BROWNBIRD SUSTAINABILITY POLICY
Policy Effective Date: June 1, 2023
1. PURPOSE AND SCOPE
Brownbird employs this Policy to define the fundamental principles for its commitment to the
well-being of its internal and external stakeholders, communities, and the environment. To
uphold the company’s Core Values and comply with Laws and Regulations within the
jurisdictions it operates.
This Policy applies to anyone accessing, participating in, or impacting the Program including,
but not limited to, employees, consultants, contractors, temporary employees, property
managers, owners, and vendors (“Users”).
2. INTRODUCTION
The Company is committed to being a leader in environmental sustainability
(“Sustainability”) and protecting the Earth’s natural resources through education, innovation,
and the efficient use of land, energy, water, and green products/services in all its operations.
It is committed to mitigating climate change and to meeting global policies and legislation to
reduce carbon emissions.
Environmental sustainability is one of four focus areas of the Brownbird Social Responsibility
Program (“SR”). The Brownbird SR Program focused pillars include championing diversity
and inclusion, protecting human rights, supporting our communities (philanthropy), and
leadership in sustainability.
The Company is taking reasonable steps to manage its Environmental Footprint and
develop programs to reduce energy and water consumption and increase waste diversion as
well as increase our usage of green products and services. The Company is in the process
of tracking and measuring its sustainability performance, manages risks and delivers triple
bottom line benefits by focusing on People (Community), Planet (Natural Capital) and Profit
(Economy). The Company has established baselines and in the coming 3 years will report
performance results annually to externally recognized third party reporting mechanisms.
Performance reporting will enable stakeholders to gauge social responsibility efforts (also
called Environment, Social and Governance (“ESG”)) in conjunction with financial reporting
to evaluate overall company performance. The Company also works with governments, non-
profit organizations, and academic institutions to develop solutions to climate change.
To that end, the Company is developing the Brownbird Green Program. The Brownbird
Green Program is designed to not only benefit its customers, associates, and shareholders
but also the communities in which it operates. The Brownbird Green Program focuses to
enhance the Company’s reputation, deliver positive economic and environmental benefits
and helping the Company attract and retain talent. The Program will also enable the
Company to optimize its risk management efforts and measure its results both quantitatively
and qualitatively to drive competitive advantage by achieving short- and long-term
Sustainability goals.3. POLICY
3.1 Sustainability. All Users are responsible for supporting the Company’s Sustainability
goals.
3.2 The Brownbird Green Program. Brownbird Management Committee (“BMC”) endorses
the mission, authority and structure of the Program and is committed to taking appropriate
steps to comply with Applicable Law. The BMC has charged the Philanthropy, Legal and
Compliance, and Finance departments with developing, maintaining, and communicating
Sustainability policies. The Philanthropy Department is responsible for the overall
administration and management of the Program. The Finance Department in conjunction
with the Operations Department is responsible for implementing processes and controls that
identify, respond to, and remediate issues with regards to environmental or Sustainability
issues and/or information regarding the Company’s facilities, products, services, and
supporting processes.
3.3 Brownbird Green Playbook.
• The Philanthropy Department in conjunction with the Legal & Finance Departments is
responsible for developing the Program’s strategies, processes and procedures that
support the Program’s objectives, including the implementation of the Brownbird
Green Playbook including related funding and resources.
• Operators are responsible for monitoring, tracking, and for using the Brownbird
Green Playbook and/or applicable resources as specified by the Philanthropy
Department in conjunction with the Legal Department.
• The Philanthropy Department is responsible for granting the Operators the
appropriate level of access to the Brownbird Green Playbook and its resources.
• The Philanthropy Department will coordinate with Information Technology when any
technology tools and/or technology support is required for Sustainability initiatives.
3.4 Environmental Management.
• 3.4.1 Minimize Environmental Footprint. Facility Administrators must take
reasonable and appropriate steps to minimize the Environmental Footprint of
Facilities, including purchasing and procuring environmentally responsible products
and services used in Facilities and taking steps to reduce waste to landfill. Waste
includes, but is not limited to, electronic devices, paper, glass, plastic, and metal plus
food products. When disposing of waste, Users must comply with Applicable Law,
including the Company’s policies regarding Information Security, Privacy, and
Information Management.
• 3.4.2 Environmental Incident Response. The Legal and Compliance Department
will partner with other areas of the organization as well as serve as a member of the
Executive Incident Response team to assess the potential impact to the company’s
assets and associates regarding any environmental incident. In addition, the Legal
and Compliance Department will be responsible for assisting those associates
impacted at any of our corporate, owned, or managed properties.
3.5 Reporting and Monitoring Environmental Risk.
• The Legal & Compliance Department in conjunction with the Finance Department, is
responsible for:
I. tracking, measuring, and reporting on the Company’s environmental
performance to be utilized by investors and rating agencies.
II. obtaining credible third-party verification and financial review of data and
metrics, including the Company’s Environmental Footprint; and
III. maintaining oversight of existing and new Sustainability products/services. The
Legal and Compliance Department will lead the data validation process through
independent third-party verification providers.• Appropriate tracking of Sustainability regulations and environmental controls must be
built into the Company’s business practices. Such tracking must be commensurate
with the level of risk and comply with Applicable Law.
• The Legal and Compliance Department shall monitor and track Facilities and the
Company’s related Environmental Footprint and activities to comply with Applicable
Law and/or reporting requirements that meet the WHR’s Sustainability goals. The
Operators are responsible for understanding and applying applicable
legislation/regulation at the property level.
3.6 Training and Communication.
• The Company will provide appropriate Sustainability training to Users and Facility
Administrators. It is the Facility Administrators and User’s responsibility to attend
required training sessions.
• The Philanthropy Department in conjunction with the HR Department, shall develop
ongoing communications with key stakeholders both internally and externally about
the Program, including but not limited to, ESG reporting, requests for proposals,
third- party reviews and the Company’s Sustainability performance.
3.7 Management of Third-Party Vendors.
• The Legal Department, with the assistance of the Operations Department, is
responsible for oversight of third-party vendors who supply and develop
Sustainability products and services to the Company.
4. RESPONSIBILITIES
It is the responsibility of all Users to understand and comply with this Policy. Upon discovery
of a violation or perceived violation of this Policy, the User will immediately notify the Legal
and Compliance Department as soon as possible. It is the responsibility of the Senior
Leadership of the Social Responsibility Council to review this Policy on an annual basis.
5. DEFINITIONS
• “Applicable Law” means any applicable regulation, statute, rule, industry standard,
contractual requirements, Company policies, standards (including privacy notices)
and procedures.
• “Operators” are individuals or groups of individuals designated by the Sustainability
Department with responsibility for monitoring, tracking, implementing and/or
maintaining Brownbird facilities and the Environmental Footprint of our facilities and
related activities. If an individual or group not designated by the Sustainability
Department the responsibility will be that of the Operations M
• anager, or Facilities Managers
• “Company” means Brownbird.
• “Environmental Footprint” means the measurement of natural resources or
sources (e.g., oil, coal, gas, water, plants, and wood) used by the Company through
business activities such as working, printing, traveling and meetings. These activities
are translated into common sets of measurements and then can be defined as a
footprint of a business, building, person, or activity.
• “Environmental Incident” is an environmental activity (e.g., unplanned event,
natural disaster, etc.) that impacts Facilities and requires review, intervention, and/or
remediation by the Company.
• “Environmental, Social and Corporate Governance” or “ESG” refers to the three
the central factors in measuring the Sustainability and ethical impact of an
investment in a business.
• “Facilities” means any physical location where the Company conducts business.• “People (Community)” means treating our associates and communities fairly, as
well as saving the environment and improving health with clean air and water.
• “Planet (Natural Capital)” means conserving the earth’s resources and our natural
environment by recycling, reusing, and reducing the consumption of resources.
• “Profit” means providing an economic benefit either through an increase in
revenues or a reduction of expenses.
• “Brownbird Management Committee” or “BMC” consists of Brownbird’s
Managing Director and his or her direct reports.
• “Sustainability” means meeting the needs and resources of the present generation
without compromising the ability of future generations to meet their own needs.
• “Brownbird Green Program” means the Sustainability Program for the Company.
• “Brownbird Green Playbook” means the tools and processes in place to support
the Brownbird Green Program
6. VIOLATIONS
Any violation of this Policy may result in disciplinary action, up to and including termination of
employment. This document shall not be construed to represent a contract of employment
between Company and any User or third party.
Any User who is requested to undertake an activity which he or she believes is in violation of
this Policy must report his or her concerns to his or her manager, any other manager, or the
Human Resources Department, and/or the Integrity Line as soon as possible.
7. QUESTIONS & CONCERNS
Questions and concerns may be directed to the Legal and Compliance (Mike Murindagomo)
at mike@brownbird.co.za.
8. Modifications
Modification 1.0 Date 01.06.2023 Modified by Roy Machingura Reason for modification
Initial Version