Environmental, Social and Governance responsibilities and risks

Environmental, Social and Governance disclosures are often called sustainability disclosures. In a business context, sustainability refers to a Company’s business model and how its products and services contribute to sustainable development.

Some of the key reasons why Environmental, Social and Governance disclosures are important include:
1. They are a potential way of attracting investors.
2. They are a regulatory requirement under the IFPR.
3. They promote transparency.
4. They promote a sustainable business model.

Environmental:

Global production and consumption have a major impact on our environment. When producing or consuming products and/or services we contribute to climate change, waste, pollution, deforestation and bio-diversity.

For these reasons, Logistable is committed to reducing waste where possible. Logistable views environmental concerns as complementary to its business. To that end Logistable has:

• Increased its initiatives to reduce travel where possible with more extensive use of electronic communication.
• Additionally should travel on a private flight be required, Logistable strives, wherever possible, to ensure that it purchases empty return legs on flights that have been purchased by a third party and which use aircraft with a lowest possible carbon footprint.
• Logistable has committed to reducing its use of paper where possible and storing its client documentation and correspondence electronically.
• In partnership with our custodian banks Logistable is able to offer our clients Sustainable Investment opportunities should they wish to avail themselves of the opportunity.

Social:

Community

Logistable is active in the Gibraltar community and is a supporter of several local charities. Additionally we are sponsors of the Gibraltar Philharmonic Society.

Staff – Equal Opportunities

Logistable is an equal opportunity employer and is committed to a policy of treating all employees and job applicants equally.

To that end, the purpose of Logistable’s Employee handbook is to set the framework within which equality and fairness is established for its employees. Logistable does not tolerate discriminatory practices on the basis of race, colour, age, gender, gender reassignment, religion, national origin, sexual orientation, marital status or disability, or any other status in connection with the hiring, promotion, transfer, compensation, termination or any other terms and conditions of employment.

Logistable is also committed to maintaining an environment in which all members of staff treat all other members of staff at all times with dignity, consideration and respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees are encouraged and assisted in the development of their careers in order that they achieve their full potential.

Staff – Remuneration 

At present the gender pay gap for Logistable stands at 45.81%. Logistable is committed to ensuring that, where and when possible, this be reduced.

Logistable’s employees are paid annual fixed salaries and there are no employees that have their remuneration linked to the performance of the Company. There were no severance payments awarded during the financial years ended the 31st of December 2022 and 2023 and no severance payments have been awarded so far during 2024. 

Aggregated remuneration (including cash, shares, share-linked instruments and any other types of remuneration) whether paid in the year due or deferred and assessed as having been paid to those whose actions have a material impact on Logistable’s risk profile is as follows for the financial year ended the 31st of December 2023: 

As at and throughout the financial year ended the 31st of December 2023, including during 2024, Regulation 85(6) and/or (7) of the Financial Services (Investment Services) Prudential Requirements) Regulations 2021 has been applicable to Logistable. Additionally, because the criteria set out in Regulation 85(6) of the Financial Services (Investment Services) Prudential Requirements) Regulations 2021 has been met, Logistable has not been required to, and therefore has not established, a Remuneration Committee.   

Governance:

Risk Management Objectives and Policies

Logistable has a Low Risk Appetite across all of the activities/operations that it undertakes.

The Board of Directors of Logistable provide policy, oversight and review of its Risk Management Policies and Procedures. Additionally the Board has established a Risk Committee that has the authorisation to manage all aspects of risk policy and strategy for Logistable and supervise the on-going operation and monitoring of Logistable’s risk environment within the established risk framework and the Terms of Reference and Operation of the Risk Committee. The committee is led by the Head of Risk management and includes two executive directors. The Committee reports formally to the Board on its proceedings via the dissemination of the minutes of each meeting. The Committee’s met on three separate occasions during the year ended the 31st December 2023 and has met once so far in 2024. 

The Board annually reviews the activities, performance and terms of reference of the Committee to ensure that the Committee is operating effectively and instruct the Committee to make any changes it considers necessary.

Internal Governance Arrangements

Internal governance arrangements are the responsibility of the Board of Directors of Logistable and establish how both directors and staff conduct their day to day activities. These include;

• A simple, well defined, clear structure.
• Internal control functions including a compliance function and a risk management structure that have the necessary authority and resources to carry out their roles effectively.
• Clear management policies and procedures that ensure that the potential for Logistable’s actions or behaviour to harm its clients, itself or the broader market are mitigated
• Policies and procedures that ensure equality and fairness for all members of staff.

Internal governance arrangements encompass the ethical, moral and legal standards that govern business conduct and cover a wide range of behaviours and practices that could lead to negative outcomes. Therefore in today’s complex and highly regulated business environment, it is crucial for Logistable to understand and manage Conduct Risk. Logistable has a robust, effective and well-resourced compliance function that plays a crucial role in ensuring that Conduct risk is properly managed. The areas that most impact this are as follows;

• The Regulatory framework that governs business behaviour. Logistable through the on-going development and training of staff, as well as recourse to outside third party advisors, maintains its awareness of and understanding of the regulatory environment in which it operates.
• Logistable’s employees and the environment in which they operate is an important aspect of Conduct Risk. The Employee handbook provides employees with information about aspects of employment covering terms and conditions, policies and standards concerning their employment and training.
• Logistable’s employees are paid annual fixed salaries and there are no employees that have their remuneration linked to the performance of the Company.
• Logistable’s Conflict of Interests Policy sets out how Logistable will identify circumstances which may give rise to a conflict of interest. It establishes and maintains appropriate systems and controls to manage those conflicts in a fair and, in as far as possible, independent manner to prevent actual damage to a client’s interests through the identified conflict.
• Logistable’s Best Execution Policy sets out how, when receiving and executing client orders in relation to financial instruments, Logistable will endeavour to direct its best efforts to ensure that all reasonable steps are taken to act in the client’s best interests and that investment decisions are based on our professional knowledge and experience in the light of available market information and market conditions existing at that time.
• Logistable acknowledges that there may be occasions where its services do not fully live up to a client’s expectations. Logistable’s Complaints Policy and Procedures sets out how it manages complaints received from clients so as to ensure;
  • Complaint(s) are dealt with, with all reasonable dispatch and without prejudice to the right of the Client to contact the relevant authorities in Gibraltar.
  • The explanation provided is clear, concise and in a language that is familiar to the client(s).
  • Appropriate action to correct a deficiency or error, should it be deemed to be required, is taken in a prompt manner.

The Logistable Board 

The Board of Directors Charter is complementary to legislation governing the permissioned activities of Logistable and the Memorandum and Articles of Association of the Company. The Board of Directors Charter is a policy document that sets out the internal roles, responsibilities and authority of the Board of Directors both individually and collectively in setting the overall direction, supervision and control of Logistable. 

As an equal opportunity employer Logistable is committed to a framework within which the appointment of a director reflects diversity and equality and which is solely based on the aptitude and ability of that individual and whether they have the relevant experience to perform and undertake their role as a board member. At present Logistable is at its full contingent of directors as provided for by its Articles of Association however Logistable is committed to ensure that going forward, and  when the opportunity should arise to do so, the Board’s composition should reflect diversity, including in respect of the relevant business, geographic and academic background of the directors, as well as their racial and gender mix. 

The number of directorships held by each member of the Board, including their directorship held with Logistable, is as follows: 

Executive directors: 

The Chairman – Mr Pierre Felix Lavie: 3  
Director with responsibility for ML/TF Prevention responsibilities – Mr Joseph Nuñez: 15  
Finance Director – Mr Charles Fava: 2  

Non-Executive directors: 
Mr Dietrich Fuhrmann: 1 
Mr Thomas Bartholdi: 6