ESG Practices

At Freeman Holdings Limited (“FH”, “the Company”), ESG principles are deeply embedded in our investment philosophy and corporate culture, serving as a strategic lens through which we assess opportunities, manage risk, and drive long-term value. We prioritize investments that demonstrate sustainable growth, ethical operations, and responsible resource stewardship. This integrated approach informs our investment decisions, risk management, and governance practices – enabling us to align capital with purpose, support value creation, and fulfill our broader responsibility to stakeholders and society.

Responsible Investment

Freeman Holdings Limited recognises the importance of environmental, social, and governance considerations in preserving long-term value and managing risk across its portfolio. While the Company is a private investment holding vehicle and does not offer investment services to third parties, it holds itself to high standards in how it evaluates opportunities, manages assets, and conducts its affairs across all jurisdictions in which it operates.

Commitment to responsible and sustainable management of group assets
Integration of ESG principles into investment and governance decisions
Transparency and accountability across all group entities and jurisdictions
Adherence to international standards of ethical corporate conduct

Investment Approach

ESG factors are considered as part of the Company's broader assessment of risk and opportunity when evaluating potential investments. This includes consideration of environmental impact, regulatory and reputational risk, governance quality, and the sustainability of the assets in which the group invests. The Company seeks to allocate capital to assets and structures that are resilient, well-governed, and aligned with its long-term strategic objectives.

Long-term value preservation through disciplined capital allocation
Assessment of environmental and social impact in investment decisions
Preference for assets with sound governance and regulatory standing
Alignment of all investment activity with the group's strategic objectives

Risk and Compliance

The Board of Directors maintains oversight of risk across the group, with ESG-related risks integrated into the Company's broader risk management framework. This includes monitoring of regulatory developments, sanctions exposure, and reputational risk across all jurisdictions in which the group operates. The Company takes a proactive approach to identifying and mitigating risks that could affect the its long-term value, integrity, and reputation
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Integrated assessment of regulatory, reputational, and ESG-related risks
Ongoing monitoring of sanctions and anti-money laundering obligations
Proactive identification of emerging risks across operating jurisdictions
Regular review of risk controls and mitigation measures by the Board

Governance and Conduct

The Company is committed to conducting its business with integrity and in full compliance with applicable laws and regulations in all jurisdictions in which it operates. This includes adherence to anti-money laundering requirements, sanctions compliance, tax transparency obligations, and the maintenance of accurate corporate and financial records. The Board of Directors maintains direct oversight of these standards across the group, including its subsidiary in Italy.

Compliance with AML, CRS, FATCA, and applicable sanctions regimes
Maintenance of accurate corporate and financial records across the group
Tax transparency and adherence to applicable transfer-pricing requirements
Board-level oversight of conduct and compliance standards group-wide