Environmental, Social and Governance Policy

The purpose of this policy is to state plainly how Lead Conneqt Limited manages its environmental, social and governance responsibilities, and to give clients, prospective clients and suppliers an honest account of what those responsibilities look like for a business of our size and type.

We provide a managed outsourced sales development function. We do not manufacture, we do not operate a vehicle fleet, and we do not hold a significant physical footprint. Our environmental impact is therefore limited and arises mainly from electricity use, the IT equipment we buy and use, and travel. Rather than publish targets or measures we are not in a position to substantiate, we focus on practical reductions we can actually make, and on the social and governance matters where a service business has the most influence: how we treat people, how we handle data, and how we behave commercially.

This policy is a statement of our own commitments. It does not create contractual obligations in itself, and it does not claim any certification, accreditation or independent assessment.

This policy applies across the whole of our business and to everyone working for or on behalf of Lead Conneqt Limited.

• Directors and anyone employed or engaged by Lead Conneqt Limited, including contractors, temporary workers and agency workers
• All of the services we deliver for clients, including ICP development, prospect research, data preparation, cold email, LinkedIn outreach, telemarketing, reply handling, qualification and appointment setting
• Our own purchasing decisions, including software, IT equipment and the suppliers and subcontractors we appoint
• Travel undertaken for business purposes, whether to client sites, events or meetings

Suppliers and subcontractors are not bound by our internal policies, but we expect them to work to standards consistent with those set out here, and we take their approach into account when we decide who to work with.

We commit to the following across the three areas covered by this policy. The detail behind each area is set out in the sections that follow.

• To reduce unnecessary consumption of resources in the way we work, and to be honest about the limited scale of our environmental impact rather than overstate it
• To treat people fairly and with respect, whether they are colleagues, clients, suppliers, workers in our supply chain, or the people we contact on behalf of clients
• To conduct our business lawfully, ethically and transparently, and to decline work or relationships that would require us to do otherwise
• To protect the personal data we handle and to use it only for the purposes for which it was obtained
• To describe our capabilities, our results and our credentials accurately, and never to claim a standard, certification or outcome we cannot evidence
• To keep this policy proportionate, current and capable of being applied in practice rather than aspirational

Our environmental impact is limited. It arises mainly from electricity used in the course of our work, the IT equipment we purchase and operate, and travel. We do not publish emissions figures, reduction percentages or dated targets, because we do not hold measurement of a quality that would make such claims meaningful. What follows are the practical steps we take.

• Reducing unnecessary consumption of energy, materials and consumables in the course of our day to day work
• Working digital first, with paperless workflows by default: proposals, contracts, reporting and internal records are created, shared and stored electronically, and printing is the exception rather than the norm
• Reducing unnecessary travel where a video call, telephone call or written update achieves the same outcome, while recognising that some client relationships genuinely benefit from meeting in person
• Extending the working life of IT equipment through maintenance, repair and reuse rather than routine replacement, and disposing of equipment responsibly at end of life, including secure removal of data and the use of recycling or reuse routes rather than general waste
• Considering environmental credentials alongside price, quality and reliability when we select suppliers, and giving preference where practical to suppliers who can demonstrate a credible approach of their own
• Complying with applicable environmental legislation relevant to a business of our size and activities

We make no claim to be carbon neutral, to have offset our emissions, or to be working to a net zero date. If our activities change in a way that makes our environmental impact more significant, we will revisit this section and set out what we are doing about it.

The social element of this policy covers how we treat people: those who work with us, those who buy from us, those who supply us, and the people we contact on our clients' behalf.

• Fair and respectful working practices, including clear terms of engagement, agreed pay and hours, and a working environment free from bullying, harassment and intimidation
• Equality of opportunity and non-discrimination in recruitment, engagement, pay, development and day to day treatment, without regard to age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation
• Responsible treatment of clients, prospects, suppliers and workers, including paying suppliers in line with agreed terms and dealing with complaints and disputes promptly and in good faith
• Respect for the time and attention of the people we contact on behalf of clients: we contact people in a business context for a genuine business reason, we identify ourselves and the client we represent, we keep contact relevant and proportionate, and we act promptly on requests to stop
• Screening of telephone data against the Telephone Preference Service and the Corporate Telephone Preference Service, and the maintenance of a Do Not Contact list that is applied across our outreach
• Support for people to raise concerns about conduct or working practices without fear of consequence, as described under reporting and escalation below

We do not tolerate modern slavery, human trafficking, forced labour or child labour in our business or in our supply chain. Our commitments in this area, and what we expect from our suppliers, are set out in full in our Modern Slavery and Human Trafficking Policy.

Personal data is central to the work we do, and handling it properly is a social responsibility as much as a legal one. Our outreach runs on a legitimate interest basis for business to business contact under the UK GDPR and the Data Protection Act 2018. How we collect, use, share and retain personal data, and the rights available to individuals, are set out in our Privacy Policy.

Governance for a company of our size means clear ownership of decisions, honest dealing, and a refusal to cut corners for commercial advantage.

• Ethical conduct in all commercial dealings, including honest representation of our services, our pricing and our results, and no misleading, exaggerated or unverifiable claims in sales or marketing
• Zero tolerance of bribery and corruption: we do not offer, give, request or accept bribes, kickbacks or improper payments, and we do not use facilitation payments, in the United Kingdom or anywhere else
• Care with gifts and hospitality, which must be modest, transparent and never given or accepted where they could reasonably be seen to influence a business decision
• Compliance with data protection law in how we obtain, use, secure, share and dispose of personal data, and control over who within the business has access to client and prospect data
• Responsible decision making, with significant commercial, legal and ethical decisions taken or approved by the Managing Director, and with the willingness to decline or end work that conflicts with this policy
• Standards expected of suppliers and subcontractors, including lawful conduct, fair treatment of their own workers, proper handling of any data we entrust to them, and an approach to bribery, modern slavery and data protection consistent with our own
• Identification and management of conflicts of interest, which must be declared as soon as they are recognised
• Compliance with applicable law and regulation relevant to our activities, including company law, employment law, data protection law and the rules governing direct marketing

Responsibility for this policy is held at director level and applied by everyone who works for or on behalf of the business.

• The Managing Director owns this policy, approves it, and is accountable for the commitments in it. The Managing Director also decides on any matter escalated under this policy
• Anyone employed or engaged by Lead Conneqt Limited is responsible for reading this policy, working in line with it, and raising anything that appears inconsistent with it
• Anyone who selects or manages a supplier is responsible for taking the expectations set out here into account when appointing that supplier and when reviewing the relationship
• Anyone delivering outreach on behalf of a client is responsible for applying our standards on data protection, suppression, screening and respectful contact on every campaign
• Suppliers and subcontractors are expected to meet standards consistent with this policy and to tell us promptly if they cannot

If you have a concern about anything covered by this policy, including environmental practice, the treatment of people, conduct in our supply chain, bribery, or the handling of data, raise it as soon as you can. Concerns can be raised with the Managing Director, or in writing to dane@leadconneqt.com. This route is open to our own people, to clients, to suppliers and to members of the public.

Concerns are taken seriously. They are handled confidentially so far as is reasonably possible, and information is shared only with those who need it in order to look into the matter or where we are required to share it by law. Where a concern is urgent or indicates a risk to a person's safety, it should be raised immediately and, where appropriate, reported to the police or another relevant authority.

Nobody who raises a concern in good faith will suffer detriment or retaliation as a result, including where the concern turns out to be mistaken. Any attempt to penalise, exclude or otherwise disadvantage somebody for raising a concern in good faith is itself a breach of this policy.

A breach of this policy is treated seriously. Where we identify or are told about a failure to meet the standards set out here, we will look into it, decide what needs to change, and act.

• For our own people, a breach may result in action under our disciplinary arrangements, up to and including dismissal, and any conduct that is unlawful may be reported to the relevant authority
• For suppliers and subcontractors, a breach may result in a requirement to put the matter right within an agreed period, suspension of work, or termination of the relationship where the breach is serious or is not remedied
• Where a breach involves personal data, it will also be handled under our data protection arrangements, including any notification required by law
• Where a breach reveals a weakness in the way we work, we will change the practice as well as address the individual matter

This policy is owned by the Managing Director and is reviewed at least annually, or sooner where there is a material change to the business, its services, its supply chain or the law. The document identity block at the top of this page records the current effective date, the date of last review and the date of next review.