ESG & DEI Policy

Cultura Creative Ltd — Environmental, Social, Governance and Diversity, Equity & Inclusion Policy

Last updated: August 2026

Our Purpose

Cultura Creative Ltd is committed to creating visual content and data responsibly, ethically and inclusively.

Our work spans photography, video, creative production and datasets for artificial intelligence and machine learning. We recognise that the images and data created today can influence how people, communities and the world are represented by future technologies.

We therefore seek to operate in a way that respects people, protects rights, broadens opportunity, reduces environmental impact and promotes responsible innovation.

Our Environmental, Social and Governance (ESG) principles and our commitment to Diversity, Equity and Inclusion (DEI) inform how we work with our employees, contributors, models, suppliers, clients and communities.

Environmental Responsibility

We recognise our responsibility to understand and reduce the environmental impact of our activities.

We aim to:

• minimise unnecessary travel and, where practical, use local production teams, contributors and suppliers;
• make responsible decisions regarding energy, equipment, materials, catering, transport and waste across our studio and location productions;
• favour reuse, repair and responsible procurement wherever practicable;
• reduce single-use materials and unnecessary consumption;
• use digital production and distribution systems efficiently;
• consider environmental impact when appointing suppliers and production partners; and
• progressively measure and reduce the environmental footprint of our operations as the business grows.

Our longer-term ambition is to reduce our carbon emissions in line with credible environmental best practice and to work towards net-zero operations. Any future carbon reduction, net-zero or offsetting claims will be based upon measurable evidence and appropriate recognised standards.

Social Responsibility

People are central to Cultura Creative.

We are committed to creating an environment in which contributors, models, employees, freelancers and partners are treated with dignity, fairness and respect.

We aim to:

• provide fair and inclusive opportunities for people from a broad range of communities and backgrounds;
• ensure that models, contributors and creative professionals participating in our productions are appropriately informed, contracted and compensated;
• support emerging and underrepresented creative talent;
• contribute to the creative and wider community in Sheffield and South Yorkshire while developing opportunities nationally and internationally;
• build long-term relationships with organisations and communities that expand access to creative opportunity;
• promote ethical, authentic and non-stereotypical visual representation;
• maintain safe, respectful and inclusive working environments; and
• encourage the professional development and wellbeing of our employees and collaborators.

Where appropriate, Cultura also supports community organisations and grassroots initiatives that help broaden participation and opportunity.

Ethical Content and Responsible AI

As a producer of visual content and datasets used in artificial intelligence and machine learning, Cultura recognises that we have responsibilities beyond conventional creative production.

We seek to ensure that datasets and content produced by Cultura are created ethically, transparently and with appropriate rights and permissions.

Our approach includes:

• obtaining appropriate model, contributor and property permissions;
• respecting copyright, intellectual property and creators' rights;
• providing clear information about the intended uses of commissioned content wherever reasonably possible;
• protecting personal data and respecting individual privacy;
• seeking diversity and representational breadth within datasets where relevant to the project;
• considering the potential for bias, stereotyping and exclusion when designing and producing datasets;
• maintaining appropriate provenance and production records;
• avoiding the knowing use of unlawfully obtained or improperly licensed content; and
• working with clients and partners who share our commitment to responsible and lawful data practices.

We believe responsible AI development depends upon responsible data creation.

Governance

Cultura Creative is committed to conducting its business ethically, transparently and responsibly.

Responsibility for ESG, DEI and ethical business practices sits with senior leadership and is incorporated into relevant business and production decisions.

Our governance principles include:

• compliance with applicable laws and regulations;
• responsible management of personal and confidential information;
• respect for copyright, intellectual property and contractual rights;
• appropriate information security and data governance;
• ethical and transparent business relationships;
• responsible financial management;
• appropriate management of conflicts of interest;
• zero tolerance of bribery, corruption, harassment, exploitation and unlawful discrimination;
• fair and responsible relationships with suppliers, freelancers and production partners; and
• review of policies and working practices as our business, technology and regulatory responsibilities evolve.

Where issues or concerns arise, we encourage employees and collaborators to raise them with senior management so that they can be considered and addressed appropriately.

Diversity, Equity & Inclusion

Diversity and representation are fundamental to Cultura's creative purpose.

We believe that the people who create images — and the people represented within them — should reflect the breadth of the society those images seek to portray.

We are committed to providing an inclusive environment and to treating people fairly regardless of age, disability, gender identity or gender reassignment, marriage or civil partnership, pregnancy or maternity, race, colour, nationality or ethnic or national origin, religion or belief, sex, sexual orientation, socioeconomic background or other personal circumstance.

We aim to:

• operate fair and inclusive recruitment and employment practices;
• broaden access to opportunities for people and communities historically underrepresented within the creative industries;
• build diverse networks of models, contributors, photographers, filmmakers and production professionals;
• make reasonable adjustments for disabled employees, contributors and participants wherever required and reasonably practicable;
• create working environments in which people feel respected and able to contribute;
• use inclusive and respectful language;
• challenge stereotypes and tokenistic representation;
• consider diversity and potential bias when creating, commissioning and curating imagery and datasets; and
• provide appropriate guidance and learning for our team on representation, bias, inclusive practice and ethical content creation.

All employment and recruitment decisions are made in accordance with applicable equality legislation. Where appropriate, Cultura may undertake lawful positive action to broaden participation and address underrepresentation.

Our Commitment

We recognise that ESG, DEI and responsible AI practice are ongoing responsibilities rather than fixed achievements.

As Cultura Creative develops, we will continue to review our impact, improve our practices and strengthen the standards by which we operate.

Our ambition is not simply to create compelling imagery and data, but to contribute to a creative and technological ecosystem that is more representative, responsible, sustainable and fair.

Cultura Creative Ltd
Sheffield, United Kingdom