1. Introduction + Purpose

What Does Not LTD ("the Company") is committed to operating as a responsible business that makes a positive contribution to society, the environment, and the economy. This Corporate Social Responsibility (CSR) Policy sets out our commitment to conducting business in an ethical, transparent, and sustainable manner.

This policy reflects our obligations under UK and applicable law, including the Companies Act 2006, the Modern Slavery Act 2015, the Equality Act 2010, and our alignment with the UK Government's Sustainable Development Goals framework and the UN Global Compact principles.

As a London-based company, we recognise the unique opportunities and responsibilities that come with operating in one of the world's most diverse and prominent cities, and we are committed to contributing positively to the communities in which we operate.

2. Scope

This policy applies to:

•       All employees, directors, and officers of What Does Not LTD

•       Contractors, consultants, and temporary workers engaged by the Company

•       Suppliers, business partners, and third parties acting on behalf of the Company

•       All operations, activities, and locations where the Company conducts business

3. Our CSR Pillars

Our CSR strategy is structured around five core pillars, reflecting the areas where we can have the greatest impact:

Environmental Sustainability

Reducing our carbon footprint and minimising environmental impact across all operations.

Social Responsibility

Supporting our employees, local communities, and charitable causes.

Ethical Governance

Upholding the highest standards of integrity, transparency, and accountability.

Diversity & Inclusion

Fostering an inclusive workplace and championing equality.

Supply Chain Responsibility

Ensuring responsible and ethical practices throughout our supply chain.

4. Environmental Sustainability

What Does Not LTD is committed to minimising its environmental footprint in line with the UK's Net Zero Strategy and the Climate Change Act 2008. We will:

4.1 Carbon and Energy

•       Work towards reducing our greenhouse gas emissions in line with the UK Government's Net Zero 2050 targets

•       Measure and report our Scope 1, 2, and 3 carbon emissions annually

•       Prioritise the use of renewable energy sources for our London office and operations

•       Reduce unnecessary business travel and encourage the use of public transport, cycling, and low-emission vehicles

•       Adopt energy-efficient practices, equipment, and technology

4.2 Waste and Resources

•       Pursue a "reduce, reuse, recycle" approach to waste management

•       Minimise single-use plastics and non-recyclable materials

•       Comply with all applicable UK waste regulations, including the Waste (England and Wales) Regulations 2011

•       Promote a paperless working environment where practicable

4.3 Biodiversity and Nature

•       Support London-based biodiversity initiatives and urban greening projects

•       Consider biodiversity impacts in any property, construction, or significant procurement decisions

•       Comply with the Environment Act 2021 biodiversity net gain requirements where applicable

5. Social Responsibility

5.1 Our Employees

Our people are our greatest asset. We are committed to:

•       Providing fair pay at or above the London Living Wage (as published by the Living Wage Foundation)

•       Ensuring safe and healthy working conditions in compliance with the Health and Safety at Work etc. Act 1974

•       Supporting employee wellbeing through mental health resources, flexible working policies, and employee assistance programmes

•       Providing equal opportunities for learning, development, and career progression

•       Consulting with employees on matters that affect them and encouraging open dialogue

5.2 Community Engagement

As a London-based business, we take pride in our role within the local community and will:

•       Provide employees with paid volunteering time (minimum one day per year) to support local charitable causes

•       Partner with London-based charities, schools, and community organisations

•       Support skills and employment initiatives in underserved London communities

•       Engage with local small businesses and social enterprises through our procurement

•       Participate in and support local London Business Improvement Districts (BIDs) and community initiatives

5.3 Charitable Giving

•       Commit to donating a minimum of 1% of annual pre-tax profits to registered UK charities

•       Provide matched funding for employee charitable fundraising efforts

•       Prioritise support for charities operating in London and addressing issues relevant to our business

6. Ethical Governance

6.1 Anti-Corruption and Bribery

What Does Not LTD operates a strict zero-tolerance policy on bribery and corruption, in compliance with the Bribery Act 2010. We will:

•       Maintain and enforce a standalone Anti-Bribery and Corruption Policy

•       Conduct due diligence on all agents, intermediaries, and business partners

•       Provide regular training to all staff on anti-bribery obligations

•       Maintain accurate and transparent financial records

6.2 Transparency and Reporting

•       Publish an annual CSR Report detailing our performance against targets

•       Comply with Companies Act 2006 reporting requirements, including the Strategic Report obligations for relevant companies

•       Be transparent with stakeholders about our progress, achievements, and areas for improvement

6.3 Data Protection

•       Handle all personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018

•       Appoint a Data Protection Officer where required and maintain a Data Protection Policy

•       Respect the privacy rights of customers, employees, and all individuals whose data we process

6.4 Tax Responsibility

•       Pay all taxes due in accordance with UK law and HM Revenue & Customs (HMRC) requirements

•       Not engage in aggressive tax avoidance schemes contrary to the spirit of UK tax law

•       Comply with the Senior Accounting Officer (SAO) regime where applicable

7. Diversity, Equity & Inclusion

London is one of the most diverse cities in the world and we celebrate this diversity within our business. We are committed to:

•       Complying fully with the Equality Act 2010 and actively promoting equality across all nine protected characteristics

•       Building a workforce that reflects the diversity of the communities in which we operate

•       Publishing Gender Pay Gap reports in accordance with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, where applicable

•       Setting measurable diversity and inclusion targets and reporting on progress annually

•       Providing regular equality, diversity, and inclusion training to all employees

•       Maintaining a zero-tolerance approach to discrimination, harassment, and bullying

•       Creating an inclusive workplace culture through employee networks, mentoring, and ally programmes

•       Supporting supplier diversity by actively seeking suppliers from underrepresented groups

8. Supply Chain Responsibility

8.1 Ethical Procurement

We expect all suppliers and business partners to adhere to the same ethical standards we hold ourselves to. We will:

•       Maintain a Supplier Code of Conduct setting out our minimum expectations

•       Conduct due diligence on new and existing suppliers to identify and address ESG risks

•       Prioritise suppliers who share our commitment to environmental, social, and governance standards

•       Support SMEs and social enterprises through our procurement decisions

8.2 Modern Slavery

What Does Not LTD has a zero-tolerance approach to modern slavery and human trafficking. In compliance with the Modern Slavery Act 2015, we will:

•       Publish an annual Modern Slavery Statement (where required by threshold) approved by the Board

•       Conduct risk assessments across our supply chain to identify potential modern slavery risks

•       Carry out due diligence on all third-party suppliers and contractors

•       Provide training to relevant staff on identifying and reporting signs of modern slavery

•       Operate a confidential whistleblowing mechanism for reporting concerns

9. Responsible Business Conduct

9.1 Customer Responsibility

•       Treat all customers fairly and in accordance with Financial Conduct Authority (FCA) Consumer Duty principles, where applicable

•       Provide clear, accurate, and non-misleading information about our products and services

•       Maintain accessible complaint handling procedures

•       Protect vulnerable customers and ensure equitable access to our services

9.2 Digital and AI Responsibility

•  Deploy technology and AI systems in an ethical, transparent, and accountable manner

•  Comply with applicable UK AI governance frameworks and guidance from the ICO

• Ensure algorithmic systems do not discriminate against protected groups

10. Implementation and Governance

10.1 Roles and Responsibilities

Directors

Ultimate accountability for CSR strategy and performance; approval of this policy and annual CSR Report.

Senior Management

Day-to-day responsibility for implementing CSR commitments across all business functions.

CSR Lead / Manager

Coordinating CSR activity, tracking KPIs, preparing reports, and liaising with stakeholders.

All Employees

Living the values set out in this policy in their daily work and reporting any concerns.

10.2 Targets and KPIs

We will set annual CSR targets and track progress against key performance indicators including, but not limited to:

•       Carbon emissions (Scope 1, 2, and 3) year-on-year reduction

•       Waste recycling and diversion from landfill rates

•       Employee volunteering hours and community engagement activities

•       Charitable donations as a percentage of pre-tax profit

•       Workforce diversity metrics (gender, ethnicity, disability)

•       Employee engagement and wellbeing survey scores

•       Supply chain due diligence completion rates

•       Number of training hours on CSR-related topics

10.3 Reporting

The Company will publish an annual CSR Report covering performance against all targets set out in this policy. This report will be made available on the Company website and shared with key stakeholders. We will comply with all applicable mandatory UK reporting obligations, including (where applicable):

•       Streamlined Energy and Carbon Reporting (SECR) under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018

•       Task Force on Climate-related Financial Disclosures (TCFD)

•       Gender Pay Gap Reporting

•       Modern Slavery Statements

11. Policy Review

This policy will be reviewed annually by the Directors, or sooner in the event of material changes to the Company's operations, applicable legislation, or stakeholder expectations. Any amendments will be communicated to all employees and published on the Company's intranet and website.

12. Questions and Reporting Concerns

Any employee, supplier, or stakeholder who has a question about this policy or wishes to report a concern related to CSR matters should contact:

CSR Enquiries

Hey [@] whatdoesnot.com

Registered Address

What Does Not LTD, 40 Bowling Green Lane, London, England, EC1R 0NE

 Approved By

What Does Not LTD, 2026