Significant sustainability topics

TMF Group is committed to making a positive impact to the communities where it operates, and aims to integrate comprehensive sustainability reporting with full assurance into its annual report by end of financial year 2025. In 2023 TMF Group made significant steps forward on this journey, undertaking its first assessment of sustainability topics to identify what should be considered significant to the business.

This was done by assessing a full range of topics against the following criteria:

  • Positive Impact - topics where TMF Group's operations can make a positive difference to communities or the environment where TMF Group operates.

  • Negative Impact - topics where there are potential negative consequences of TMF Group's operations on communities and the environment.

  • Financial Risks - topics where communities and the environment pose a potential risk to TMF Group's financial performance.

  • Financial Opportunities - topics where communities and the environment present opportunities to improve TMF Group's financial performance.

Based on the assessment TMF Group considers nine topics significant to its operations. TMF Group plans to incorporate those topics in TMF Group's sustainability reporting framework, with ambitions and achievements covered in the group’s impact reports. Further work in 2024 aims to validate this assessment with stakeholders from across our value chain, to ensure our reporting framework aligns to upcoming regulatory requirements.

The topics are combined in three separate categories, as outlined below.

Governance topics

  • Corruption and bribery - as part of its operations, TMF Group frequently has access to client accounts, makes payments and holds positions of fiduciary responsibility on behalf of clients. Effective controls to prevent bribery and corruption are critical in preventing negative outcomes for clients. Providing easier client access to best practice controls has a positive impact on efforts to tackle corruption and bribery globally. Failure to maintain these controls would pose a risk to TMF's reputation and revenue.

  • Information management - in the provision of services TMF Group handles significant volumes of company sensitive and personal data on behalf of clients. Effective controls over the management of such information provides clients with a safe and secure way of completing business tasks whilst minimising data risks. Failure to maintain these controls could create risks to clients and to TMF Group's financial performance. There is also risk of escalating cost of maintaining these controls as information security threats increase their sophistication.

  • Transparency - through the administration of entities used for structuring of investments and corporate groups, TMF Group is often responsible for making or supporting client disclosures in line with international and local requirements, often designed to promote sustainability and expose illicit/unethical activities. Such disclosures are facilitated by the knowledge of TMF Group's network of local experts and their relationships with regulators. Capitalising on this capability is a major driver of commercial expansion for the business, but comes with material risk of sanctions and reputational damage if responsibilities are not fulfilled.

  • Corporate culture - research shows that an effective corporate culture built on strong values is a key enabler of strong performance, both from a financial and social impact perspective. This is also true for TMF Group, were establishment of positive culture across the firm accelerates efforts to mitigate risks and unlock opportunities across the business.

Social topics

  • Working conditions of employees - TMF Group employs over 11,000 people, with the expertise held by colleagues in 87 jurisdictions key to our service proposition to clients. How the group treats these colleagues has the potential to bring both positive and negative consequences to the communities where they are based. Failing to protect employee working conditions also poses a risk to the stability of business operations.

  • Equal treatment and opportunities for all - the growth of the business and employee turnover means that the business fills about 2,500 positions every year through a combination of external recruitment and managing career opportunities for existing employees. Managing a fair and inclusive approach to talent selection helps the business to build a diverse and effective team, with positive social consequences across our communities.

  • Community involvement - the geographic diversity and expertise of the TMF Group employee base provides a capability to support cross border collaboration, establish effective governance controls, and mobilise extensive networks of support. When applied to social projects this capability has the potential to make a positive contribution to communities where we operate.

Environmental topics

  • Climate change mitigation - TMF Group is part of the supply chain of a significant international client base including many of the world’s largest corporate groups and investment firms. Such clients are increasingly making climate commitments, which require similar commitments to be made across their supply chain. Working towards such a plan would make a positive difference to global efforts to mitigate climate change, and also mitigate risks to future growth if TMF Group is unable to keep pace with the ambition of its clients.

  • Energy - within corporate environmental commitments, Scope 1 and 2 emissions are often seen as the most actionable, as require control over the resources directly consumed by the company. Energy consumption in offices is the largest component of Scope 1/2 emissions for TMF Group, and therefore is a key area where the business can make a direct difference to global GHG emissions.

Sustainability Impact Report – Living our Values

To manage impact on significant Social and Governance topics we have organised a sustainability programme around five themes aligned to our group values. This helps reinforce the culture we aim to promote within our employee group, by showing how as a company we can live our values to the benefit of clients, colleagues, and the environment.

Our sustainability ambition:

  1. Insight - fulfil our purpose of facilitating global investment and trade.

  2. Service - deliver high integrity service to our clients.

  3. Integrity - ensure a high standard of governance.

  4. Talent - create great careers for all.

  5. Teamwork - use our resources to help communities where we operate.

Delivering this ambition is a responsibility of our group functions, who continue efforts to evolve and improve the business. In 2023, TMF Group also established formal governance to steer CSRD compliance and sustainability efforts. This included launching a subcommittee of the Supervisory Board, establishing a steering group consisting of company executives, and assigning dedicated resources to relevant reporting and monitoring.

The maturity of our sustainability programme is assessed annually by Ecovadis and has shown improving performance for each of the last 4 years, placing TMF Group in the top 13% of companies within our industry group with Silver Medal recognition since 2021. We are also signatories of the Principles for Responsible Investment since 2021, and UN Global Compact since 2023.


TMF Group's purpose sets out an ambition to the business to support multinational businesses in operating safely and securely across a large geographic footprint. Delivering on this has a positive impact in building better governance practices for multinational organisations and supporting international trade and investment flows between nations.

The success of these efforts can be seen in the ability of the business to grow the number of jurisdictions and services it provides to its clients, demonstrating increased coverage and need for the support we provide.

2023 sales records shows that expansion of existing multinational accounts is the most important driver of our growth, and growing in significance each year. This shift has been supported by the additional insight we bring to clients regarding managing complexity of doing business across borders – for example in the publication of the group’s 2023 Global Business Complexity Index (GBCI), a 10th anniversary edition.

TMF Group is also investing in improving the breadth of support it provides, launching a number of new solutions to enhance the way clients navigate multinational complexity. This includes the launch of ESG Administration Services in 2023, which provides a capability to support clients with the increasing administrative processes of ESG compliance.

In 2024 we aim to build on this work with the introduction of the ‘OneWorld’ expansion programme, which provides a greater focus on growing as a ‘Performance Partner’ for our global accounts.


TMF Group provides critical administration services to clients, where protecting the accuracy and integrity of information we process is crucial to avoid negative repercussions.

Recognising this, in 2023 the group launched it’s ‘Flawless Service’ campaign, to promote service excellence standards across the business. This included the launch of the three service excellence behaviours – Accountable, Proactive, and Thoughtful, through a global internal communication campaign to engage colleagues.

These commitments are supported by a range of delivery controls to help protect client information and service quality. This includes assurance across an ISAE 3402 control framework for Payroll, IT, and Fund Services, and ISO 27001 compliance across our locations. We also maintain dedicated information security and data protection teams who oversee policies, controls, and compliance to make sure we fulfil our responsibilities to protect client personal and sensitive information.

Continuing to improve our standards of service also relies on the feedback we receive directly from clients. In 2023 we have been working to create additional ways for clients to share concerns, such as creating a Speak Up Channel on our website. All client escalations are monitored centrally to ensure these are properly addressed. Our client engagement survey is also sent annually to gather comments from our clients.

Our client engagement results shows steady improvement in the NPS of local TMF Group Services over the past 3 years (from +43 in 2021 to +44 in 2022 and +47 in 2023). We aim to continue this trajectory as we invest further in quality of service in 2024.


Maintaining credibility with our clients, employees, and investors requires TMF Group to adhere to a high standard of corporate governance.

This includes maintaining a mature and comprehensive set of policies with mandatory training for all employees on critical topics (such as bribery and corruption). Training completion rates are centrally monitored, with any instances of non-compliance addressed. We also set careful controls on client acceptance (by the client acceptance committee), have central initiatives to enhance controls over key business risks, and maintain a transparent dialogue with regulators across our 26 regulated jurisdictions.

We invest in a number of ways to hold ourselves to the standards we set. Our process adherence is regularly reviewed through our internal audit function with findings regularly discussed in key management forums. Colleagues and clients also have the opportunity to highlight any concerns anonymously and confidentially through our Speak Up Channel, in line with our whistleblowing policy.

Overall, our business controls are well regarded in the industry with our Ecovadis ratings consistently positioning us within the top 4% of companies in our industry group for ethics.


People are at the heart of the TMF Group proposition, and so supporting colleagues in their ambitions as a fair employer is key to the commercial success of the business. This is why we aspire to be the home of great careers for our team, and the employer of choice in our industry.

This ambition is supported by a mature HR platform which maintains a comprehensive set of policies and talent programmes at a group level, which are then localised with the support of region, market, and country level HR support. A consistent HR technology backbone makes this possible, including HRIS, Talent Acquisition, and Performance Management tools.

Employees are regularly consulted on their views on the business, with employee satisfaction surveys conducted three times in 2023. Feedback is then shared with management, who are responsible for acting on changes to continuously improve our colleague value proposition. TMF Group also cooperates with formal employee representation in relevant locations (e.g. Works Council).

A key focus has been improving the proportion of experienced vacancies being filled by internal promotion. This has been measured since 2022 and has been a particular focus of management in 2023, resulting in a positive step forward in promotion rates (increased from 31% in 2022 to 45% in 2023). We are targeting further improvement in this measure in 2024, with the support of a new talent platform which has been approved for implementation this year.

The overall success of this programme is monitored through our colleague engagement score (increased from 65% in 2021 to 69% in 2022 and finally 71% in 2023) as well as voluntary employee turnover rates (from 24% in 2021 to 23% in 2022 and 17% in 2023, dropping to 14% in Q4 2023). Both have been trending positively for the last three years, which we aim to continuously improve in the years ahead.


TMF Group started 2023 with the completion of its Diversity, Equity, and Inclusion discovery journey, facilitated by Ashoka. This involved representatives from the group leadership positions engaging with a number of external speakers to reflect on the way the group supports its diverse talent base. This resulted in a series of new initiatives supported through the global network of DEI ambassadors, with a key focus being improving the representation of women in senior business roles. Women represent 67% of TMF Group employees, but are a smaller percentage of senior positions. This gap has been closing in recent years (increased from 39% in 2021 to 42% in 2022 and 44% in 2023), but the group is aiming to close this gap further in the years ahead by removing barriers preventing women advancing in the organisation.

TMF Group also significantly increased engagement in CSR initiatives in 2023. A new partnership was launched with Bridge for Billions, which will utilise the expertise of several hundred employees in mentor relationships with social entrepreneurs. The initiative will help the entrepreneurs learn from TMF Group experience in business while developing mentoring skills for our employees.

The CSR committee also increased the availability of funding to support locally led initiatives, managed through the established network of local CSR ambassadors. Since launching the updated approach in August over 350 colleagues have been engaged in 11 group sponsored local initiatives, with €55 thousand of group investment deployed alongside €12.5 thousand of colleague fundraising. We aim to build on this momentum in 2024 to further step up CSR engagement.

Finally, 2023 saw the formalisation of the TMF Foundation. The group have a history of using our international reach to support colleagues and their families in times of need (e.g. warfare, natural disasters, pandemics). TMF Foundation formalises this support mechanism with clear governance and ring-fenced funding. The first claims on this fund were approved in the second half of 2023.

Climate Impact Report

TMF Group is committed to limiting the carbon impact of its services, by taking responsible steps to mitigate the risk of climate change.

Employee led initiatives have been running for several years in this area, including office led initiatives to control waste, educate colleagues, and promote ‘Tree per Client’ programmes across the business. In 2023 the group also took steps towards formalising its GHG reporting and climate commitments by completing a carbon inventory exercise with the support of external advisors.

This work estimates that four key areas represent over 80% of the group’s emissions footprint:

  1. Remote working - a high share of TMF Group employees work remotely for some of their time. This reduces the impact of commuting and office-based emissions, but introduces emissions related to home working environments into the TMF Group GHG reporting scope.

  2. Procurement - suppliers to TMF Group for both purchased and capital goods have GHG emissions associated with their services, which form part of the group’s scope 3 emissions. Much of this is technology related procurement, linked to the supply of hardware and software needed to complete and support client work.

  3. Employee commuting - TMF Group has many employees who commute to city-based offices for most of their working days. Typical commuting methods vary by location but collectively make a significant contribution to scope 3 emissions.

  4. Purchased energy - of the emissions the group directly controls (Scope 1 and 2), energy purchased for heating, cooling, and supply of electricity to offices is the most material. Control over energy provision varies across the business based on local availability and the nature of office leases.

In 2024 the business aims to introduce a series of initiatives to reduce the carbon impact of TMF Group services from these activities. The group is also actively working on implementing a robust carbon reporting system to ensure full GHG disclosures can be provided in future sustainability reports and is exploring the commitments it can make to formalise its decarbonisation journey.