mapped to the corporate risk register so that for each risk there are appropriate mitigation measures. The materiality review allows for new and emerging risks to be identified and recognised in the register. The review process ensures that the business strategy, as well as our sustainability framework are aligned with and integrated into Cromwell's enterprise risk management framework.

Materiality Process