Overview

By developing and implementing this ESG framework, Flutterwave aims to demonstrate its commitment to environmental sustainability, social responsibility, and strong corporate governance while creating long-term value for all stakeholders. This framework also aims to help Flutterwave understand how Flutterwave can manage risks and opportunities related to ESG factors.

This policy is intended to align Flutterwave’s business and operational objectives with the national and international ESG standards/ principles as well as the Sustainable Development Goals (SDGs), mandates of the Central Bank of Nigeria, Securities and Exchange Commission, and relevant global environmental, social, labor, and biodiversity conventions ratified by Nigeria.

We have based Flutterwave’s ESG framework on the Global Reporting Initiative (GRI). The GRI is the most flexible ESG Framework, making it ideal for companies starting their ESG journey, as it forms a solid basis for reporting over time.

In addition, Flutterwave is incorporating the International Sustainability Standards Board (ISSB) International Financial Reporting Standards (IFRS) S1 and S2 into its ESG reporting framework. This aligns with Nigeria’s Financial Reporting Council Roadmap Report (March 2024), which encourages proactive adoption of these standards before the mandatory reporting window in 2028. This approach aligns with global best practices, and allows Flutterwave to refine its reporting systems in advance of full compliance.

Additional Regulatory Frameworks that were considered include:

CBN Sustainable Banking Principles: These emphasise sustainability reporting and disclosures for transparency and accountability in the banking sector.

Nigerian Exchange Group (NGX Group) Sustainability Disclosure Guidelines: These provide a framework for listed companies to disclose their ESG performance.

Nigerian Sustainable Finance Principles: Issued by the Securities and Exchange Commission of Nigeria, these require public interest/listed entities to integrate ESG considerations in their operations.

Relevant Nigerian ESG legal frameworks: Including the Climate Change Act 2021, Environmental Impact Assessment Act 1992, National Environmental Standards and Regulations Enforcement Agency (NESREA) Act 2007, NDPR 2019 & 2023, Employee Compensation Act 2010, Nigeria Code of Corporate Governance 2018, among others.

Goals

1. Create a thorough understanding of our stakeholders’ expectations and guidance for the development of our sustainability framework.
2. Establish a framework for Flutterwave’s long-term ESG Goals.
3. Highlight and communicate Flutterwave’s social impact.

Scope and Application

This Policy will guide all of Flutterwave’s business activities and applies to our operations in Nigeria. While ownership and ultimate responsibility for the review of this policy rests with the Board, the development of this policy is the responsibility of the Regulatory team.

This policy is essential for providing long-term value to our clients and partners. Flutterwave seeks to align its strategic business objectives with the ESG pillars in this Policy. Flutterwave’s ESG Policy has been designed in consonance with the applicable national laws/ regulations and is aimed at ensuring ESG-compliance through our activities.

Our Business

Flutterwave is Africa’s leading payments infrastructure for enterprises, large local corporates, small businesses, and consumers; enabling transactions domestically, regionally, and globally. Our ambition is to be the digital payments infrastructure that connects Africa and the global economy.

Flutterwave’s payment processing platform replaces multiple payment integrations with one, connecting banks, card networks, mobile wallets & other payment providers, across multiple countries and currencies. Our core payments infrastructure powers a range of use cases branded under 2 distinct products: Flutterwave for Business, through which merchants and businesses receive cross-border payments, and Send App which facilitates remittances.

Our management team combines innovators, business builders, and leaders from global financial services companies. Our shareholders consist of global investment firms and strategic investment arms of large, diversified payments companies.

Environmental and Social Risk Management

Flutterwave will implement procedures for managing Environmental and Social Risk issues, with clear roles and responsibilities assigned to relevant staff. These procedures may be adjusted over time to address any changes.

A comprehensive ESG risk reporting framework will be developed, including the collection of quantitative data on client engagements assessed for ESG risks, categorized by risk type, sector, and financial product.

The ESG management system will be reported annually in Flutterwave’s Sustainable Banking report. Long-term targets will focus on tracking the percentage of clients screened for ESG risks, measuring the impact mitigated, and monitoring improvements in ESG ratings over time.

This framework will align with IFRS S1 and S2, ensuring that governance, strategy, risk management, and metrics and targets are incorporated into our approach to environmental and social risk.

Additionally, Flutterwave will document cases where ESG engagement has led to positive outcomes for clients and will organize events to raise awareness of ESG risks. Client feedback will be used to measure progress and inform future initiatives.

Reporting

Flutterwave will create a reporting template that aligns with the criteria set by the Central Bank of Nigeria (CBN) and other relevant regulatory bodies. Flutterwave will set clear targets and milestones in line with the CBN’s Sustainable Banking Principles and other relevant policies, establishing performance indicators to track progress and ensure continuous improvement.

In addition, Flutterwave’s reporting will integrate the disclosure requirements of IFRS S1 and S2 standards. IFRS S1 focuses on governance, strategy, risk management, and metrics and targets for sustainability-related risks and opportunities, while IFRS S2 outlines disclosures specific to climate-related risks and opportunities. These will be embedded into Flutterwave’s ESG reporting structure, ensuring consistency with global investor expectations and enhanced transparency.

To measure its performance, Flutterwave will gather data and conduct internal audits to assess the effectiveness of its ESG structures and procedures. Additionally, an independent third-party review will evaluate the company’s internal reporting system and data collection processes.

Annually, Flutterwave will report to external stakeholders on its progress in implementing the CBN’s principles and other applicable policies. These reports will adhere to the Global Reporting Initiative Financial Sector Supplement, as well as the ISSB’s IFRS S1 and S2 requirements, and where necessary, third-party assurance will be sought to ensure the accuracy of the external audit process.

Collaborative Partnerships

Flutterwave will maintain continuous engagement with the CBN Bankers’ Sub-Committee on Economic Development and Sustainability to promote sector-specific or issue-based initiatives.

Flutterwave will also collaborate with policy partners like ABC and other industry stakeholders, such as the ACT Foundation, to advance its ESG initiatives. Flutterwave will also cultivate active collaboration with the Financial Reporting Council of Nigeria’s Adoption Readiness Working Group (ARWG) members, including the Financial Reporting Council (FRC), NGX, ISSB, SEC, and the National Council on Climate Change. Regular meetings and capacity-building workshops will be held to support the ongoing implementation of the Pillars.

Additionally, Flutterwave will make meaningful, public commitments to leading global standards and actively participate in relevant international initiatives that align with its core business activities and operations that are consistent with the Pillars.

Environmental and Social Footprint

Flutterwave will develop an ESG footprint management program to address environmental and social issues within its business operations. This program will cover areas such as climate change, greenhouse gas reduction, water efficiency, waste management, and facilities, as well as labor, health and safety, and human rights standards. Best practices will be drawn from frameworks like ISO 14001, the UDHR, and the International Labour Organisation. The program and associated reporting framework will also align with IFRS S1 and S2 to ensure climate-related risk disclosure and sustainability transparency.

Key roles in procurement, vendor management, facilities management, communications, human resources, and other relevant departments will be identified to help develop ESG policies, procedures, and the management program. An implementation plan will be created to roll out the environmental management program, followed by ongoing implementation.

In addition, Flutterwave will establish a community investment program, supported by senior management, to ensure the bank's resources generate long-term positive impacts aligned with national development goals. Third-party E&S standards will also be developed to manage risks and potential impacts related to suppliers, contractors, and other third-party service providers. The company will create an initial implementation plan for these standards, with ongoing monitoring and application thereafter.

To track progress, Flutterwave will develop an ESG footprint reporting framework, including quantitative data on continuous improvements in its ESG footprint management, aligned with the Global Reporting Initiative standards. The ESG footprint reporting framework will particularly track digital infrastructure energy efficiency, data center emissions, and overall carbon footprint tracking and reduction.

The community investment program’s reporting metrics will include contributions in human capital, time, financial, and other resources. Additionally, third-party ESG standards reporting will provide information on the number of suppliers, contractors, and service providers assessed and the standards applied. ESG footprint progress will be reported annually as part of Flutterwave’s ESG report.

Capacity Building

Flutterwave will focus on raising internal awareness of ESG principles and practices and develop training programs across relevant management levels, commercial teams, and mid- and back-office functions.

Flutterwave will implement training and education systems, tools, and resources to improve awareness of ESG principles, integrating these into our learning, development, and onboarding curricula. To ensure employees are incentivized to meet ESG-related responsibilities, Flutterwave will align ESG metrics with existing performance management indicators.

Flutterwave will also collaborate with industry sectors and shared learning platforms to create awareness and promote the practical implementation of applicable standards and practices for its personnel.

Additionally, Flutterwave will consider developing ESG training and assessment tools to maintain consistency in the application of standards and practices at the sector level. We will also have regular engagement with relevant third parties that will help build sector-wide capacity and skills. Participation in Sustainable Banking Communities of Practice will further enhance this initiative. Flutterwave may also establish a Board-level Sustainable Committee to oversee the development and implementation of ESG commitments and initiatives.

Financial Inclusion

Flutterwave will develop a financial inclusion policy aligned with the CBN Financial Inclusion Strategy alongside other relevant frameworks, which will focus on supporting SME development and growth, promoting financial literacy, and enhancing consumer protection in line with the CBN’s consumer protection framework.

The policy will set a target for a minimum of 30% female staff representation, encourage female management, and offer tailored women’s entrepreneurship development programs. It will also drive innovation to improve accessibility and usage of the financial system.

To track progress, Flutterwave will create financial inclusion reporting criteria consistent with CBN guidelines, including data on the number of disadvantaged groups supported, investment or loan levels by state location, the uptake of new or innovative products, the number of previously unbanked individuals brought into the banking system, and the number of individual and SME accounts held with Flutterwave. Financial inclusion progress will be reported annually as part of Flutterwave’s ESG report.

Women’s Economic Empowerment

Flutterwave will develop a women’s economic empowerment policy, integrated into its broader ESG framework, aligned with the CBN Women’s Economic Empowerment Strategy. The policy will aim to promote gender equality by focusing on two key areas: economic empowerment of women through access to financial services, and promoting gender diversity within the workplace. An implementation plan will be developed to establish and roll out the policy’s requirements, followed by ongoing implementation.

Flutterwave will also create reporting criteria to track progress, including data on female representation across business units, management levels, and the Board, as well as total investment made towards female employees and the number of women’s economic empowerment programs in place. Progress will be reported annually in Flutterwave’s ESG report.

A dedicated women’s economic empowerment committee, consisting of senior leaders across the business, will be set up to oversee these efforts, ensuring responsibility for promoting gender equality both in the workplace and within society.

Human Rights

Flutterwave will develop a human rights policy, integrated into its broader ESG framework, ensuring alignment with the United Nations Declaration on Human Rights, the Nigerian Constitution, and local law. The policy will also adhere to best practices, including the UN Guiding Principles on Business and Human Rights. To support this, Flutterwave will develop and implement human rights due diligence procedures and tools to assess, screen, and integrate human and labor rights considerations into its business decision-making processes.

Clear roles and responsibilities will be defined for applying human rights standards across the company's operations. A grievance and dispute mechanism will also be established to handle any related issues. An implementation plan will guide the initial rollout of the human rights policy, with ongoing implementation thereafter.

Employees will be trained on human rights issues, and policy owners will be sufficiently trained on their implementation responsibilities. Reporting metrics will include data on the level of investment and the number of employees trained. Flutterwave will commit to international initiatives, such as the United Nations Global Compact, and adhere to standards like Anti-Money Laundering (AML) and Anti-Trafficking regulations.

Human rights risk reporting will include data on the number of clients and engagements assessed for human rights risks, with progress reported annually as part of Flutterwave’s ESG Report.

Governance

Flutterwave has a structured Anti-Bribery and Corruption policy reflective of its opposition to all forms of bribery and corruption and articulating the control framework in this respect.

This policy is communicated to all employees and business partners of Flutterwave to ensure their knowledge of, and commitment to it. Flutterwave applies a zero-tolerance approach to acts of bribery and corruption by any of our employees or by business partners working on our behalf.

Flutterwave is committed to ensuring adherence to the highest legal and ethical standards and all national and international anti-bribery and corruption laws. It is our policy to conduct business in an honest way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.

There are several steps Flutterwave has taken to assist in the prevention of bribery and corruption:

1. Risk Assessment: Effective risk assessment lies at the core of the success of this policy. Risk identification highlights the specific areas in which Flutterwave may face bribery and corruption risks and allows us to better evaluate and mitigate these risks. Management will assess the vulnerability of each business unit to these risks on an ongoing basis.
2. Clear, practical and accessible policies and procedures: All Flutterwave staff are circulated with the policy and made aware of the associated procedures. These will be accessible at all times to employees.
3. Effective monitoring and review: It remains the responsibility of each staff member to be vigilant to the risks of bribery and corruption and closely monitor and review transactions and make reports where necessary. Each staff member will be responsible for reporting any suspicions to the Risk and Compliance Director and to the CEO/MD in line with the whistleblowing policy discussed in the next section.
4. From a governance perspective, the Anti-Bribery and Corruption Policy is subject to annual review by Flutterwave and presented annually to the meetings of the Board Risk and Audit Committee for review and reapproval. This submission includes confirmation of the circulation of the policy, that staff have received appropriate training during the year which is reinforced as part of the Bank’s corporate governance strategy during staff briefings presented by the CEO/MD and executive management, and also that systems and controls currently in place to mitigate risks attached to the Bribery Act 2010 are considered to be adequate.
5. In addition, Flutterwave will ensure that governance disclosures as outlined in IFRS S1 are met, including oversight of sustainability-related risks and opportunities, the role of management, and the processes by which sustainability governance is embedded across the organization.

Cyber Security and Information Security

Flutterwave, guided by its Cyber Security and Data Protection Policies, has established a comprehensive and robust mechanism in place to ensure the highest degree of data protection. Flutterwave, guided by Information Security Policy, shall continue to adhere to the principles of Confidentiality, Integrity and Availability with respect to information security.

A Board-level Committee oversees effective implementation of data privacy and information security in the Bank.

Flutterwave’s cybersecurity and information security governance will also align with IFRS S1 risk management requirements by disclosing how these risks are identified, assessed, managed, and integrated into the company’s overall risk processes. Flutterwave will also incorporate IFRS S2 climate-risk considerations related to digital infrastructure, data center emissions, operational resilience, digital infrastructure energy efficiency, green data centres, carbon footprint tracking and reduction.