ESG Policy

This Policy defines the principles, structure, and operational commitments that govern MKS Law’s approach to Environmental, Social, and Governance practices. It formalizes the integration of ESG standards into the firm’s internal operations, strategic positioning, and decision making processes. All provisions are binding, non discretionary, and applicable across all functions and levels.

Structure

This Policy is organized into sections that address ESG domains within MKS Law’s internal governance. It is designed for traceability, audit readiness, and integration into existing controls and workflows. This Policy applies in full across all areas and functions and is not subject to selective application.

Introduction and Commitment

MKS Law adopts ESG as an internal framework incorporated into its operational and managerial standards. The firm’s approach is grounded in governance, enforceability, and control, and is applied through internal management and oversight. ESG standards are applied as internal criteria for compliance, governance, and operational risk control. This Policy establishes mandatory standards in place of discretionary initiatives, and its application is required with the same rigor applied to internal compliance obligations.

ESG Governance

Responsibility for ESG rests with firm leadership. ESG matters are handled under the firm’s existing governance and supervision structure. Decisions, actions, and identified gaps may be recorded when relevant to internal control, institutional review, or third party requirements. Managers are expected to apply this Policy within their areas of responsibility and address deviations when identified. Non compliance with this Policy is treated as an internal matter and may lead to corrective measures.

Environmental Pillar

MKS Law applies standards related to environmental matters through general conduct expectations and reasonable measures compatible with its structure and operations. These considerations may inform internal choices on resource use, digital practices, and third party engagement where relevant to the firm’s activities. The firm may request related information from suppliers and service providers when required for institutional review or third party due diligence, and may record relevant items within its internal supervision framework.

Carbon and Climate Related Matters

MKS Law applies carbon and climate related considerations as part of its internal ESG framework, in a manner compatible with its structure and operations. Where relevant, such considerations may inform internal decisions concerning resource use, business travel, and engagement with service providers. Where required for client onboarding, third party due diligence, or other formal review processes, the firm may compile and maintain substantiated information regarding its carbon related practices. Any statement concerning carbon emissions, carbon related measures, or climate related practices must be accurate, supportable, and consistent with the firm’s actual records and implementation status. Carbon related exposure relevant to the firm’s operations or third party requirements may be addressed within the firm’s governance structure as an environmental and operational matter.

Social Pillar

Social commitments cover working conditions, equity, merit based structures, and professional safety. Recruitment, promotion, and leadership decisions must follow objective criteria and inclusive procedures. Harassment, discrimination, or any form of coercion or degradation are prohibited, regardless of intention or context. Teams must maintain a work environment that protects dignity and professional integrity. External relationships are expected to meet standards consistent with those applied internally.

Governance Pillar

Governance requires transparency, accountability, and documentation across decision making processes and supervision layers. Approvals, controls, and strategic actions must be recorded and traceable. Informal arrangements and discretionary processes are not permitted in areas subject to governance review. Failures of structure, supervision, or compliance are treated as internal risk and trigger corrective handling. Governance is applied through procedures and measurable standards.

Reporting and Transparency

Where ESG related information is communicated internally or externally under this Policy, it must be factual, consistent, and aligned with what the firm can substantiate at the time of disclosure. Communications must not be selective or promotional, and must not include distortion, omission, or concealment of relevant facts. Any ESG related statements issued on behalf of MKS Law must follow internal authorization parameters and remain consistent with this Policy.

Stakeholder Engagement

Engagement with ESG relevant stakeholders must follow formal procedures. This includes clients, suppliers, regulatory bodies, and institutional partners. Communications must be factual, documented, and aligned with internal standards. Only authorized individuals may communicate on ESG matters on behalf of the firm. Informal responses and unofficial statements are prohibited. Stakeholder expectations must be addressed through defined processes with traceability and substantiated records.

Compliance and Risk

ESG standards under this Policy are mandatory and apply across all functions and levels. Any material deviation must be escalated to firm leadership for review and handling. ESG related exposure may be treated as operational risk where it affects legal compliance, internal conduct, third party relationships, or institutional requirements. Where third party conduct creates relevant exposure, the firm may request clarification or take appropriate measures within the scope of its engagement.

Training and Implementation

All professionals must be familiar with the ESG standards set out in this Policy and apply them in their daily conduct and decisions where relevant. Guidance and clarifications may be issued by firm leadership, and any such guidance becomes applicable upon communication. Lack of awareness does not exempt any individual from responsibility under this Policy.

Annual Review

This Policy is subject to annual review and may be reviewed earlier if triggered by legal, institutional, or operational developments. Reviews are led by designated leadership and must result in a documented version under formal version control. Updates take effect upon communication and fully replace prior wording. Revisions must be distributed, stored, and auditable. Each department is responsible for ensuring internal alignment with the most current version.