Environmental management policy

1.1. Lords LB Asset Management UAB (hereinafter referred to as the “Management Company”) understands that its activities in the management of investment funds and/or investment companies (hereinafter referred to as the “Funds”) have an impact on the environment. Environmental impact is understood as the impact generated by direct activities and the impact arising from the Funds under management.
1.2. The Environmental Management Policy (hereinafter referred to as the “Policy”) sets out general guidelines for the protection of the environment and the sustainable development and responsible use of natural resources.
1.3. Sustainable development can be defined as meeting the present needs of society without compromising the future needs of society. Sustainable development principles:
• environmental protection – the aim is to preserve ecosystems and reduce the negative impacts of human activities on nature, thereby protecting natural resources for future generations.
• economic development – ensuring economic growth and innovation for long-term prosperity while avoiding resource depletion.
• social well-being – to achieve justice, equity and better living conditions for all people by tackling social inequalities and promoting inclusion.

2. OBJECTIVES

2.1. The main objectives of the Policy are to minimise the negative direct and indirect environmental impacts of the Management Company’s activities, to promote sustainable development and to ensure a healthy and clean environment for future generations.
2.2. The Policy helps to ensure compliance with all environmental legislation and supports existing European Union initiatives such as the EU Green Deal.
2.3. In order to ensure the successful and purposeful development of the company and to ensure a stable and competitive market position, the Management Company expects, through the implementation of the Policy, to:
• strengthen relationships with investors, suppliers and partners whose approach to environmental protection and responsibility is in line with that of the Management Company;
• increase the environmental awareness of its employees, prevent pollution through safe and responsible waste management;
• use energy and natural resources rationally;
• comply with the requirements of the environmental legislation of the Republic of Lithuania and other normative documents regulating its activities;
• meet the company’s sustainability objectives.

2.4. The Management Company undertakes to continuously monitor, evaluate, document and improve the relevant environmental aspects and processes related to its activities.
2.5. The Management Company shall regularly carry out an environmental impact assessment to identify the most important aspects that interact positively or negatively with the environment. This assessment results in the formulation of environmental objectives focusing on the most important aspects.

GHG emissions
The aim is to reduce the company’s direct and indirect GHG emissions to contribute to the EU’s goal of becoming a climate-neutral economy:
• by continuously monitoring and analysing GHG emissions from direct activities and value chains;
• finding technical options to reduce GHG emissions through energy and fuel efficiency solutions;
• reducing GHG emissions in the value chain through sustainable procurement practices.
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Energy
The aim is to reduce energy consumption and switch to renewable energy:
• by continuously monitoring and analysing the energy consumption of the buildings/facilities where the company operates;
• installing efficient equipment;
• using electricity generated from renewable energy sources in its operations;
• avoiding the use of fossil fuels in all operational activities.

Waste
The aim is to reduce the amount of waste generated:
• reducing waste generation through sustainable purchasing practices and promoting responsible consumption;
• repurpose electronics, appliances and other items that are no longer in use but are still usable;
• properly sorting as much of the waste generated by the business as possible.

Natural resources
The objective is to minimise the use of natural resources by the Management Company by the purchase of goods and services:
• giving preference to suppliers who demonstrate a commitment to sustainability and reduce their environmental impact;
• prioritising, where possible, those goods and services with the lowest life cycle environmental impact;
• where appropriate, choosing products that are made from recycled materials and are recyclable;
• where appropriate, sourcing goods and services from local producers and suppliers;
• organising activities in a way that saves water.

Employee involvement
The aim is to raise awareness of the Management Company’s environmental objectives among its employees and encourage them to contribute to their implementation:
• providing periodic staff training on environmental, social ang governance (ESG) topics and presenting the results of the environmental management system;
• involving employees in the development of the objectives of the environmental management system and its continuous improvement.

Employee resilience in emergencies
The objective is to increase the resilience of the Management Company’s staff to emergencies:
• by organising periodic training of employees in simulated emergency situations.

Good Governance
The objective is to implement good governance practices that are in line with sustainability objectives:
• introducing and developing environmental and social aspects in managed funds;
• developing and implementing the Management Company’s sustainability strategy;
• regulary disclosing relevant sustainability-related information in sustainability reports to ensure transparency and accountability to stakeholders.
2.6. The Management Company undertakes to establish monitoring indicators for the achievement of the objectives.

3. COMPLIANCE WITH INTERNATIONAL STANDARDS

3.1. The Management Company undertakes to comply with the EN ISO 14001 (or equivalent) environmental management system standard and to monitor and evaluate its performance and effectiveness by collecting, analysing and discussing the achievement of the objectives set.
3.2. The compliance of the management company’s activities with the environmental management standard shall be certified by an independent certification body. The procedures for verifying and certifying compliance of the management company shall be carried out in accordance with the requirements of the standard.

4. POLICY AND DOCUMENT CONTROL

4.1. The Management Company shall follow supporting procedures to assist in the implementation of the Policy:
• control of documents and records;
• identification of potential accidents;
• accident prevention and response plan;
• assessment of environmental aspects;
• stakeholder assessment;
• Internal audit;
• setting of environmental objectives and monitoring indicators;
• management system assessment;
• risk assessment.
4.2. The Management Company shall implement the Policy in accordance with the Environmental Management System Manual.

5. RESPONSIBILITIES FOR IMPLEMENTING THE POLICY

5.1. The Chief Executive Officer of the Management Company holds responsibility for the effective implementation of the Policy. It is the responsibility of the CEO to:
• ensure that the Policy and its objectives are aligned with the Management Company’s strategic directions and are integrated into the business processes;
• ensure that the necessary resources are available for the proper implementation, functioning and development of the Policy;
• involve and motivate employees to contribute to the proper implementation of the Policy;
• ensure the achievement of the results of the Policy.
5.1. Management Representative is a member of the Company appointed by the Chief Executive Officer of the Management Company who, independently of his/her direct duties, is assigned responsibility and authority for coordinating the implementation of the requirements of the Policy within the Company. The Management Representative’s duty:
• ensure that the environmental management system and its processes are developed, implemented and maintained;
• provide information to top management on the effectiveness of the environmental management system, including recommendations for improvement.
5.2. Management Company employees are responsible for the proper implementation of this Policy. Employee responsibility:
• comply with the Policy procedures and related legislation, follow sustainable practices and report environmental risks or incidents;
• use energy, water and other resources efficiently, reduce waste, GHG emissions and handle hazardous materials responsibly;
• participate in environmental training and support continuous improvement initiatives.

6. SCOPE OF APPLICATION

6.1. The Policy applies to the Management Company operating at Jogailos g. 4, LT-01116, Vilnius, and the infrastructure owned or administered by it.
6.2. The term “Infrastructure” includes the company’s buildings (premises), workplaces, work equipment and related utilities, technical equipment, transport, software, communications.

7. FINAL PROVISIONS

7.1. This Policy is made public.
7.2. This Policy shall enter into force on the date of its approval and may only be repealed, amended and/or supplemented by decision of the Board. Amendments and/or additions to the Policy shall take effect from the date of approval of the updated Policy, unless another effective date is specified in the amendments and/or additions. The CEO of the Management Company shall ensure that the persons referred to in part 8 of the Policy are made aware of this Policy and are informed of amendments and/or additions to the Policy in a timely manner.
7.3. The CEO of the Management Company shall be responsible for the implementation of, monitoring compliance with and maintaining effectiveness of this Policy.
7.4. In the event of any discrepancy between the translation into English and the Lithuanian version, the Lithuanian version shall prevail.