Environmental, Social & Governance (ESG) Policy

1) Overview

Southwind Holdings (Pvt) Ltd and its subsidiary brand Hurtle Digital (“Southwind Group”, “we”, “us”, “our”) are committed to responsible business practices that support long-term value creation and ethical operations.

This ESG policy reflects key commitments across integrity, human rights, labour standards, inclusion, environmental sustainability, community impact, and corporate governance.

2) Environmental Responsibility

We aim to minimize our environmental impact through practical and measurable actions, including:

• Compliance with applicable environmental laws and regulations.
• Reducing energy use, emissions, and waste.
• Encouraging sustainable suppliers and digital-first practices (including within Hurtle Digital operations).
• Continuous improvement in environmental performance.

3) Social Responsibility

Human Rights & Labour Standards

• No child labour, forced labour, bonded labour, or exploitative practices.
• Equal opportunity and non-discrimination.
• Fair wages, reasonable working hours, and safe working conditions.
• Freedom of association and respectful workplace culture.

Diversity, Equity & Inclusion (DEI)

• Merit-based recruitment and career progression.
• Zero tolerance for harassment or discrimination.
• Equal pay for equal work and inclusive leadership.

Health, Safety & Well-Being

• Risk identification and mitigation.
• Promotion of employee physical and mental well-being.
• Compliance with occupational health and safety standards.

Community Engagement & Social Impact

• Support education, skills development, and innovation.
• Align initiatives with national priorities and UN Sustainable Development Goals.
• Transparent, non-political community engagement.

4) Governance & Ethics

Code of Ethics & Business Conduct

• Act honestly, fairly, and responsibly in all business dealings.
• Comply with applicable laws and regulations.
• Avoid conflicts of interest and disclose potential conflicts.
• Zero tolerance for bribery, corruption, or unethical inducements.

Anti-Bribery & Anti-Corruption

• No bribes, facilitation payments, kickbacks, or improper gifts.
• Due diligence on clients, suppliers, and partners.
• Transparent procurement and contracting processes.

Whistleblower Protection

• Confidential reporting channels.
• Protection against retaliation.
• Fair and impartial investigation of concerns.

Corporate Governance & Accountability

• Clear roles and responsibilities at Board and management levels.
• Risk management and internal controls.
• Transparent reporting to stakeholders.

5) Data Protection & Information Security

We protect personal, client, and organizational data through:

• Lawful, fair, and transparent data processing.
• Data minimization and purpose limitation.
• Secure storage, controlled access, and breach response.

For Meta-related data handling and deletion instructions, see: Meta App Privacy Policy.

Open Privacy Policy

6) Policy Oversight & Review

All policies are approved by Group Management and reviewed periodically to ensure alignment with international best practices, regulatory requirements, and the evolving business environment.

Approved By: Southwind Group Management
Effective Date: 2025-01-01

7) Contact

For ESG inquiries or policy-related questions:

• Company: Southwind Holdings (Pvt) Ltd
• Brand: Hurtle Digital
• Email: hello@southwindholdings.co
• Phone: +94 76 144 6262
• Country: Sri Lanka