Safeguarding Policy

Pain Pals GY CIC.

1.           Preliminary

1.1        The Charity Commission has stated that safeguarding should be a key governance priority for all charities, regardless of size, type, or income, not just those charities working with children or vulnerable adults. It has also stated that it is essential for charity trustees to have and implement safeguarding policies and procedures and that they have to be adequate and appropriate for the charity’s particular circumstances.

1.2        This Policy applies to all staff and volunteers of the CIC. In this Policy, “volunteers” means and includes the CIC directors, members and all other volunteers.

2.               Commitment to safeguarding

2.1    Those who receive services or participate in the activities provided by Pain Pals GY or are beneficiaries of the CIC or who come onto Pain Pals GY premises are referred to in this Policy as its service users and beneficiaries.  

2.2    Service users and Beneficiaries may be at risk due to age, illness or disability. The CIC is committed to working in their interests, to promote their welfare, and to put in place safeguards and measures to protect them. In providing services, activities and benefits for service users and beneficiaries, the CIC will endeavour at all times to minimise risk to them and to ensure that they are as safe as the CIC can make them.

2.3    The CIC aims to protect all of its service users and Beneficiaries from any act or behaviour of any member of staff or volunteer which, whether deliberately or unknowingly on the part of that member of staff or volunteer, gives rise to harm or ill treatment.

2.4    Such harm or ill treatment includes abuse (physical, sexual, emotional, discriminatory, institutional or organisational, financial or material), neglect, or impairment of the health or development of the CIC service users and Beneficiaries.

2.5    The CIC also aims to ensure the provision to them of safe and effective care  and to promote the well-being and welfare of its service users and Beneficiaries.

2.6    The CIC recognises that it has a duty to act on reports or suspicions of abuse or neglect. It adopts a “zero-tolerance” policy of abuse within the CIC.

2.7    The CIC maintains a Safe Working Practice Guidance. It includes:

(a)   Staff training in safeguarding

(b)   Safeguarding risk assessments

(c)   Recording and Reporting

The CIC will ensure that the Guidance is implemented by all within the CIC and, for that purpose, it will ensure that its staff and volunteers have read and understood it.

2.8    The CIC will work in partnership with local / national agencies to put in place appropriate procedures for reporting, making referrals, and accessing training and specialist support, as and when required.

3.               Safe recruitment

3.1    To aim to protect its Service users and Beneficiaries, the CIC will seek to recruit staff and volunteers using appropriate procedures, safeguards and checks.

3.2    The CIC will take up to two references for all staff posts and volunteer roles prior to appointment.

3.3    The CIC will provide an induction programme for all new volunteers and staff, and appropriate training and ongoing/refresher training for them at regular intervals, to enable all volunteers and staff to undertake their roles safely, effectively and confidently. The induction will make it clear to them that they have an obligation to implement this Policy and to learn about protection issues and their related responsibilities.

3.4    Where the CIC should do so, it will use the Disclosure & Barring Service (“DBS”) checks to help it to assess suitability of a candidate for a particular volunteer or staff role which is treated by the DBS as Regulated Activity and is therefore subject to a barring list check. In relation to a post or role which is eligible for an enhanced DBS check, where it considers it appropriate it will carry out an enhanced DBS check. The CIC will assess any criminal record information that is disclosed in line with its data protection and equalities recruitment of ex-offender’s policies.

3.5    The CIC will regularly review its recruitment and other human resources procedures in response to changes in legislation and systems external to the CIC, e.g. DBS and barring list checks.

4.               Volunteers

4.1    All volunteer roles will be supported by a Volunteer Co-ordinator /Supporter.

4.2    Volunteers will be treated equally alongside paid staff, and all volunteers will be offered the same opportunities for advancement, responsibility, training and gaining qualifications, and acknowledgement for their contribution to the CIC.

4.3    In turn, volunteers will be required to adhere to the applicable parts of the Code of Conduct (Staff and Volunteers) at all times as a representative of the CIC. Before they take up their role, they will each be given a clear description of the requirements and responsibilities of their role and the member of staff or trustee recruiting them will discuss their role with them, to ensure that they understand what is expected of them.

4.4    Any volunteer roles, which would be Regulated Activity if unsupervised, will be appropriately supervised in accordance with statutory guidance.

5.               Safeguarding Officer

5.1    The CIC appointed Safeguarding Officers as from 28/08/2026 are

Lead safeguarding officer: Helen Hartley

Deputy Safeguarding officer: Colin Begley 

Safeguarding Officer. They will have access to appropriate training to support them in these roles.

5.2    They will be available to all staff, volunteers and services users and Beneficiaries to speak to when they have any concerns, issues, or complaints regarding the safety, well-being or conduct of service users Beneficiaries, volunteers or staff.

5.3    The Safeguarding Officers and Deputy Safeguarding Officer will liaise with appropriate local and national agencies, contribute to appropriate policies, maintain records, keep confidentiality, adhere to and promote this Policy within the CIC, and support or provide access to support for individuals suffering harm or abuse.

6.               Awareness of harm and abuse within the Charity

6.1    All incidents of harm to any Service user or Beneficiary will require an appropriate response to reduce risks and improve the CICs services and activities.

6.2    Harm is caused by accidents, deliberate abuse (physical, psychological, sexual, emotional, financial), neglect (deliberate or not) or factors such as bullying, prejudicial attitudes, or a failure to enable a person to participate in activities that are open to most of their peers. It can also include abuse via use of ICT facilities (e.g. grooming, bullying via the internet).

6.3    Deliberate acts of harm (physical, psychological, sexual, emotional and financial) and neglect are abuses against the person. Those acts will incur disciplinary proceedings and require reports and referrals to social services, the police, other professional bodies, and the DBS if the act is by someone in Regulated Activity. If a criminal offence is thought to have been committed by any staff member or volunteer, the police will be informed. 

7.               Confidentiality

All reports and logs (including personnel records) will be kept securely and confidentially according to the CICs Data Protection Policy and Confidentiality Policy or in line with the DBS Code of Practice for Registered Bodies if appropriate, until or unless it is necessary to share this material with the agencies named above. Information will be shared by the CIC on a “need-to-know” basis only.

8.               Reports of possible or actual harm

8.1    The CIC supports and encourages all Service users, Beneficiaries, volunteers and staff to promptly speak up and contact the Safeguarding Officer or Deputy Safeguarding Officer where there is a concern (i.e. a worry, issue or doubt about practice or about treatment of a Service user, Beneficiary or colleague, or their circumstances), or a disclosure (i.e. information about a person at risk of or suffering from Significant Harm) or an allegation of an incident or a possibility that a volunteer or staff member has caused harm or could cause harm to a person in their care.

8.2    Staff or volunteers can report, and have a responsibility to report, something that they become aware of if they suspect or discover that it is not right or is illegal or if it appears to them that someone at work is neglecting their duties, putting someone’s health and safety in danger or covering up wrongdoing. They may become aware of any of these things from what they see or hear or from something another person has disclosed to them.

8.3    In the first instance the staff or volunteer making a report should speak to their line manager who will then liaise with the Safeguarding Officer, Deputy Safeguarding Officer or the CIC member with appropriate responsibility. However, if the report implicates their line manager, the staff member or volunteer making the report should instead speak directly to Safeguarding Officer or Deputy Safeguarding Officer.

8.4    The CIC prefers that anyone should use internal processes whenever possible to make a report as above, but this does not prevent them from making a report or referral, in their own right as a private individual, to statutory agencies such as social services or the police.

8.5    The CIC cannot promise confidentiality to staff or volunteers making an internal report (to the Safeguarding Officer, Deputy Safeguarding Officer, the CICs members with appropriate responsibility or their line manager) where it is has to be shared with any statutory agencies.

8.6    The CIC also supports its staff or volunteers to raise concerns or to disclose information, which they believe shows malpractice - whistle-blowing (disclosure in the public interest).

9.               Safeguarding Officer’s action 

Where there is risk of Significant Harm to any Service user Beneficiary, volunteers or staff, the Safeguarding Officer and Deputy Safeguarding Officer have the power to act as necessary and, in particular, as follows:

-  log all conversations regarding the issue

-  sign and request signatures on reports and statements

-  confidentially seek advice from expert sources

-  share concerns (with consent where required and appropriate) internally with senior staff / Chair of the Board of trustees

-  share concerns and make referrals to external agencies such as social services or the police, as appropriate to the circumstances

-  make a referral to the DBS regarding staff or volunteers in Regulated Activity whose conduct is harmful to Service users, Beneficiaries and refer them to DBS when they are removed from Regulated Activity.

10.            Communication by the CIC about safeguarding and this Policy

10.1    All staff and volunteers have an obligation to learn about protection issues and their related responsibilities.

10.2    The CIC will communicate this Policy (using appropriate methods, formats and language to communicate the substance of it) to all of its staff, volunteers, and Service users, Beneficiaries and their families / carers, and it will also make it available to the public. Karen Lovejoy the CICs Secretary will be responsible to the Board members for communicating this Policy to them.

10.3    To encourage everyone involved in the CIC to understand that safeguarding is the business of everyone, and to assist all staff and volunteers to learn about protection issues and their related responsibilities, the CIC will hold meetings open to all staff and volunteers about safeguarding presentations to staff and volunteers about safeguarding policy and procedures][place safeguarding on the agenda for meetings of the Board of members and provide other opportunities for discussion about issues and concerns, policy and procedures to reflect, review and to continue to learn and improve in relation to the CICs safeguarding responsibilities.

11.            Implementation of this Policy

11.1    This Policy must be followed by all staff and volunteers of the CIC and must be promoted by all of its members and senior staff. Failure to follow it will be treated as a very serious matter.

11.2    This Policy needs to be read in conjunction with the following policies and procedures of the CIC:

Safe Working Practice Guidance

Health & Safety Policy

Lone working Policy

Code of Conduct (Staff and Volunteers)

Data Protection Policy

Confidentiality Policy

Equal Rights and Diversity Policy

Complaints Policy

Whistle Blowing Policy

12.            Adoption, coming into effect, and review, of this Policy

12.1    This Safeguarding Policy was approved by the Board of members for Pain Pals GY 03/09/2025 It also comes into force on that date.

12.2    The Board will, as appropriate, monitor and enforce this Policy,

12.3    The Board will revise this Policy from time to time. The next date for review of this Policy is 03/09/28

This policy will be reviewed annually or when there is a change in circumstances, in work practices or the introduction of new legislation.

This policy has been approved & authorised by:

Name: Helen Hartley

Position: Founder/Director

 Date:     03/09/25

 Review   03/09/28

Pain Pals GY

Health and Safety

Arrangements and Procedures

1. Supervision

2. Risk Assessments

3. Workplace & Site Safety, and Welfare

4. Control of Substances Hazardous to Health

5. Asbestos

6. Manual Handling

7. First Aid

8. Accident Reporting

9. Electricity

10. Noise

11. Vibration

12. Working at Height

13. General Work Equipment

14. Fire

15. Computer Screens

16. Personal Protective Equipment

          ARRANGEMENTS AND PROCEDURES

1.               Training and Supervision

It will be the policy of Pain Pals GY (“the Business”) that health and safety information relevant to the activities at hand is given to all staff members and sub-contractors.

Ongoing training will be provided to ensure that employees at all levels are:

·        competent to carry out their duties, to operate specialist tools, plant and work equipment; and

·        aware of their health and safety responsibilities.

Decisions relating to ongoing training of staff members will be reviewed on a regular basis. The person with day to day responsibility for Health and Safety will be responsible for identifying and implementing health and safety training needs.  Records of the training will be kept on each staff members individual file.

Checks will be made to ensure that sub-contractors are competent to carry out the tasks allocated to them and that they have health and safety management systems in place appropriate to their work.

2.               Risk Assessments

(Reg. 3 Management of Health and Safety at Work Regulations, 1999)

The Management Team will ensure that all hazardous work activities undergo a suitable and sufficient Risk Assessment.  Upon the establishment of the level of risk, preventative measures will be introduced, maintained and revised as needed.

3.               Workplace Safety and Welfare

(The Workplace (Health, Safety and Welfare) Regulations 1992; Construction (Design & Management) Regulations 2015)

The management will ensure that all workplaces meets the health, safety and welfare needs of all those who will use them, including contractors, and wherever appropriate, people with disabilities. Where works are to take place where members of the public have access, measures will be taken to ensure that they are not adversely affected.  

4.               Control of Substances Hazardous to Health

(COSHH 2002)

Where needed, Risk Assessments and all Material Safety Data Sheets of substances used will be kept at the Business’ office.  From the Risk Assessments the Management will instigate the principles of good practice for the control of exposure as detailed in Schedule 2A Regulation 7(7).   No staff member will introduce any substance without the specific consent of their Line manager.

5.               Asbestos

(Control of Asbestos at Work Regulations 2012)

In the event that any substance suspected to be, or containing, asbestos is found during the course of the Business’ works, all works in the area will cease immediately to avoid any exposure.  Work will be suspended in that area until the substance has been identified and if appropriate made safe/removed by specialist contractors. No works will be carried out that may disturb suspect substances without a suitable Asbestos Survey having been done by a specialist contractor. 

6.               Manual Handling

(Manual Handling Operations Regulations, 1992)

The designated H&S person will assess all manual handling operations within the workplace, and where possible change the nature of any task or provide mechanical aids in order to reduce or lighten the manual handling of loads.  They will ensure that adequate Risk Assessments are carried out to identify hazards associated with manual handling and ensure that where needed, lifting aids are provided. 

7.               First Aid

(Health and Safety (First Aid) Regulations, 1981)

The designated H&S person shall ensure that all staff members have access to adequate First Aid provision at all times. The level of cover shall be determined by risk assessment.

(See First Aid Policy)

8.               Accident Reporting

(Reporting of Injuries, Diseases, Dangerous Occurrences Regulations 2013)

All accidents and incidents will be recorded in an accident book and personal details kept secure to comply with Data Protection legislation. Any reportable accidents, incidents, or dangerous occurrences will be reported to the HSE.

9.               Electricity

(Electricity at Work Regulations, 1989)

It is the policy of the Business that wherever possible, all hand tools will be battery powered or 110v.  Where this is not possible a Residual Current Device (RCD) will be used.

10.            Noise

(Control of Noise at Work Regulations, 2006)

The person in charge of a working area/site will ensure that noisy works do not cause a nuisance to others in the vicinity of their works area. They will always ensure that suitable ear protection is freely available to anyone who needs it.

11.            Vibration

(Control of Vibration at Work Regulations 2005)

The designated H&S person will ensure that where the use of vibration causing hand tools cannot be reduced, suitable safeguarding procedures are brought in, including where appropriate, anti-vibration gloves. 

12.            Working at Heights

(Work at Heights Regulations 2005)

Where the business activities involve ‘work at height’ the designated H&S person will assess the task beforehand and will consider the most suitable means of access. Suitable control measures such as exclusion zones will be put in place to ensure the safety of any others who will be in the vicinity.

13.            General Work Equipment

(The Provision and Use of Work Equipment Regulations (PUWER) 1998) (Lifting Operations and Lifting Equipment Regulations (LOLER) 1998)

It will be the designated H&S person’s responsibility to ensure:

·        Suitable equipment is supplied for the tasks to be done (Reg. 4)

·        That the equipment will be maintained in an efficient state, in efficient working order and in good repair (Reg. 5)

·        That all equipment and plant shall be inspected as required by Regulation 6

·        That those tasked with using the equipment are competent to use it. (Regs. 8 & 9)

14.            Fire

(The Regulatory Reform (Fire Safety) Order 2005)

It will be the responsibility of the designated H&S person to ensure adequate fire extinguishers are available at all work locations. All fire extinguishers are to be checked annually by a specialist contractor.

15.            Computer screens

(The Health and Safety (Display Screen Equipment) Regulations, 1992)

The designated H&S person will ensure suitable assessments are carried out for all persons who use display screen equipment. The assessments will consider the amount of time a person uses a VDU and the work done, the usability of their workstation and general working environment.

16.            Personal Protective Equipment (PPE) 

(The Personal Protective Equipment at Work Regulations (PPE) 1992)

The designated H&S person will ensure that all individuals have access to a sufficient supply of PPE when required.

These arrangements and procedures will be reviewed annually or when there is a change in circumstances, in work practices or the introduction of new legislation.

Name: Helen Hartley

Position: Founder/Director

Date: 07/2025

Review Date: 07/2026 completed

07/2027

Pain Pals GY

Environmental, Social and Governance Strategy

07/2024

1.               What are Environmental, Social & Governance (ESG) Issues?

Growing concerns about social and environmental issues in society as well as more attention being given to corporate governance issues and increasing legal obligations on companies, has led to greater interest in how companies are governed, overseen and should operate to ensure that they carry on their business and behave in a responsible way. Specifically, companies are increasingly expected to consider purpose as well as profit, and the future of our planet and its peoples. All these various issues are collectively referred to as ESG.

Each ESG issue is usually placed under one of the following headings: environmental, social and governance issues. Each issue is a discrete area but increasingly they are collectively grouped together and considered under the title, ESG.

ESG issues include, amongst other things, climate change and greenhouse gas emissions; energy efficiency and resource depletion; emissions to air, water and land pollution and waste; health and safety considerations; diversity, inclusion and equal pay; stakeholder and community engagement; bribery and corruption; conflicts of interest and anti-money laundering.

ESG will however mean different things to different companies depending on their size and the sector they operate in.

2.               Why have an ESG strategy?

ESG issues have recently assumed greater prominence and importance by regulators, employees, customers and other stakeholders. Currently SMEs are outside the scope of any specific ESG related disclosures in the UK[1], however failure to tackle ESG issues that are relevant to SME companies may lead to, amongst other things, regulatory enforcement as well as posing a litigation, physical, commercial, financial and reputational risk to a company, that might adversely affect its sustainability. In addition, there is a growing trend for ESG requirements and compliance by a company to be a pre-requisite for it to contract with other parties.

Considering this, and to minimise any potential risks, SMEs may wish to put in place an ESG strategy, commensurate with its size and sector focus, setting out the type of organisation that it aspires to be.

3.               What should an ESG strategy cover?

For most SMEs, an ESG strategy will involve putting in place a framework of various policies and practices to cover amongst other things:

·        Staff/people;

·        customers;

·        suppliers;

·        health & safety;

·        environment; and the community

How ESG affects each of these different areas and how each is dealt with by a business will depend on the importance that the business attributes to each one.

This ESG strategy is, by its very nature, generic, but highlights the key areas that businesses should focus on when determining their ESG strategy.[2]

ESG Strategy:

1)     Introduction

We are, Pain Pals GY

The Company aims to implement the highest environmental, social and governance (ESG) standards appropriate to its size and sector. The prosperity of the Company and of the communities within which it operates requires a commitment by it to the sustainable management of its activities.

Rapidly developing legal and voluntary frameworks, stakeholder demands and increasing environmental concerns, all mean that ESG is fast becoming a top priority for businesses. To keep pace with this change, the Company wishes to:

• keep abreast of the most up to date information available to it;

• understand the risks and opportunities ESG presents; and

• take action to ensure that the Company continues to satisfy stakeholders and places itself in the best position for long term, sustainable development.

It is recognised that a failure to tackle ESG issues that are relevant to the Company may lead to, amongst other things, regulatory enforcement as well as to pose a litigation, physical, commercial, financial and reputational risk to the Company that may adversely affect its sustainability and resilience.

The directors of the Company already have a duty under Section 172 of the Companies Act 2006, to promote its success. This means that each of its directors must act in the way they consider, in good faith, would promote the success of the Company for the benefit of its members as a whole.

However, in addition, the directors have decided to develop a robust and transparent ESG strategy that goes further than this Companies Act duty and affects and enhances all areas of the Company’s business in line with ESG issues, namely Community projects, events, support of service users and the local community at large.

The Company wishes to adopt this strategy as a framework for how the directors will manage ESG issues relevant to the Company’s business.

2) ESG Audit

The Company is a SME and operates in the Volunteer Community interest companies sector.

In the first instance, it will carry out a comprehensive ESG audit and material risk assessment across its business to establish:

• what ESG means for the Company;

• which stakeholders should be consulted; and

• an ESG baseline.

Materiality

The Company considers the following to be material to it:

Environmental Commitments

·  Energy use and efficiency — Track annual energy bills, choose renewable tariffs where possible, reduce unnecessary usage, and ensure any shared premises follow good practice.

·  Travel impact — Encourage low‑carbon travel for staff and volunteers (public transport, car‑sharing, remote meetings). Record travel patterns annually.

·  Sustainable procurement — Prioritise suppliers with ethical or environmental credentials for printing, catering, IT, and training materials.

·  Digital sustainability — Reduce unnecessary cloud storage, choose efficient hosting, and avoid energy‑intensive digital practices.

·  Waste reduction — Minimise printing, recycle materials, and avoid single‑use items at events.

·  Community environmental stewardship — Demonstrate care for the local area (Great Yarmouth) through litter‑free events, accessible venues, and responsible use of public spaces

Social Commitments

·  Accessibility and inclusion — Ensure all services, training, and events are accessible to disabled people, neurodivergent people, and those on low incomes.

·  Affordability and equity — Commit to keeping resources low‑cost or free for people on benefits or outside NHS pathways.

·  Volunteer wellbeing and fair treatment — Clear expectations, safe working conditions, training, and support for unpaid volunteers.

·  Safeguarding — Strong safeguarding policies for vulnerable adults, with transparent reporting routes.

·  Community impact — Show how your activities improve wellbeing, reduce isolation, and support people who fall through gaps in statutory care.

·  Data ethics — Responsible handling of sensitive health‑related information, privacy protection, and transparent consent practices.

Governance Commitments

·  Leadership responsibility — Name who oversees ESG (e.g., founder or a designated trustee).

·  Decision‑making with ESG in mind — Show how environmental and social impacts are considered when planning services, hiring, procurement, or partnerships.

·  Ethical conduct — Anti‑discrimination, anti‑harassment, and conflict‑of‑interest statements.

·  Transparency — Annual reporting on what you’ve done, what you plan to improve, and what is realistically outside your capacity.

·  Continuous improvement — Commit to reviewing ESG priorities annually based on capacity, funding, and community needs.

Additional ESG Elements Especially Relevant to Pain Pals GY

·  Commitment to lived‑experience leadership — Recognise the value of people with chronic pain, disability, or trauma shaping your services.

·  Protection of intellectual property — State that Pain Pals GY materials cannot be reproduced or altered without permission (aligns with your existing stance).

·  Low‑cost community support — Explicitly embed affordability and accessibility as part of your social governance.

·  Trauma‑informed practice — Ensure all volunteers and staff follow trauma‑aware communication and support principles.

·  Local partnership ethics — Work only with partners who respect inclusion, accessibility, and community wellbeing

Members

The Company will consult with:

Its members, employee, service users and local community

Baseline

It is important to identify an ESG baseline. The Company shall identify existing policies, processes and practices it already has in place that consider matters closely aligned with ESG.

The following policies, processes and practices are considered relevant:

Environmental policy

Health and safety

Waste management policy

Local impact studies

Quality assurance policy

These policies will be assessed for their usefulness in relation to ongoing ESG related activity and may also be useful to establish which ESG areas the Company should prioritise and which stakeholders it should consult.

3) ESG objectives and framework

Having caried out a thorough ESG audit as set out above, the Company will identify its priority areas and set out its ESG objectives. It will implement an ESG framework based on these priorities through new policies, processes and practices relevant to the Company’s size and sector.

4) New ESG Policies etc

The new policies, processes and practices the Company will implement will include:

An ESG policy which incorporates the Company’s priority ESG areas and ESG objectives.

5) Board Terms of Reference & ESG Committee

The Company aims for its board of directors to achieve the highest board standards. It already has robust and transparent legal and professional standards in place but also aims to incorporate relevant ESG considerations into the board’s terms of reference. This will include ESG matters becoming a routine consideration in the board’s decision-making process going forward and the Company putting in place a committee to specifically consider ESG matters and advise the board accordingly.

6) Updating Existing Policies

The Company has implemented several policies appropriate to its business that consider [staff/people, customers, suppliers, health & safety, the environment and the community]. To bring these policies in line with the Company’s ESG strategy and ESG requirements [and its proposed new ESG policy document], it will update

Environmental policy

Health and safety

Waste management policy

Local impact studies

Quality assurance policy

7) Measuring and Reporting

The directors will regularly review, measure and report to members at suitable intervals on the Company’s progress in implementing its ESG strategy.

These arrangements and procedures will be reviewed annually or when there is a change in circumstances, in work practices or the introduction of new legislation.

Name: Helen Hartley

Position: Founder/Director

Date: 07/2025

Review Date: 07/2026 completed

07/2027

.

[1] As a SME, the company will not be subject to The Companies (Strategic Report) (Climate-related Financial Disclosure) Regulations 2022 (SI 2022/31) & the Limited Liability Partnerships (Climate-related Financial Disclosures) Regulations 2022 (SI 2022/46).

[2] If the business or industry has specific practices, policies and procedures that it should/must adhere to, these should be referenced and worked into the ESG strategy where relevant.