givvable provides various data products and services that serve a variety of client types. It has developed a conflicts of interest framework designed to effectively manage actual or potential conflicts of interest arising from its business activities and the development and provision of its data products (together, ESG activities).

The framework encompasses several essential components including disclosure to the public and relevant authorities of possible conflicts of interest, implementation of policies and procedures for identifying and managing conflicts of interest, periodic evaluation and monitoring the effectiveness of our policies and procedures, and the provision of training to all our employees on recognizing and managing conflicts of interest.

givvable has identified different types of actual or potential conflicts of interest relating to its ESG activities:

(i) Commercial factors (including fees, engagement progress, partnerships, subscriptions, referral and licensing arrangements) could impact, or give the appearance of impacting, its objectivity in connection with its ESG activities.

(ii) Different ESG activities serving different clients’ needs could potentially impact, or give the appearance of impacting, objectivity related to one or more of those ESG activities.

(iii) Remuneration/other incentives (whether financial or otherwise and whether received by givvable or its employees) could potentially impact, or give the appearance of impacting, givvable’s objectivity in respect of its ESG activities.

(iv) A client of givvable, or a Subject Entity who is also a vendor or a supplier to givvable could potentially impact, or give the appearance of impacting, objectivity in respect of its ESG activities. A Subject Entity is an organisation for which givvable holds credential or attribute data and/or has registered on givvable.

(v) A givvable employee’s personal ownership interests (including in securities and money market instruments) could impact, or give the appearance of impacting, givvable’s objectivity in respect of its ESG activities.

(vi) A givvable employee’s more than arm’s length, ordinary course of business relationships (including outside business activities) could impact, or give the appearance of impacting, givvable’s objectivity in respect of its ESG activities.

(vii) A givvable employee’s receipt of gifts, entertainments or inducements could impact, or give the appearance of impacting, givvable’s objectivity in respect of its ESG activities.

(viii) Material non-public information accessed during the course of their employment may influence a givvable employee’s actions in respect of their personal ownership interests.

Identification of Conflicts of Interest

givvable recognizes the importance of maintaining the integrity and objectivity of its ESG activities. givvable also acknowledges the potential and perceived conflicts of interest arising as a result of receiving fees for ESG data products and services, and the associations and interactions that givvable employees may have with external parties, as well as the potential and perceived conflicts of interest arising from the personal interests of givvable employees.

givvable maintains a list of actual or potential conflicts of interest including activities which are prohibited or, where permissible, managed through written policies and procedures. This list and related policies, procedures and controls are reviewed periodically. Management of Conflicts of Interest

givvable has established the following procedures, measures and mechanisms for the effective management of actual or potential conflicts of interest relating to ESG activities.

(i) Internal organization and infrastructure: givvable maintains a robust governance structure with clear reporting lines, roles and responsibilities. givvable’s sustainability team who is responsible for mapping Subject Entities’ sustainability actions, are subject to access control protocols to prevent them from viewing any pricing or subscription documentation that includes how pricing is determined/calculated. All givvable personnel are prohibited from accepting any inducements, fees or gifts above a fair market value assessment of AUD$20.00 from Subject Entities, partners or clients.

(ii) Compliance framework: The givvable Compliance program includes, but is not limited to, policies and procedures, personal interest disclosure obligations, compliance monitoring and review, and mandatory compliance training.

(iii) Confidential Information: As a general practice, givvable bases its ESG activities, which include the mapping of sustainability & ESG credentials, on information disclosable in nature, already publicly disclosed/available, directly from Subject Entities and/or directly from primary source data issuers. To the extent that Confidential Information is received, givvable Personnel may only share or discuss Confidential Information or material non-public information in accordance with givvable’s policy on data privacy and security.

(iv) Remuneration: The remuneration structure for any givvable Personnel is not directly linked to specific ESG activity outcomes.

(v) Personal Interests: At the start of employment and periodically thereafter, givvable Personnel are required to provide the givvable Compliance team with information in relation to personal interests, such as securities ownership and trading information, outside business interests, significant personal relationships, and former employment. The Compliance team will determine whether any actual or potential conflicts of interest exist and will direct the employee to take appropriate action, which can include divestment of financial interests, removal from outside business appointments.

(vi) ESG data processes and methodology: givvable applies its methodology consistently across its processes for development and provision of its data products and services and uses the same standard of objectivity when assessing or interacting with Subject Entities and primary source data issuers, irrespective of whether the Subject Entity or data issuer is also a client, business partner or supplier. givvable has controls and measures in place to ensure the effectiveness of and adherence to its data import and mapping processes and that mapping is the result of an appropriate and consistent application of givvable’s methodology.

(vii) Communication with clients, Subject Entities and primary source data issuers: Communication with primary source data issuers in relation to mapping of credentials is managed by the Sustainability Team, while commercial related communication is managed by Business Development, Sales and Co-Founder teams. Business Development and Sales teams are prohibited from discussing specific pricing details with the Sustainability team that have the potential to put pressure on such personnel (e.g. contract value, client tier etc). Data and support teams communicate with Subject Entities, and to the extent that a Subject Entity is also a prospective client or client, the Business Development, Sales and Co-Founder teams may also have contact them.

Monitoring and reporting of Conflicts of Interest

In addition to disclosing the list of actual or potential conflicts of interest either prohibited by, or managed by, givvable, the givvable Compliance team ensures that the Conflicts of Interest policy is periodically reviewed.

Where required, the givvable Compliance team is responsible for publishing and/or disclosing all actual or potential conflicts of interest to the public and/or to the relevant national competent authority.cribe your values, show more info, summarize a topic, or tell a story.