Sustainability reporting
Our sustainability journey and future goals
At TMF Group, sustainability is deeply embedded in our purpose, values, and operations. As a global leader in compliance and administrative services, we recognise that our role extends beyond business success - we have a responsibility to support a sustainable and equitable global economy. By helping clients invest and operate safely around the world, we promote prosperity, stability, and responsible growth across borders.
Our commitment to sustainability is reflected in our long-term strategy, which integrates environmental, social, and governance (ESG) considerations into our business model. We believe that strong governance is the foundation of sustainable business, and our work ensures that companies operate with integrity, transparency, and compliance across jurisdictions. As an extension of national legal and regulatory frameworks, we help direct investment toward responsible and ethical business practices.
Since 2023, TMF Group has been a proud signatory of the UN Global Compact and a member of the Principles for Responsible Investment (PRI), reinforcing our commitment to responsible business conduct. We uphold sustainable values in our daily operations and client services, recognising the urgency of climate change mitigation and the importance of equal opportunities for all.
Our people are at the heart of our ESG ambitions. With a workforce of over 11,700 employees worldwide, we prioritise employee well-being, professional growth, and inclusivity. Great Place to Work certifications serve as an external benchmark of our efforts, ensuring that we foster a positive, supportive, and diverse work environment. Additionally, we continuously refine our policies on remote work, travel, and office space to minimise our environmental footprint.
Looking ahead, TMF Group remains committed to embedding sustainability deeper into our business. Through collaboration, innovation, and responsible leadership, we aim to create long-term value for our clients, employees, and communities while actively contributing to a more sustainable and equitable world economy.
To ensure our sustainability strategy aligns with the most pressing issues for our business and stakeholders, we have initiated a stakeholder engagement process to identify key material topics. As part of this, we are conducting a double materiality assessment (DMA), aligned with European Sustainability Reporting Standards (ESRS), which will provide a comprehensive understanding of how sustainability matters impact our business and how our business impacts people and the environment. The full results of this assessment will be published in our ESG report together with our annual report of 2025.
Corporate governance and the Group's operating principles
Sustainability is embedded in TMF Group’s corporate governance framework, ensuring strategic oversight, accountability and continuous improvement. TMF Group measures its ESG maturity through annual EcoVadis assessments reflecting the Group’s commitment to responsible business practices. In 2024 we received bronze rating. By embedding sustainability into corporate governance, TMF Group ensures ESG remains a core strategic priority, aligned with stakeholder expectations and regulatory developments.
Due diligence and corporate policies
At TMF Group, we maintain a robust governance framework that ensures compliance, integrity, and risk management across our global operations. Our policies and procedures are designed to uphold ethical business practices, protect sensitive information, and ensure business continuity. We communicate these policies through multiple channels, including a global policy library accessible via our intranet and mandatory training programmes for employees.
Code of conduct
Our code of conduct, available publicly on our website, outlines TMF Group’s core values and commitment to integrity. It sets out guiding principles for ethical business conduct and risk management, covering areas such as anti-money laundering (AML) and combatting the financing of terrorism (CFT). Employees must adhere to stringent policies to prevent financial crime. To reinforce these principles, annual code of conduct training is mandatory for all employees, ensuring continuous awareness and adherence to our ethical standards.
Anti-bribery and corruption policy
TMF Group upholds a zero-tolerance approach to bribery and corruption. Our anti-bribery and corruption policy mandates strict compliance with international anti-corruption laws, requiring all employees to complete annual training on:
respecting international sanctions
preventing money laundering and terrorist financing
countering bribery and corruption.
The effectiveness of our compliance programme is regularly validated by our internal audit function, ensuring policies and procedures remain robust and effective.
Data protection and information security
Given the sensitive nature of our client services, information security and data protection are critical priorities. The Audit and Risk Committee oversees cybersecurity and privacy risks, ensuring appropriate controls are in place. TMF Group maintains dedicated information security and data protection teams to oversee compliance and risk management.
Key measures include:
incident response – immediate notification to clients in case of a data breach, in compliance with local data protection laws
operational controls – stringent security policies to protect personal and sensitive information
compliance monitoring – ongoing assessment and enhancement of security measures to address evolving threats.
Whistleblower policy
TMF Group encourages ethical behaviour and provides a confidential Speak Up channel for internal and external stakeholders to report governance violations. Our whistleblower policy ensures:
protection of whistleblowers from retaliation
proper escalation procedures for reported concerns
transparency in handling cases, with management responsible for acting on reported issues.
Employees, clients, contractors, suppliers and any other stakeholders, can use this mechanism to report concerns safely and responsibly.
Business continuity and resilience
TMF Group prioritises business continuity to protect employees, clients and all other stakeholders. Our resilience strategy includes:
geographically distributed data centres with additional connectivity, ensuring near 100% uptime
secure backup protocols, including encrypted daily, monthly, and yearly backups stored with certified providers
remote access capabilities, enabling employees to securely work from any location with multi-factor authentication
data retention compliance, ensuring information is retained in accordance with legal requirements even after client services end.
In addition, health and safety is a key part of our risk management strategy, ensuring the well-being of employees, clients and visitors within our offices.
Risk management framework
TMF Group applies a comprehensive risk management (RM) framework to identify and mitigate compliance, operational, reputational, financial and legal risks. For details please refer to the risk management section of the Director’s report. Through the above structured approach, TMF Group ensures transparency, accountability, and resilience, reinforcing our commitment to responsible business practices.
Environment
Our commitment to climate action
Climate change is one of the highest-priority sustainability issues for investors and an increasingly important business issue for companies. TMF Group is part of the supply chain of a significant international client base that includes many of the world’s largest corporate groups and investment firms. These clients are increasingly making climate commitments that require similar commitments throughout their supply chains. By working together with our clients, we aim to contribute positively to global efforts to mitigate climate change and reduce risks to future business growth.
To identify and manage our climate impacts, we track our greenhouse gas (GHG) emissions across all scopes. This includes monitoring our direct emissions (Scope 1), indirect emissions from purchased energy (Scope 2), and emissions from our upstream and downstream value chain (Scope 3). Our approach involves collecting data from suppliers, activity-based sources, and financial records to ensure a comprehensive understanding of our carbon footprint. These details will be included in our ESG report together with our emissions mitigation plan.
GHG Emissions and Key Sources
scope 3 accounts for most of our emissions, mainly from purchased goods and services, employee commuting and business travel
purchased energy is the most material component of our direct emissions, though energy procurement varies by location and lease arrangements
procurement of technology-related services and goods contributes significantly to Scope 3 emissions
employee commuting and remote working emissions represent an important focus area, given our global workforce and flexible work arrangements.
Our climate strategy and emissions reduction initiatives
In 2024, we collaborated with external advisers to develop an actionable emissions reduction plan covering all scopes. This plan includes measures to assess the investments required to align our operations with the Paris Agreement and position TMF Group to set GHG reduction targets in line with climate science and the Science Based Targets initiative (SBTi).
During 2025, TMF Group aims to take the following steps to reduce our emissions:
strengthening carbon reporting: we are implementing a robust GHG reporting system to ensure complete and accurate emissions disclosure in future sustainability reports.
Encouraging our supply chain to reduce their GHG emissions by:
mapping purchased services and identifying key suppliers with high emissions
engaging with major suppliers to collect emissions data and assess sustainability maturity
incorporating sustainability criteria into supplier selection, including emissions intensity and data transparency
providing sustainability education for lower-maturity suppliers.
Reducing office-related emissions:
exploring opportunities to improve energy efficiency across our offices
encouraging offices in leased spaces to procure renewable energy where feasible
managing employee commuting and remote work emissions
encouraging low-carbon commuting options, such as public transport, carpooling and cycling.
Embedding sustainability in our operations
To enhance awareness and engagement with our ESG commitments, we have developed an Environmental Guideline for our offices. This framework provides practical recommendations for sustainable office management and employee behaviours, covering both in-office and remote work settings.
Looking Ahead, TMF Group is committed to making measurable progress in reducing our environmental impact. As part of this commitment, we aim to publish our GHG reduction targets in our next annual report, further solidifying our decarbonisation journey.
In 2024, we conducted a climate and nature risk analysis in collaboration with AXA Climate’s Attitude platform. This assessment provided insights into the physical and transitional risks TMF Group may face due to climate change and biodiversity loss. The analysis helped us identify vulnerabilities across our operations, such as the potential impacts of extreme weather events, regulatory changes, and supply chain disruptions. Understanding these risks allows us to proactively integrate climate resilience and nature-related considerations into our business strategy, ensuring long-term sustainability and compliance with emerging regulatory frameworks.
Social
At TMF Group, our people are at the core of our services. Supporting our employees in their professional ambitions is fundamental to our success, and we strive to be the employer of choice in our industry.
Our strategy for fostering great careers is built on five pillars.
Continuous learning and development: we invest in training programmes, both internal and external, to enhance employees’ skills, knowledge and career progression.
Work–life balance: we promote a supportive and flexible work environment, with many colleagues taking advantage of our hybrid working arrangements.
Diversity, equity, and inclusion (DEI): we provide training on unconscious bias, inclusive communication, and equitable career advancement opportunities.
Transparent communication: we engage employees through regular updates, town hall meetings, surveys, and feedback channels to foster trust and inclusion.
Fair compensation: our annual pay review process includes multiple levels of calibration and pay-gap analysis.
A key focus in 2024 has been on increasing internal promotions, with internal promotions into mid and senior level positions rising from 40% in 2023 to 53% in 2024. To further enhance career mobility, we launched Talent Hub, a platform linking employees’ skills with learning resources and internal job opportunities.
Our employee satisfaction is reflected in our well contained voluntary attrition (14%), strong colleague engagement (70%) and continuous Great Place to Work re-certifications. At the end of 2024, we had 27 countries actively Great Place to Work certified, with further 9 up for re-certification.
Employee health and safety
As an office-based service provider, TMF Group does not face material health and safety risks. However, we uphold global standards to ensure a safe and healthy work environment for all our work force.
Our global HR policy outlines key health and safety principles, including:
safe working environments
prevention of accidents and injuries
emergency response and medical protocols
business continuity planning
safe international travel and employee evacuation
mental well-being initiatives.
Human and labour rights
TMF Group is committed to upholding high ethical standards and combatting all forms of labour exploitation, in alignment with the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.
Our modern slavery statement outlines our commitment to preventing forced labour, unlawful child labour and human trafficking within our business and supply chains. Employees are encouraged to report any concerns via our Speak Up channels, as detailed in the whistleblower policy.
Diversity, equity, and inclusion (DEI)
TMF Group fosters an inclusive work environment, rejecting all forms of discrimination based on age, gender, ethnicity, religion, marital status, neurodiversity, disability, or sexual orientation.
Our global HR policy, code of conduct, and internal recruitment policy establish equal opportunities for learning, promotions, and fair hiring practices. Recruiters and hiring managers receive training on competency-based interviews and removing barriers for underrepresented groups.
In 2024, we launched new DEI initiatives through a global network of DEI ambassadors, focusing on improving women’s representation in senior roles. At the end of 2024, 46% of our senior leaders were female.
The TMF Business Academy provides DEI training on unconscious bias, inclusive communication and anti-discrimination practices. Additionally, we run internal awareness campaigns covering topics such as neurodiversity, religious holidays, and LGBTQIA+ events.
Employee career development and training
The TMF Business Academy offers extensive learning opportunities tailored to local and global needs. Employees can access training in:
technical skills and business processes
global and local regulatory standards
English language development
mental health and well-being
leadership and management development.
In 2024, 87% of our employees engaged in TMF Business Academy Courses, with an average of 13 learning hours per participating employee (mandatory e-learning courses not included), reflecting our commitment to continuous learning. Our training programmes are delivered through a combination of face-to-face sessions, virtual learning, and self-paced courses to cater to diverse learning preferences.
Corporate social responsibility (CSR)
In 2023, TMF Group ended our multi-year CSR partnership with Ashoka and launched a new social impact programme Beyond Boundaries, in partnership with Bridge for Billions. The programme connects TMF Group employees with underrepresented entrepreneurs across North America, Latin America, Europe and Asia Pacific to deliver high-quality entrepreneurship training and mentorship. In November 2024, we launched Year 2 of the programme, where our colleagues engage in a structured journey with entrepreneurs, enhancing their mentoring skills and sharing their expertise and knowledge.
Our CSR Committee also increased funding for local initiatives, managed through a network of CSR ambassadors. In 2024, 1,400 employees participated in 34 community projects, with TMF Group’s investment of €122,439 from the central budget.
To further strengthen our social impact, we established the TMF Foundation in 2023, which provides emergency relief for TMF employees and their families in times of crisis, and has since helped 8 employees and/or their close family members.
In 2025, we aim to build on this momentum by increasing employee engagement in CSR activities and expanding global and local partnerships to drive sustainable social impact.
TMF Group is dedicated to fostering an inclusive, supportive and socially responsible workplace. Through continuous investment in employee development, DEI initiatives, ethical business practices and CSR engagement, we create an environment where employees thrive, communities benefit and our business prospers.
Our commitment to fair labour practices, employee well-being and corporate social responsibility reinforces our position as a responsible employer.