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 our 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 towards responsible and ethical business practices.

Since 2023, TMF Group has been a proud signatory of the UN Global Compact, reinforcing our commitment to responsible business conduct. 

Our people are at the heart of our ESG ambitions. With a global workforce of over 12,000, we prioritise the well-being, professional development and inclusion of all our employees. Our Great Place to Work certification is an external signal of our efforts to foster a positive, supportive and diverse work environment. Furthermore, we continuously refine our policies on remote working, business travel and office management to minimise our environmental footprint.

 Looking ahead, we are committed to further embedding sustainability into our operations. Through cross-team collaboration, innovation and responsible leadership, we aim to generate long-term value for our people, clients and local communities.

To ensure that our sustainability strategy reflects the issues that are most relevant to our business and stakeholders, we conducted a double materiality assessment (DMA), which was aligned with the European Sustainability Reporting Standards (ESRS). This assessment identified the topics most material to TMF Group, and these topics are now fully embedded in our sustainability strategy. The full DMA results will be published in our 2025 Sustainability Report. 

Corporate governance and TMF Group's operating principles

We have integrated sustainability into our corporate governance framework to ensure strategic oversight, accountability and continuous improvement. At TMF Group, we assess our ESG maturity through annual EcoVadis assessments, which reflect the group’s commitment to responsible business practices. In 2025, we received a bronze rating from EcoVadis. By incorporating sustainability into our corporate governance framework, we guarantee that it remains a core strategic priority, in line with stakeholder expectations and regulatory developments.

Due diligence and corporate policies

We maintain a robust governance framework to ensure compliance, integrity and risk management across our global operations. Our policies and procedures are designed to uphold ethical business practices, protect sensitive information and guarantee business continuity. We communicate these policies through multiple channels, including a global policy library accessible via our intranet and mandatory training programmes for our employees.

Code of conduct

Our code of conduct is publicly available on our website and outlines TMF Group’s core values and commitment to integrity. The code establishes guiding principles for ethical business conduct and risk management, addressing areas such as anti-money laundering (AML) and combating the financing of terrorism (CFT). Employees must adhere to strict policies to prevent financial crime. To reinforce these principles, all employees must complete mandatory annual code of conduct training to ensure continuous awareness of, 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 and requires all employees to complete annual training on:

  • Respecting international sanctions

  • Preventing money laundering and terrorist financing

  • Countering bribery and corruption

Our internal audit function regularly validates the effectiveness of our compliance programme, ensuring that our policies and procedures remain robust and effective.

Data protection and information security

Due to the sensitive nature of our client services, information security and data protection are critical priorities. The audit and risk committee is responsible for overseeing cybersecurity and privacy risks and for ensuring that appropriate controls are in place. TMF Group has dedicated teams responsible for information security and data protection, who 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

This mechanism can be used by employees, clients, contractors, suppliers and any other stakeholders 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 have ended

In addition, health and safety is a key part of our risk management strategy, ensuring the well-being of our employees, clients and visitors in our offices.

Risk management framework

At TMF Group, we apply a comprehensive risk management framework to identify and reduce compliance, operational, reputational, financial and legal risks. Please refer to the risk management section of the director’s report for more details. This structured approach ensures transparency, accountability and resilience, thereby reinforcing our commitment to responsible business practices.

Environment

Our commitment to climate action

Climate action remains a key priority for TMF Group, reflecting the growing expectations of investors and our global client base. As we are part of the supply chains of many of the world’s largest corporate groups and investment firms, we recognise that their climate commitments increasingly require aligned action from partners. Through close collaboration with our clients, we aim to contribute to the broader effort to mitigate climate change and support long-term business resilience.

In order to understand and manage our climate impacts, we measure our greenhouse gas (GHG) emissions across scopes 1, 2 and 3. This involves tracking direct and energy-related emissions, as well as value chain emissions, using supplier data, activity-based information and financial records. We are also committed to the Science Based Targets initiative (SBTi) and intend to submit our emissions reduction targets in accordance with its guidelines. These insights will be presented in our 2025 ESG Sustainability Report.

GHG emissions and key sources

The majority of our emissions arise from purchased electricity in scope 2 and from scope 3 activities. Our scope 3 activities represent the majority of our footprint and are mainly driven by purchased goods and services, employee commuting and business travel.

Our climate strategy and emission-reduction initiatives

At TMF Group, we are strengthening our commitment to climate action by improving the way we measure, manage and reduce GHG emissions across our global operations. In 2024, we partnered with external advisers to develop a comprehensive emissions-reduction roadmap covering scopes 1, 2 and 3. This work has enabled us to identify the necessary investments and operational changes to align with the Paris Agreement's ambitions and prepare for the setting of science-based targets in accordance with the Science Based Targets initiative (SBTi). To reinforce the accuracy and consistency of our environmental data, we have started to implement a global carbon accounting platform that will enable the collection of high-quality, audit-ready emissions data across all TMF Group offices. This platform provides a unified foundation for calculating emissions and supports transparent disclosures as regulatory expectations continue to evolve.

Strengthening carbon reporting

Improving data quality remains a key priority. With global carbon accounting platform, we are strengthening the robustness of our GHG reporting processes to ensure that future disclosures reflect complete, accurate and verifiable emissions data across all scopes.

Engaging our supply chain

We recognise that a significant proportion of our overall emissions arises from purchased goods and services. To address this, we are expanding our collaboration with suppliers to build a more sustainable and transparent value chain. This includes: 

  • Mapping key categories of purchased services and identifying high‑impact suppliers

  • Engaging directly with major suppliers to collect emissions data and assess sustainability maturity

  • Integrating emissions intensity, transparency and climate‑related expectations into supplier selection and evaluation processes

  • Supporting suppliers with lower sustainability maturity through targeted guidance and education

Reducing office‑related emissions

Across our global operations, we are committed to reducing emissions from our offices. This involves identifying ways to improve energy efficiency, encouraging the purchase of renewable electricity in leased spaces where possible, and managing emissions related to employee commuting and remote working. We also promote low-carbon mobility options, such as public transport, cycling and carpooling. Additionally, our environmental policy provides offices with practical guidance on implementing sustainable operational practices, ensuring a consistent approach to environmental stewardship across regions.

Embedding sustainability in our operations

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 that 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, thereby 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 to achieve their professional goals is fundamental to our success, and we aim to be the employer of choice in our industry.

We have developed a five-pillar strategy for fostering great careers.

  • 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

Our employee satisfaction is reflected in our well-contained voluntary attrition (14%), strong colleague engagement (71%) and continuous Great Place to Work re-certifications.

Employee health and safety

As an office-based service provider, TMF Group does not encounter any significant health and safety risks. However, we uphold global standards to ensure a safe and healthy working environment for all our workforce.

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

In line 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, we are committed to upholding high ethical standards and combating all forms of labour exploitation.

Our modern slavery statement sets out 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 the Speak Up channels detailed in our whistleblower policy.

Diversity, equity and inclusion (DEI)

TMF Group promotes an inclusive working environment and rejects 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 undergo training in competency-based interviews and how to remove barriers for underrepresented groups.

In 2024, we launched new DEI initiatives through a global network of DEI ambassadors, with a focus on improving women’s representation in senior roles. By the end of 2025, 46% of our senior leaders were women.

The TMF Business Academy provides DEI training on topics such as unconscious bias, inclusive communication and anti-discrimination practices. We also run internal awareness campaigns that cover topics such as neurodiversity, religious holidays and LGBTQIA+ events.

Employee career development and training

The TMF Business Academy offers a wide range of training opportunities, tailored to both local and global needs. Employees can access training in the following areas:

  • Technical skills and business processes

  • Global and local regulatory standards

  • English language development

  • Mental health and well-being

  • Leadership and management development 

In 2025, 87% of our employees engaged in TMF Business Academy courses, with an average of 13 learning hours per participating employee (excluding mandatory e-learning courses). This reflects our commitment to continuous learning and ongoing professional development for our workforce. We deliver our training programmes through a combination of face-to-face sessions, virtual learning and self-paced courses, catering to a range of 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 called Beyond Boundaries, in partnership with Bridge for Billions. This programme connects TMF Group employees with underrepresented entrepreneurs across North America, Latin America, Europe and the Asia Pacific region, providing them with high-quality entrepreneurship training and mentorship. In November 2025, we launched the programme's third year, during which our colleagues will engage in a structured journey with entrepreneurs, enhancing their mentoring skills and sharing their expertise and knowledge.

In 2026, 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.

At TMF Group, we are dedicated to fostering an inclusive, supportive and socially responsible workplace. By continuously investing 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 CSR strengthens our reputation as a responsible employer.