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PILLAR 3: CORPORATE PERFORMANCERisk ManagementESR Group LimitedEnvironmental, Social and Governance Report 202477Automated Counterparty Due Diligence WorkflowCASE STUDYLaunch of ComplyESRIn 2024, Group Compliance collaborated with an external vendor to launch ComplyESR, our new in-house compliance and risk management system, designed to streamline and simplify compliance-related tasks for all ESR employees. This in-house system replaced ComplySci%u00ae for the submission of all compliance certifications and preclearance requests.ComplyESR allows all employees to submit preclearance requests by simplifying requests for security trading, gifts and entertainment, charitable donations, conflicts of interest and outside business affiliations. It also enables employees to stay informed and track active compliance discussions. The system provides multiple approval channels where supervisors will be able to approve the requests, view data records and managed brokerage accounts through the various online platforms including TEAMS, email or the PowerApps itself. The user-friendly interface also enables employees to navigate intuitive menus and tools, allow automation by reducing manual effort with streamlined workflows and provide transparency where employees can track the status of their certifications and preclearance requests in realtime.Group Compliance also prepared a user guide and developed a set of training videos which cover the key features of ComplyESR, including the steps involved for completing the annual certification and obtaining preclearance approval.Pre-due diligence screening %u2022 Data collection and automated screening ofresponses from counterparties%u2022 Responsibility of screening falls on the BusinessUnit Managers%u2022 Monitoring via Worldcheck, the Screening & DueDiligence database by LSEG%u2022 Approval of counterparties subject to renewalevery 24 months%u2022 Due Diligence reports are generated from LSEG%u2022 Initiated and overseen by Legal and ComplianceteamsDue diligence investigationPost-due diligence monitoring2 This represents the total number of screened counterparties in 2024 to-date, which includes 2,416 suppliers.Key Performance Indicators%u2021 Politically Exposed Persons, Relative or Close Associates, State Owned Entities and State Invested Entities3 Risk Buckets containing 67 Specific Risk Areas assessed%u2022 Official lists covering sanctions, watchlists, regulatoryand enforcement lists%u2022 Political exposure covering PEPs, RCAs, SOEs and SIEs%u2021%u2022 Structured adverse media which covers an extensive listof risk areas including fraud, insider trading,cybercrime, bribery and corruption%u2022 Environmental and social risks8,3102Counterparties by geographiclocation AustraliaChina China, Hong KongIndia3,437 2,454 313442Japan South Korea Singapore Vietnam, Indonesia &Thailand918 458 25632