Environmental, Social and Governance Policy
(Version 2.2 - Updated November 2024)
1. Introduction
1.1 Terms and Definitions
“we”, “us” and “our” refer to Data Zoo. “staff” and “users” means all of those who work under our control, including employees, contractors, interns etc.
1.2 Purpose and Scope
The purpose of this policy is to provide information about ESG (Environmental, Social and Governance factors) and Data Zoo’s policies towards ESG. This policy has been developed in consultation with the Data Zoo leadership team. This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.
1.3 Users and Responsibilities
The Data Zoo Executive Team has general responsibility for the efficient operation of this policy. They have delegated responsibility for overseeing its implementation to individual business units. Recommendations for any changes are stated to the Business Continuity and Disaster Recovery Steering Committee (BC&DR Steering committee). Business unit heads have ongoing responsibility for this policy and any questions about this policy should be referred to them in the first instance.
2. Data Zoo’s Commitment on Environment
2.1. CEO’s Message
“Year after year, I am proud to share our commitment to advancing Environmental, Social, and Governance (ESG) practices at Data Zoo. As a digital identity verification company, we understand the profound impact our operations can have on society and the environment. We are dedicated to nurturing a culture of responsible business practices that not only align with regulatory standards but also contribute positively to the communities we serve. Our focus on sustainability involves minimizing our carbon footprint through efficient operations, investing in renewable energy sources, and implementing responsible waste management practices. Data Zoo team recognizes the importance of social responsibility and equity in the digital identity landscape. We are committed to promoting diversity and inclusion within our workforce and ensuring fair and ethical practices in our technology solutions. By incorporating strong ESG principles into our core values, we aim to create a lasting positive impact on both our clients and the world at large.”
2.2 The Environmental Impact
The nature of the industry that we are operating in, does not have a high environmental impact, nonetheless, we continuously promote a work culture anchored in environment protection. Using third-party software, we have calculated our carbon footprint for our three main offices (Sydney (head office), Brisbane, and Melbourne, which represent the majority of our workforce), for the period of Dec 2023 to Dec 2024.
** **Table.1. Data Zoo Carbon Footprint December 2023-2024
Categories
tCO2e
Travel
78
Energy
66.7
Water & Energy
7.906
Food & Drink
20.5
2.3. Carbon Accounting, Paper and Plastic Usage Management
- In the interests of information security, Data protection and the environment, at Data Zoo, we have a strong preference for electronic communication and documentation. We minimise the use of paper for internal and external communication. The use of printed paper is strongly discouraged, however, when it is ultimately necessary, we ensure we use recycled paper and recycle paper once it is used, wherever it is used, in all of our offices.
- We use glass water bottles at all our offices, which has helped us steer clear of plastic usage.
- As part of the new-starter pack, each new staff member is provided an eco-friendly steel water bottle to limit usage of plastic/disposable bottles. This can be used both for hot and cold drinks.
- At all Data Zoo offices, the kitchens are stocked with re-usable dishes, cups, glasses and cutlery to lessen the use of disposable plastic.
- Kitchens are equipped with carbonated flavoured water machines to reduce employee consumption of similar beverages from cans.
2.4. Energy Consumption
Our offices are fitted with motion sensor lighting which restricts electricity consumption to only necessary usage. The Air conditioning system has sensible energy consumption in mind, as each room is equipped with separate heating control systems to ensure energy consumption only when the room is in use by staff.
For all Data Zoo purchases, low energy rating for products is taken into account, where applicable and All staff are encouraged to put their screens, workstations, and notebooks into automatic sleep mode when they are not used.
2.5. Recycling Bins
Kitchens, at all Data Zoo office locations, include multiple recycling bins to assist staff in separating landfill trash from recyclable materials. Furthermore, all office rooms are provided with separate recycling bins to encourage recycling among all employees.
**2.6. Travel **
Our business model factors in efficiency and cost/impact of travel into the selection of office locations and work/ travel arrangements. As a result:
- All of our offices are located in central Business Districts, which makes travel by public transport easier and efficient, resulting in very few employees and visitors driving to our premises.
- We encourage hybrid working for our employees, which reduces the need to travel every day and reduces our office footprint.
- Data Zoo is committed to offset staff carbon emissions caused by staff’s business travel. Carbon neutral flights are booked at all times, for all business-related travels for staff members.
3. Data Zoo’s Commitment to Social Responsibility
We are continuously looking for ways to give back to the communities in which we operate. In this vein, we have found opportunities for direct involvement in these communities by providing volunteer hours, financial support, and other resources to members within these communities so as to increase opportunity and access to prospects in our industry.
3.1. Education- Data Zoo PhD Scholarships
Data Zoo’s PhD scholarship program aligns with the company’s strategic goals and aims to strengthen Australia’s **STEM **talent pipeline and equip the workforce with the skills needed to fill the gap. Working collaboratively with universities, the PhD scholarship program combines an immersive STEM education with outreach activities. Scholarships are offered to doctoral candidates who undertake a higher degree by research and are enrolled at an Australian University, for projects that are in line with Data Zoo’s key research fields.
3.2. Community Investment- Woorabinda Project
We allocate a portion of our profits to reinvest in our communities, to drive towards a more inclusive and equitable future. In this regard, we started our Digi-Tech Initiative with the Woorabinda State School in 2021. Woorabinda (‘Woorie’), a remote town in Central Queensland is a small community of around 1,000 Indigenous Aboriginal and Torres Strait Islander people, many being youths. One of the biggest struggles for the younger population is maintaining a high enrolment and attendance rate for the school.
Data Zoo donated 30 laptops for the students at the Woorabinda State School. We empower the teachers with the necessary skills so they can support the learning and development of the children.
In 2021 our team instructed ‘digital literacy skills’ sessions each week to classes of students of the community in line with their curriculum. In 2021 the kids learned how to make a PTT and later in term 4 they learnt digital art skills.
The 2023 School year involved weekly sessions continuing Digital Literacy skills plus instructions in line with the “Data Changing our World” element of the curriculum.
In 2024, the Data Zoo Team will continue conducting lessons for school on a weekly basis.
We thank the Principal of Woorabinda State School, the teachers, support staff, Traditional Owners, Elders and especially the kids for giving Data Zoo this opportunity.
3.3. Compensation and Benefits
At Data Zoo, we prioritize the well-being and success of our team by offering a competitive remuneration package complemented by exceptional benefits.
In addition to a generous salary, full-time employees enjoy:
• Additional Paid Leave: Supporting work-life balance and personal needs.
• Weekly Bootcamps: Promoting health and fitness (Sydney office only).
• Quarterly Data Zoo Day Off: A dedicated day to recharge.
• **Paid Parental Leave: **Supporting families during important life transitions.
• Flexible Working Arrangements: Empowering you to work in ways that suit your lifestyle.
We also provide access to an Employee Assistance Program for confidential support in navigating personal or professional challenges.
To give our staff a sense of ownership and ensure long-term engagement, our **Equity Compensation Program **is among the most generous in the industry, giving employees a direct stake in our collective success.
3.4. Culture, Engagement and Growth
We create a fun, friendly work culture that promotes innovation and teamwork throughout the company. Every new employee is given a welcome pack which includes the business code of conduct and emphasises our core cultural values that we all strive to represent daily.
Senior leadership exemplify an **“open door policy” **where everyone is accessible. Staff are encouraged and given the opportunity to give honest feedback via annual performance reviews and appraisals, and employee engagement surveys. We organise employee appreciation events on a regular basis. Shout-outs and gratitude are expressed during our all-staff meetings at all levels throughout the year. Staff receive “Pillar Kudos” via slack. Regular dinners and social gatherings are also arranged throughout the year to build relationships between the staff and for all staff to encourage and express pride and gratitude together with a sense of belonging and ownership. We also seek to promote personal as well as professional development for staff through annual performance reviews, role-specific training and career development opportunities.
3.5. Health, Safety and Wellbeing
At Data Zoo, the health and safety of our employees, clients, and partners is our highest priority. We are committed to maintaining a safe and supportive environment by adhering to stringent health and safety standards across all teams and business units, as outlined in our Workplace Health and Safety Policy.
Our commitment extends to both physical and mental well-being, ensuring that everyone connected to Data Zoo can thrive in a secure and positive environment.
**3.6. Equity, Inclusion and Diversity **
Data Zoo embraces and values diversity in all its forms, regardless of gender, ethnicity, age or cultural origin. Equal opportunity is part and parcel of Data Zoo’s hiring procedure, as our goal is to build a community of diverse skills and talent.
For our executive and leadership teams, diversity extends beyond demographics to encompass a broad spectrum of business and industry expertise, experience, and perspectives. The executive and leadership team makes good use of these differences and distinctions among individuals to broaden the skill array and maximise staff utility.
To reflect the diversity of our workforce and operating environment, all executive and leadership appointments are made with consideration of merit, including skills, experience, independence, and knowledge. This ensures the leadership team has the competencies needed to drive success while fostering inclusivity. The current composition of our executive team, which highlights these commitments, is detailed in Tables 2.
Table.2. Executive Commitee Diversity Matrix
Total members
6
Gender Identity
Male
Female
Non-Binary
Gender Undisclosed
Members
4
2
-
-
Members who identify in any of the categories below
1
-
-
Asian
2
1
-
-
Black or African
-
-
-
-
Hispanic or Latino
-
-
-
-
Indigenous
-
-
-
-
Two or More Races or Ethnicities
-
1
-
-
White
4
-
-
LGBTQ+
-
-
-
-
3.7. Collaborations with Clients for Social Impact
Data Zoo invests in building and maintaining valuable partnerships across our internal teams, suppliers, clients, and broader stakeholders. We focus on collaboration both inside and outside our organisation that helps us maximise the progression of our ESG initiatives.
As part of this commitment, we integrate our clients’ Supplier Code of Conduct into our own, ensuring that ESG standards and principles are effectively upheld and propagated throughout the supply chain.
3.8. Communication and Messaging
Data Zoo is dedicated to maintaining transparent and consistent communication about ESG strategy with our staff and key stakeholders. This commitment is reflected through various initiatives, including:
• Sharing our Business Code of Conduct with employees to align our values and practices.
• Conducting regular **ESG training sessions **to promote awareness and accountability.
• Providing our Supplier Code of Conduct to clients and suppliers, promoting ESG standards across our network.
• Ensuring accessible and up-to-date ESG information is available on our website.
Through these efforts, we aim to embed ESG principles into every aspect of our operations, building a culture of responsibility and sustainability.
**4. Data Zoo’s statement on Ethical Governance **
Data Zoo’s focus is to promote strong oversight, transparency, and risk management at all levels of organisation, ensuring the resilience and long-term preservation of value for our business. We maintain strong corporate governance practises through exemplary board stewardship, management accountability, and proactive risk management. We cultivate strong stakeholder relationships through transparency, open communication, and responding to stakeholder input.
4.1. Security and Privacy at Data Zoo
We keep privacy and security of data at the core of our products, infrastructure, and policies. Our ecosystem lets our clients engender customer trust by ensuring data transparency, protection, privacy, and ownership.
Data Zoo has a dedicated GRC team, which is responsible for overseeing and managing our rich compliance framework. The GRC team continuously monitors and improves Data Zoo’s policies, manages enterprise risk management, and ensures compliance to relevant laws and regulations. We have established a strong privacy program guided by the global privacy principles. Data Zoo’s Global Privacy Program is aligned with organisational goals and objectives and has matured considerably over the years. Data Zoo’s Global Privacy Policy can be accessed here.
4.3. Supplier Relationships
In line with our commitment to ESG goals, Data Zoo views its suppliers and contractors as critical value chain participants. Data Zoo strives to make sure that our suppliers, partners, and vendors are also committed to sustainable business practices.
ESG assessment is part of Data Zoo’s annual vendor due diligence program. Data Zoo suppliers complete a questionnaire consisting of a list of questions covering environmental protection, social responsibility and governance, including quality management.
4.4. Employee Learning and Development
At Data Zoo, employee training, learning and development prospects are identified via the annual performance management process and through an organisation training needs analysis. Data Zoo offers learning and development under the broad categories of:
- Leadership – developing our managers and next leaders
- Technical/professional – role and/or function specific
- Organisational – relating to the sector and/or working effectively together
- • Governance, Risk and Compliance
4.5. Compliance
Our data processing strategy is grounded in a comprehensive risk assessment and aligns with globally recognized standards and frameworks, including ISO 27001, SOC 2 (Type II), SOC 3, ASAE 3150, ISO 30701, and CSA STAR Level 2. It also adheres to key regulations such as the Privacy Act 1988 (Australia), New Zealand Privacy Act 2020, GDPR, CCPA, PIPL, and Singapore PDPA, ensuring robust compliance across jurisdictions.
Data Zoo’s identity verification solution operates within a secure and well-defined regulatory framework, supported by strong policies that build trust in digital identity verification. These policies prioritize data protection, privacy, and accountability, reinforcing confidence in our services.
Our compliance framework clearly defines legal responsibilities and safeguards data subject rights, with regular audits conducted by qualified independent third-party auditors. Additionally, we meet all applicable legal and regulatory requirements for cross-border data interoperability, ensuring seamless and lawful data management across international boundaries.
**5. Data Zoo’s ESG Commitment **
As a business, we also have a duty to our people, our customers, and the wider world. ESG gives us an opportunity to meet those obligations and maximise the impact. We value investing in our people as we value protecting our environment and being a good corporate citizen.
Our vision to enhance our social and environmental accomplishment proves a robust, well-enlightened management mindset and a values-led culture that is both vigilant and sensitive to the challenges and opportunities of doing business, responsibly and sustainably.
6. Breach of Policy
We will take all necessary measures to remedy any breach of this policy including the use of our disciplinary or contractual processes where appropriate.
7. Records
Records retained in support of this procedure are listed in the ISMS Document Control and Improvements Register and controlled according to this ISMS Document Control Procedure.