Environmental and Social policy

1. Introduction

Mogo Auto Limited (“Mogo”) is part of Eleving Group, whose Environmental, Social and Governance (“ESG”) Strategy defines the sustainability priorities and impact areas that guide Mogo’ environmental and social (“E&S”) approach. Mogo recognizes that its operations and financing activities may give rise to environmental, social, governance, and related operational or reputational risks. Building on this foundation, Mogo has established the Environmental and Social Policy (“Policy”), which reflects Eleving Group’s sustainability principles while addressing the specific context of Kenya.

The Policy integrates E&S considerations as set out in the ESG strategy into both internal operations and financing processes and articulates company’s commitments to responsible, inclusive, and sustainable business practices in Kenya.

The Policy serves as the foundation for the Environmental and Social Management System (“ESMS”) which provides the operational means to implement these commitments. Collectively, the Policy and ESMS ensure that Mogo’s financing activities are undertaken in a responsible and consistent manner, aligned with both internal standards and external stakeholder expectations.

 

2. Purpose, scope, and applicability

The purpose of this Policy is to ensure that Mogo conducts its business responsibly by integrating E&S considerations into all internal operations and financing activities. It promotes environmental stewardship, safeguards employees and clients, and supports inclusive access to financial opportunities for communities.

Policy linkages
This Policy complements other frameworks at both Eleving Group and Mogo level. Where such policies exist - related to underwriting, debt collection, human resources, customer care, consumer protection or data protection - this Policy should be read alongside them. Together, these documents form a coherent framework that supports responsible business conduct and safeguards stakeholders.

 

3. Principles and commitments

3.1 Compliance with laws and standards

Mogo conducts all operations and financing activities in compliance with applicable Kenyan environmental, health, safety, and labor laws. In addition, where international standards exceed local requirements, Mogo shall endeavor to meet these standards to the extent practicable and consistent with Kenyan law including aligning its practices with the folowing:

• the International Finance Corporation (IFC) Performance Standards[1], including Performance Standard 2 on Labor and Working Conditions (2012)[2];
• the World Bank Environmental and Social Standard 9 (ESS9) for Financial Intermediaries[3]; and
• the International Labor Organization (ILO) Core Labor Standards[4].

Mogo’s approach is also aligned with Eleving Group’s ESG Strategy[5] and the United Nations Sustainable Development Goals (SDGs), ensuring that E&S management practices contribute to broader sustainability objectives and maintain consistency across all Eleving Group markets.

 

3.2 Environmental responsibility

Mogo recognizes the importance of environmental stewardship. The company is committed to identifying, managing, and monitoring environmental impacts associated with its operations and financing. It will take proactive measures to avoid adverse effects while promoting positive contributions, such as expanding access to climate-friendly products like electric vehicles, reducing electricity, paper, and water consumption, and supporting waste reduction and recycling wherever feasible and appropriate.

 

3.3 Social responsibility

Mogo views the well-being of employees, clients, and communities as integral to its business operations.

Internally, the company upholds respect for human rights and gender equality through fair employment practices, non-discrimination, and equal opportunities for professional growth. Mogo fosters an inclusive workplace that values diversity and ensures safe and decent working conditions for all employees. It is also committed to taking proactive steps to prevent accidents and occupational hazards and to promote a positive and productive working environment.

Externally, Mogo advances human rights, gender equality, and poverty reduction through its financing activities. The company supports job creation and entrepreneurship, particularly among micro, small, and medium enterprises and female-led businesses. Mogo also promotes road-safety awareness among clients and communities and supports financial-literacy initiatives that help clients to make informed borrowing decisions and strengthen long-term financial resilience.

 

3.4 Responsible financing and consumer protection

Mogo integrates E&S considerations into its underwriting and credit appraisal processes, applying credit-granting criteria to avoid clients or transactions with unacceptable risks and to prevent client over-indebtedness. E&S considerations are also embedded in debt collection practices.

 

As part of its commitment to responsible financing, Mogo also upholds consumer protection principles throughout the entire credit cycle:

1) Clients are treated fairly, transparently, and with respect — from loan origination to repayment and debt recovery;

2) Loan terms and charges are disclosed in advance to enable informed decision-making;

3) Customer data is safeguarded, and

4) Accessible grievance mechanisms are available to clients.

 

3.5 Governance, integrity, and transparency

Mogo maintains governance practices consistent with Eleving Group’s standards, emphasizing integrity, transparency, and accountability. The company promotes ethical conduct in decision-making to ensure that operations comply with applicable laws, internal standards, Eleving Group’s values, and internal philosophies. Mogo’s management structure supports the integration of E&S commitments in business processes and management oversight through defined responsibilities, regular reporting, and accountability mechanisms across departments.

Stakeholder engagement is conducted in a transparent and inclusive manner, respecting the rights, dignity, and culture of affected parties. Mogo actively fosters open dialogue and ensures that vulnerable or under-represented groups can participate in decisions in a free, prior, and informed way. Communication with investors, regulators, employees, clients, and other stakeholders is clear, accurate, and timely, reflecting the company’s commitment to ethical business conduct and trust-based relationships within Kenya.

 

3.6 Continuous improvement

Mogo recognizes that E&S impacts, expectations, and standards change over time. Accordingly, this Policy will be reviewed at least annually and updated as necessary to reflect changes in national legislation, investor requirements, and international good practice.

Mogo is committed to fostering a culture of learning and adaptation, ensuring continuous improvement through lessons learned, stakeholder feedback, and regular internal evaluations. Insights from these processes will inform updates to the ESMS and related procedures, ensuring that Mogo’s approach remains effective, proactive, and aligned with Eleving Group’s sustainability objectives.

 

4. Roles and responsibilities

The Board of Directors holds overall oversight of this Policy and the ESMS. The Country Manager, alongside the senior management team, is responsible for ensuring that the Policy is implemented effectively and that its commitments are communicated to both internal and external stakeholders.

Day-to-day implementation of this Policy is coordinated by the ESG and Impact Manager, who is responsible for ensuring the effective operation of the ESMS.

Department heads - including those in Operations, Human Resources, Marketing and Underwriting, Sales, Debt Collection, and Customer Care - are responsible for integrating E&S considerations into their respective areas of work.

All employees are expected to engage in provided trainings and apply the principles of this Policy in their daily work, contributing to a culture of responsibility and sustainability across Mogo.

 

5. Monitoring and reporting

Implementation of this Policy will be monitored through internal reporting systems and reviewed by senior management and the Board of Directors. Externally, Mogo’s E&S performance will be disclosed in a consolidated manner through Eleving Group’s Annual Integrated Report (Sustainability Statement), ensuring transparency to investors, regulators, and other stakeholders.

All measurable targets - including environmental, social, governance, and consumer protection objectives - are consolidated within the E&S Targets Table in ESMS. This table serves as the central reference point for tracking progress and accountability.

Mogo also commits to maintaining and monitoring accessible grievance mechanisms to ensure that complaints from employees, clients, and other stakeholders are addressed in a timely, fair, and transparent manner.

 

6. Communication

This Policy will be communicated to all employees through regular training and engagement sessions to ensure awareness and understanding. External stakeholders - including clients, investors, regulators, and communities - will have access to the Policy through Mogo’s website and relevant reports.

In this way, Mogo ensures that its commitments are transparent and that stakeholders are kept informed of its progress.