1. Preamble

1.1. This policy (hereinafter referred to as the “Policy") shall be called "ESG Policy " of IBS Bulgaria Ltd (hereinafter referred to as “IBS”, the "Company" or "We").

1.2. IBS is an open, committed and passionate team of professionals, providing Data Management, Systems Integration and Software Development services. We work with Banks, Fintech, Government, Medium and Large Enterprises since 2003.

1.3. We have clearly articulated our intent of being an Admirable, Inspirational and Sustainable institution in our CODE (https://code.ibs.bg). The core values of Collaboration, Ownership, Development and Efficiency are embedded into our corporate culture. These values guide our decision-making processes, enabling all the employees to take ownership and responsibility for their individual actions.

1.4. Environmental, Social and Governance (ESG) continues to gain increased attention with  customers and market demands performance reporting. ESG processes and procedures focus on non-financial performance indicators that address a company’s approach towards responsible investment, sustainability, its impact on society and the environment, as well as other ethical and corporate governance considerations.

1.5. This document outlines the Company’s approach towards sustainability and ESG (“the Policy”). It proposes to act as a guiding framework to manage the Company’s environmental, social and governance impacts and risks as well as long-term value creation.


2. Objective

2.1. The objective of this Policy is to incorporate ESG considerations into operations and business, mitigate material impacts and risks thereof. The Polcy also serves as a guiding document for the ESG initiatives and activities undertaken by the Company. The approach towards ESG integration includes development of a robust governance mechanism, implementation framework, systems for risk management and controls, incorporation of environmental and social considerations into the standard operating procedures of the Company’s operations as well as communication and disclosure of ESG performance.

Our ESG Vision

To be an environmentally and socially responsible institution built on the foundation of ‘Assurance’, focused on generating sustainable long-term value for all our stakeholders.

Our ESG Goals

  1. Profitability with ethical, environmental and social responsibility
  2. Mainstream ESG practices into business, operations and value chain
  3. Achieve best in class ESG ratings

3. Key Principles

The ESG is based on the 9 principles. The companies should be socially, economically and environmentally responsible. They should also develop a better understanding of the process of transformation that makes their operations more responsible. The principles:

  • Conduct and govern with integrity in a manner that is Ethical, Transparent and Accountable
  • Provide goods and services in a manner that is sustainable and safe
  • Respect and promote the well-being of all employees
  • Respect the interests of and be responsive to all stakeholders
  • Respect and promote human rights
  • Respect and make efforts to protect and restore the environment
  • When engaging in influencing public and regulatory policy, do so in a manner that is responsible and transparent
  • Promote inclusive growth and equitable development
  • Engage with and provide value to our consumers in a responsible manner

Here is how we adopt these principles.


4. Policies

Principle 1

4.1. Ethics, Transparency and Accountability

4.1.1. The Company believes in value-based governance and practices. We are committed to maintain the highest standards of ethics in all spheres of its business activities. The senior management have a responsibility to set exemplary standards of ethical behavior, both internally within the organization, as well as in our external relationships. Management shall constantly endeavor to instil this ethical behavior at all levels in the organization so that it becomes an essential part of the working culture among all IBS employees. Every employee of IBS shall conduct herself and deal on behalf of the company with professionalism, honesty and integrity, conforming the moral and ethical standards.

4.1.2. All business decisions and transactions shall be fair, transparent, amenable to disclosure and be visible to relevant stakeholders. IBS believes that transparency means explaining Company’s policies and actions to those to whom it has responsibilities. Therefore, the Company shall ensure maximum appropriate disclosures without jeopardizing the Company's strategic interests. Internally, transparency means openness in Company's relationship with its employees as well as the conduct of its business in a manner that will bear scrutiny. The Company believes that transparency enhances accountability. Everything we do must stand the test of public scrutiny.

4.1.3. Empowerment is an essential component of the Company’s principle of governance, which enables all coworkers to take the enterprise forward. Empowerment unleashes creativity and innovation throughout the organization by truly vesting decision making powers at the most appropriate levels in the organizational hierarchy. The Board of Directors is accountable to the shareholders, and the management is accountable to the Board of Directors. Each executive and employee is similarly accountable for the entrusted functions and responsibilities.

4.1.4. The Company is committed to and supports the Constitution and government bodies of the countries we operate. We shall not support any political party or candidate for political office. The Company's conduct shall prevent any activity that could be interpreted as mutual dependence favour with any political body or person, and shall not offer or give any Company funds or property as donations to any political party, candidate or campaign.

4.1.5. Employees at all levels shall put Customer's, Public and Company’s interest above personal interest while discharging his/her duties and responsibilities. Employees shall avoid apparent conflict of interest. Conflict of interest may exist when we have personal interest that may have a potential conflict with the interest of the Company. Illustrative cases of conflict of interest are: Related Party Transactions: Entering into any transactions or relationship with the Company or its subsidiaries in which there is a financial or other personal interest (either directly or indirectly such as through a family member or relation or other person or other organization with which they are associated). Consultancy/Business/Employment: Engaging in any activity (be it in the nature of providing consultancy service, carrying on business, accepting employment) which is likely to interfere or conflict with their duties and responsibilities towards the Company. Employees should not invest or associate themselves in any other manner with any supplier, service provider or customer of the Company.

Principle 2

4.2. Safety and Sustainability of goods & services

4.2.1 The Company implements numerous projects in the private and public sector. IBS is committed to continuously improve its safety, sustainability and goods & services by the following points:

Sustainable products and services are those generate measurable social or environmental benefits.
The goods and services that does not deplete resources.
The goods and services which safeguard water, energy, less generation of waste at various stages of handling.
Promoting Environmental and Safety Awareness among all the employees, vendors and contractors.
Principle 3

4.3. Human Resources Development and Well-being of employees

4.3.1 The Human Resource Management function is a champion for:

Organizational transformation to global performance standards
Aligning people with business strategy
Culture building, mentoring, values introduction and personal development for positive action with the objective of overall development of the employees and organization
Delivering world class HR processes that develop leadership capability, organizational performance and strategic employee competencies
Ensuring the wellbeing of employees at all levels
IBS is committed to continue to take steps to promote a safe and productive work environment for its coworkers and will provide guidance on occupational health and safety, appropriate healthcare benefits and medical cover to all its employees.

IBS - HR policy and procedures (hereinafter collectively referred to as “HR”), thus address the following facets of HR:

4.3.2 HR as a Strategic Partner

Strategic HRM is the first process of linking HR function with the strategic objectives of the organization in order to improve performance. HR has to play the role of a business partner keeping in view the Company's Vision, Mission, strategic imperatives, stakeholders’ interests, business objectives and the competitive environment.

At IBS strategies are envisioned by cross-functional teams representing all business lines and we deliberate on business issues and environment faced by the Company. HR plays an pivotal role in this process.

4.3.3 Talent Attraction & Retention

Attracting and retaining talent involves many activities including employee engagement, career development and personal empowerment. HR function provides the necessary environment to promote self-learning. HR promotes close-ended formal education. The knowledge so acquired by the individual by various modes supplement individual domain expertise as well as blend with business goals of the Company. Employee training and mentoring would help in spreading and blossoming technical and managerial talent. These measures reinforce IBS as a learning organization.

Company-wide tools and initiatives on Knowledge Management and Sharing help in domain and cross functional expertise building, as well as general communication channel between all company members.  We have well defined training & development programs for all staff members.

4.3.5 Leadership Development and Change Management

The ultimate competitive advantage of an enterprise is its ability to grow and develop leaders faster than its competitor. The pace of change due to globalization, customer demands, technological innovation and information access demands that the Company go beyond strategy, structure and systems to purpose, process and people. HR would champion the change management initiatives of the Company enabling it to create a robust leadership pipeline and align itself to a global outlook.

IBS has institutionalized the Succession Planning Process through Gap Analysis, identifying critical roles and identifying key bench strength for each critical role position, Readiness index of the successors based on Performance Management Systems and other criteria.

The vacancies of all critical posts as per succession plan are filled meticulously through regular incumbent with the internal talent pool and if required with outsiders in case internal talent pool is not available.

4.3.6 Employee Relations and Welfare

Employees at all levels have access to a grievance redressal mechanism. All employees are be paid timely salaries, wages, allowances and other benefits as per the statutory provisions and as agreed.

The Company provides a workplace environment that is safe, hygienic, humane, comfortable and which upholds the dignity of the employees. We shall provide facilities for the wellbeing of its employees including those with special needs. The Company shall comply with all statutory provisions with regard to health, safety and wellbeing of its employees.

Specific provisions contained in the Labour laws for ensuring health, safety, hygiene, comforts and wellbeing of employees are complied in letter and spirit.

IBS provides and maintain equal opportunities at the time of recruitment as well as during the course of employment irrespective of caste, creed, gender, race, religion, disability or sexual orientation.

IBS does not use child labour, forced labour or any form of involuntary labour, paid or unpaid. We create systems and practices to ensure a harassment free workplace where employees feel safe and secure in discharging their responsibilities. Statutory provisions with regard to these aspects shall be fully complied.

4.3.7 Equal Opportunity Policy

We provide equal opportunity to differently abled employees.


Principle 4

4.4. Protection of Stakeholders' Interest

4.4.1 IBS values the support of its stakeholders and respects the interests and concerns they have towards it.

4.4.3 IBS is conscious of the impact of its policies, decisions, products and services and associated operations on the stakeholders and shall avoid such actions which adversely affect the health, safety and welfare of the stakeholders.

4.4.4 IBS shall proactively engage with and respond to those sections in the society that are disadvantaged, vulnerable and marginalized. It shall also give special attention to stakeholders in areas that are underdeveloped.

4.4.5 IBS shall resolve differences with stakeholders in a just, fair and equitable manner.


Principle 5

4.5. Promoting Human Rights

4.5.1 The Company appreciates that human rights are inherent, universal, indivisible and interdependent in nature. The Company shall always strive to adhere to the human rights laws and guidelines of the International Bill of Human Rights.

4.5.2 The Company shall integrate respect for human rights in management systems and ensure that all individuals impacted by the business have access to grievance redressal mechanisms.

4.5.3 The Company shall recognize and respect the human rights of all relevant stakeholders and groups within and beyond the workplace, including that of communities, consumers and vulnerable and marginalized groups.

4.5.4 The Company shall, within its sphere of influence, promote awareness and realization of human rights across its value chain.


Principle 6

4.6. Protection of Environment

4.6.1 The Company is committed to achieve the economic, ecological and social responsibility objectives of sustainable development through its varied business operations and activities. As an Environmentally Responsible Company, IBS is committed to work in environmental friendly manner, protect environment and prevent pollution of all types. We fulfil our compliance obligations, conserve natural resources and continually improve to enhance environmental performance.

4.6.2 IBS commits itself to take all necessary initiatives towards optimization and continual reduction in utilization of natural resources. The Company is determined to focus its attention to achieve the goal of “Reduce, Reuse and Recycle” in its entire operation and process for sustainable development. Company is committed to put efforts towards renewable resources to avoid depletion of natural resources.

4.6.3 The Company shall comply with all legal/regulatory requirements related to environment protection, management and sustainable development. Company shall have regular monitoring programme to assess its performance of environment management and sustainable development.

The Company shall identify hazardous process, assess its risk and determine appropriate control measures to minimize the impact on Environment.

4.6.4 Environmental friendly processes and operations shall be given high priority while selecting or introducing any new process, operation or product or service. Efficient processes shall be opted in order to minimize impact on environment.

4.6.5 The Company shall initiate environment management programs to minimize impact on the environment. This shall be a continuous process. Introduction of cleaner technologies, elimination of hazards, complying with legal requirements and resource conservation, etc. shall be the impetus areas of Company’s environment management programs.

4.6.6 The Company shall promote customer awareness in environment management to minimize impact on environment during usage of the Company’s products. The Company shall persuade and encourage its business partners to move towards environmentally friendly processes right from design to disposal. Furthermore, the Company is committed to continuously improve its Sustainability and Environmental Management through processes defined below:

  • Minimizing the consumption of electrical energy and natural resources
  • Encouraging use of renewable / replenishable / sustainable resources
  • Compliance to applicable legal requirements and other requirements related to environmental aspects
  • Promotion & adoption of environmental friendly practices
  • Setting, Maintaining and Monitoring the Environmental Objectives & Targets

Principle 7

4.7. Public and Regulatory Policy

4.7.1 Тhe Company understands its responsibility to function within the democratic set up and the constitutional framework. It recognizes that businesses operate within the specified legislative and policy frameworks prescribed by the Government, which guide our growth and also provide for certain desirable restrictions and boundaries. The Company and its employees would respect the legal/regulatory framework and shall comply with all the applicable provisions of existing local, state, national, and international laws. They shall also follow and obey the policies, procedures, rules and regulations relating to the business of the Company.

4.7.2 In case of any grievance with any legislative / regulatory mandates, it shall seek remedy. Wherever necessary and to the extent possible, the Company shall seek policy changes through the trade and industry chambers and other such collective platforms.

4.7.3 The Company believes that policy advocacy must preserve and expand public good and thus shall never advocate any policy change to benefit itself alone or a select few.


Principle 8

4.8. Inclusive growth and equitable development

4.8.1 Code of conduct for Vendors/Suppliers

4.8.2 Customer Relations Management:

a. Effective Systems shall be provided for:

i. Registration of Customer complaints.

ii. Timely redressal of customer complaints.

iii. Making status on Customer Issues

iv. Periodic reporting to top management / concerned authorities on the status of all customer complaints with details of analysis.

v. Obtaining customer feedback on complaints.

b. Customer satisfaction survey shall be conducted periodically to assess customer satisfaction.


5. General

The above policies shall be subject to review/changes by IBS as may be deemed necessary and in accordance with regulatory amendments.