Responsible Lending Charter.

Sustainable and Socially Responsible Lending

October is committed to a Sustainable & Socially Responsable lending approach and signed the United Nations Principles of Responsible Investment in 2019.

Founded in 2014 in France with the mission to empower small and medium-size businesses to thrive by simplifying their funding, October now operates as a pan-European lending marketplace with offices in France, Spain, Italy, the Netherlands and Germany.

With a community representing more than 90 million jobs, small and medium-size businesses are the heart of the European economy. Our aim is to support the sustainable growth of this ecosystem by matching these companies with private and institutional lenders on a transparent marketplace where both sides have access to all data, selection criteria and portfolio statistics. Transparency is what makes the platform work in a fast, simple and responsible way.

Convinced that extra-financial factors contribute to sustainable growth, October is committed to a Corporate and Social Responsability^[1] approach and signed the United Nations Principles of Responsible Investment (UNPRI) in December 2019.
In 2020-2023, October will be actively working on its 3-year Environment, Social and Governance^[2] plan setting out our CSR policy and integrating ESG issues into our lending approach.

CSR Policy of October

Defined around environmental, social and governance (ESG) goals, our CSR policy aims to generate improvements by focusing on the most material issues for our activity.

Environment

To reduce our environmental footprint, we focus our action on the most impactful themes for October:

• Reduce or offset the greenhouse gas emissions generated by the conduct of our business
• Implement, support and promote good environmental practices as a signatory of the Climate Tech’Care Initiative launched in 2019 by a consortium of Tech companies committed to reducing their carbon emissions and environmental impact
• Strengthen our energy efficiency and opt for the use of renewable energy
• Reduce the consumption of paper and other office supplies
• Eliminate the use of disposable plastics & commit to recycling (waste, supplies, office equipment, furniture, etc.)

Social

Our human capital is one of our key strengths. To develop, grow and retain our talents, we focus our action on the following points:

• Promote gender equality, diversity and equal opportunities
• Ensure the employability of our team members via relevant and regular training as well as active management of their career paths
• Involve employees in the performance of October via a group-wide employee shareholding program
• Support health, safety and well-being of our employees

As a company, we engage in a transparent and constructive dialogue with our community of borrowers, private and institutional lenders as well as business partners via our blog articles, newsletters and financial education tutorials, and social media posts.

October is involved at the European level as well as in each country through relevant industry initiatives and working groups to keep improving the access to financing for European SMEs.

Governance

We strongly believe that good governance is essential to the long-term, sustainable growth of October. We choose to focus on the following points:

• Establish a responsible and ethical culture with a strong management of potential conflicts of interests
• Maintain clear separation between decision-making and supervisory functions
• Continuously strengthen our risk management
• Ensure ongoing compliance with laws, regulations and other commitments including the UNPRI
• Ensure protection, confidentiality and integrity of all data collected and processed as part of October’s activity

Implementation of ESG Criteria as a Sustainable Lender

Convinced that a systematic ESG analysis can help identify risks and value creation opportunities, we integrate extra-financial assessments in our investment process. With the goal to foster the growth of Sustainable and Socially Responsible Lending, we help our borrowers share their ESG approach and progress in their consideration of ESG issues.

In accordance with the commitments we made when signing the UNPRIs:

• We systematically take ESG issues into account in our investment analysis and decision-making processes
• We are an active lender who integrates ESG issues into its investment practices and encourages its community of borrowers to integrate ESG criteria and goals in their activity, in particular around the following themes:
  • employment
  • sustainable use of resources
  • human resources managed as the main wealth of the company
  • attention to suppliers and customers
  • positive impact on community
  • sound governance
• We commit ourselves to supporting our community of borrowers and help them increase their awareness of ESG relevant themes
• We ask our borrowers to share relevant information on their ESG approach and progress in their consideration of ESG matters
• We will publish an annual non-financial ESG report based on the data collected from our community of borrowers highlighting the progress made

[1] Corporate & Social Responsibility. CSR is the integration of social, ethical and ecological concerns into our business and our relationships with our clients, partners and stakeholders.

[2] ESG: Environment, Social and Governance – the three pillars of extra-financial factors.