1.1 Introduction

EFG Holding and its direct and indirect subsidiaries (collectively, “EFG Holding Group” or “the “Group”) is a Leading Financial Institution with a Universal Bank in Egypt and the Leading Investment Bank in the Middle East and North Africa. As an intrinsic part of our commitment to Corporate Social Responsibility (CSR), we recognize that we have a responsibility to our shareholders and the societies where we work. 
 

Community engagement is a crucial aspect of our CSR activities and includes different initiatives designed for the benefit and development of community and society. This Policy lays down the guidelines for the identification, design, implementation, and monitoring of programmes of this type. Types of community engagement covered by this Policy can be found in Appendix II.
 
1.2 Backgound

At EFG Holding Group, giving back to the community is an inherent part of our culture. The Group as a whole and our team members individually have professional and personal stakes in the wellbeing of our communities. The Group demonstrates its commitment not only through its professional support of local business and economic growth, but also through its financial and in-kind sponsorship of a multitude of organizations, youth activities and non-profits. 

Community engagement activities shall encourage and nurture volunteering among employees with the objective of improving company morale, building more committed teams, and creating a connection to beneficiary communities. Giving back to the community increases feelings of well-being among colleagues and provides opportunities for growth, self-development, and increased self-confidence.
 
 1.3 Purpose

The purpose of this Policy is to provide principles and a governance framework for community engagement aligned to the strategic priorities of EFG Holding Group and in fulfilment of our Social Purpose of “leveraging our financial expertise and capitalizing on our human talent to create sustainable value for our stakeholders and the communities we serve.” 
This Policy also sets out the proper process for compliance and gaining authorisation for community engagement programmes, initiatives or contributions. These processes must be followed by all EFG Holding Group employees pursuing any form of community engagement (See Appendix II).
The eligibility of community engagement activities shall be determined via a relevant combination of the following criteria:
1.    Alignment with Group values and objectives: community engagement activities should have goals that align with the values and objectives outlined in section 1.3.1.
2.    Clear community need and relevance: community engagement activities should be able to demonstrate how they fulfil or support a need in the community in which they are set.
3.    Due diligence or KYC on partners: all organisations with which EFG Holding Group is involved for the purposes of community engagement activities must be described within the form included in Appendix I. This will enable the Group Chief Compliance Officer and Group Chief Sustainability Officer to indicate if they require further due diligence be undertaken to confirm eligibility, with the scope and depth of such due diligence to be conducted in accordance with EFG Holding's AML & CFT Policy. 
4.    Avoidance of conflicts of interest or political affiliations: community engagement activities should not expose EFG Holding Group or any of its employees to conflicts of interest.
5.    Politically Exposed Persons (PEP): PEP relationships must be approved by Group Chief Executive Officer and Group Chief Risk Officer before establishing or continuing the business relationship, and this approval must be and documented, in alignment with EFG Holding’s Politically Exposed Person Policy.

1.3.1 Alignment with Group values and objectives
Community engagement activities shall be aligned with the UN’s Social Development Goals (SDGs) and the United Nations Global Compact (UNGC) and designed according to the following general principles: 
SOCIAL IMPACT 
•    Address tangible issues facing the communities we serve and deliver positive impact. 
•    Reach out to the wider spectrum of the population, especially disadvantaged and underserved sectors. 
ENVIRONMENTAL IMPACT 
•    Embrace a precautionary approach to environmental challenges. 
•    Undertake initiatives that promote greater environmental responsibility. 
•    Prioritise the development and use of environmentally friendly technologies. 
GOVERNANCE 
•    Ensure ethical conduct and compliance with all applicable quality control, legal, regulatory and risk management requirements. 
 

2.1 Policy Scope

This Policy shall apply to all subsidiaries, business lines, and departments involved in any form of community engagement across all offices and locations under EFG Holding Group. 
This includes the three verticals that make up EFG Holding Group: the Investment Bank (EFG Hermes), the NBFI (EFG Finance) and the Commercial Bank (Bank NXT), including their subsidiaries and any future acquisitions. Each vertical must abide by the centralised authorisation process outlined in this Policy.
Affiliates of EFG Holding Group may adopt this Policy or may maintain separate community engagement policies, provided that the provisions of such policies are consistent with the principles and requirements set forth herein. 

2.2 Governance, approval and responsibility for this Policy

The Corporate Sustainability & Impact (CSI) department is the owner of the Community Engagement Policy and is responsible for distributing the Policy to all EFG Holding Group’s employees and other relevant stakeholders. The CSI department is tasked with ensuring that EFG Holding Group subsidiaries are aware of the Policy and that any updates and changes are communicated. 
It is the responsibility of all subsidiaries to understand their commitment to abide by this Policy as well as all other existing EFG Holding Group policies. 
The Policy will be reviewed on an annual basis or as and when required, whichever occurs earlier.
The Board of EFG Holding Group is responsible for the approval of this Policy, and for approving any updates or changes to this Policy. 
Senior Management and all employees are responsible for ensuring adherence to this Policy. Failure to comply with the provisions of this Policy may result in appropriate corrective or disciplinary action, in accordance with internal HR procedures.

2.3 Approval process for initiatives, programmes and contributions

Authorisation for any initiatives, programmes and contributions must be granted by the Group Chief Compliance Officer and the Group Chief Sustainability Officer.
Authorisation at the business unit level does not constitute sufficient authorisation. 
Authorisation may only be granted through completion and subsequent sign-off of the accompanying request form (see Appendix I) by the Group Chief Compliance Officer and Group Chief Sustainability Officer.
The authorisation process is outlined in the below steps:
1.    Request form completed by the party requesting authorisation.
2.    Request form is submitted via relevant department head to the Group Chief Sustainability Officer and Group Chief Compliance Officer. The request form must be filed before the planned commencement date of the initiative, programme or contribution.
a.    Department and Business line heads must keep an accurate record of all community engagement activities undertaken by those in their department. 
3.    The relevant Compliance team of the business line will be responsible for conducting all due diligence and screening on the partner / organization as required by the Group's AML & CFT Policy.
4.    Approval for any partner identified as a Politically Exposed Person (PEP) must be granted by the relevant business line's Senior Management as required by the Group’s PEP Policy.
5.    Approval decision made by Group Chief Sustainability Officer and Group Chief Compliance Officer.
6.    If, during an initiative, programme or contribution, a significant change occurs to the scope, parties involved, resource requirement or goal of the engagement, reapproval must be sought from the Group Chief Compliance Officer and the Group Chief Sustainability Officer via the above process.
On an annual basis, department and business lines heads must submit to the Group Chief Sustainability Officer, a list of all initiatives, programmes and contributions undertaken by their department or colleagues employed within their department. This record should be kept per item 2a in the above process.
It is the responsibility of the Group Chief Sustainability Officer to cross-reference this annual list with the CSI department’s list of initiatives, programmes and contributions that have been approved via the above official process. This is to ensure no unauthorised activities have taken place within the year.
 

2.4 Acknowledgements, Escalations and Consequences for Non-Compliance

All EFG Holding Group employees and relevant stakeholders involved in community engagement activities are required to read and acknowledge their understanding of this Policy. The CSI Department shall ensure that appropriate awareness and communication mechanisms are in place to facilitate this process. Heads of business lines and departments are responsible for ensuring that all employees under their supervision have read and acknowledged this Policy.
Any instance of non-compliance with the provisions of this Policy, including failure to follow the approval process, engage in due diligence, or report activities accurately, shall be considered a breach of Group policy. Such breaches must be escalated to the Group Chief Sustainability Officer and Group Chief Compliance Officer for appropriate review.
Consequences for non-compliance will be determined based on the nature and severity of the breach and may include revocation of project approval, internal disciplinary action in line with HR policy, or further escalation to Group Senior Management and the Board, where appropriate.