A practical, proportionate plan on Environmental SocialGovernance (ESG) for an agile microenterprise delivering high-trust professional legal services. Published December 2025
About Us
Enigma Legal Ltd is a specialist legal services provider dedicated to supporting managers and coaches within the sports industry. Our unique structure brings together a panel of expert barristers, all with extensive experience in sports law and advisory work, particularly through their involvement with the League Managers Association. As an SRA-regulated firm, we combine professional integrity with sector-specific expertise, offering trusted guidance to clients navigating complex contractual, regulatory and governance challenges.This sports-industry focus means our ESG commitments are not abstract: they directly reinforce the values of integrity, safeguarding, and duty of care that underpin professional sport and public trust.
1. ESG Vision
Enigma Legal Ltd is committed to operating as a responsible, ethical and transparent partner. Our ESG ambition is to cultivate a business that is:
• Inclusive and respectful, enabling equitable access, fair treatment and diverse representation.
• Environmentally aware, minimising our footprint and supporting clients’ sustainability priorities.
• Well-governed, safeguarding people, data and integrity in all client engagements.
• Accountable, with clear processes for assurance, continuous improvement and reporting.
This roadmap provides a realistic, scalable framework for a micro enterprise professional-services firm while still meeting the expectations of private clients, public bodies and regulated sectors.
We will publish this roadmap itself as a consultative draft, inviting feedback from clients, associates, and stakeholders to ensure our ESG commitments are transparent, relevant, and co-owned by those we serve.
2. Legislative Context
Enigma Legal Ltd aligns its EDI and sustainability practices with the key UK legislation relevant to a small professional-services firm, including the Equality Act 2010, the Health and Safety at Work etc. Act 1974, the Protection from Harassment Act 1997, and rights-based standards informed by the Human Rights Act 1998.
Our environmental commitments reflect proportionate compliance with the Environment Act 2021, and the UK’s Net Zero framework under the Climate Change Act 2008.
Our social commitments are informed by the guiding principles set out in the Social Value Act 2012 public-sector procurement.This ensures our ESG approach is legally grounded, proportionate for a micro enterprise legal firm, and consistent with private and public-sector expectations.
3. Roadmap Overview (2025–2030)Year 1 – Foundations Governance
• Establish an ESG Policy and publish it.
• Introduce a simple ESG risk register covering data governance, conflicts of interest, safeguarding, workforce wellbeing, environmental impact, and responsible procurement.
• Adopt annual ESG summary reporting.
We are mentored by our sister company, Enigma Healthcare, part of the wider Enigma Holdings Group. Enigma Healthcare has already established ESG practices with ISO-certified systems, and their experience provides us with a proven framework and guidance to scale proportionate ESG commitments within a micro enterprise context.
EDI
• Publish an EDI Statement setting out commitments to fairness, accessibility, and non-discrimination.
• Conduct a baseline review of recruitment, inclusion practices, and accessibility of services.
• Roll out core training: EDI awareness, anti-harassment, safeguarding, and trauma-informed practice.
Note: Our contribution to EDI extends beyond our role as an employer. Through the HR legal services we provide, we actively support fair, inclusive and non-discriminatory practices in client organisations, amplifying our impact across the sports and professional services sectors.
Environment
• Calculate a baseline carbon footprint using micro enterprise-appropriate and free-to-use tools (e.g. SME Climate Academy Hub).
• Note: As a micro law firm, our physical footprint is minimal. We operate in an agile manner, primarily through remote working, work-from-home arrangements, or onsite client engagement, rather than maintaining our own buildings or estates. This will be reflected in our baseline, where emissions are expected to arise mainly from travel and digital activity rather than property or estate management.
• Adopt a digital-first approach to minimise printing and travel.
Year 2 – Embedding
Governance
• Formalise a Code of Conduct for staff, associates and subcontractors including confidentiality, conflicts, anti-corruption and whistleblowing.
• Introduce documented ethical decision-making guidance.
EDI & Safeguarding
• Calculate a baseline social impact footprint using microenterprise-appropriate and free-to-use tools (e.g. Social Value UK).
• Review client-engagement methods to ensure they reflect duty-of-care principles.
• Introduce optional demographic monitoring for workforce diversity. Explore the feasibility of launching a new Apprenticeship scheme.
• Continue embedding EDI into client-facing HR legal services, ensuring our advice promotes equitable treatment and compliance with statutory obligations.
Environment
• Set reduction targets for business travel and energy use.
• Introduce sustainable procurement criteria for office supplies, IT, and travel.
Year 3 – Maturity Governance
• Conduct an internal ESG audit and refresh policies.
• Develop a simple supplier ESG assessment for any subcontractors.
• Draw on mentorship from our sister company, Enigma Healthcare (part of Enigma Holdings Group), which has already established ISO-certified ESG systems. Their experience will guide us in scaling proportionate practices for a microenterprise context.
EDI & Safeguarding
• Integrate EDI considerations systematically into client work and stakeholder engagement.
• Introduce a Wellbeing & Workload Charter for staff and associates.
• Demonstrate measurable impact of HR legal services in advancing inclusive practices within client organisations.
Environment
• Launch a Carbon Reduction Plan consistent with net-zero principles.
• Provide sustainability guidance to associates and subcontractors.
Year 4 – LeadershipGovernance
• Publish an enhanced annual ESG Report with progress metrics and case studies.
• Engage external peer review or light-touch assurance.
EDI & Safeguarding
• Support clients with EDI-integrated approaches and inclusive engagement practices.
• Introduce inclusive design principles for all research and communications.
Environment
• Update Carbon Reduction Plan with revised targets and offset policy.
• Achieve measurable reductions in travel, waste and digital emissions.
• Building on Enigma Healthcare’s ISO experience, examine feasibility of ISO or equivalent certification as part of continuous improvement.
Year 5 - Continuous Improvement & Alignment
Governance
• Review the ESG framework and set new five-year targets aligned to evolving client and regulatory expectations.
• Embed ESG into all key business decisions and major bids.
EDI & Safeguarding
• Demonstrate mature practice through external feedback.
• Refresh training and update practices in light of new guidance or sector reviews.
Environment
• Aim for verified year-on-year emissions reductions.
• Transition to renewable-powered digital infrastructure where possible.
4. Cross-Cutting Principles
• Proportionate for a microenterprise – lightweight, scalable processes.
• Applicable across sectors – suitable for public bodies or commercial clients.
• Aligned to post-Whyte Review expectations – culture, duty of care, integrity embedded in operations.
• Transparent and evidence-led – annual reporting, audit trail, and KPIs.
• People-focused – ethical, fair and safe engagement with staff, clients, and stakeholders.
• Sports-industry relevance – safeguarding, integrity and duty of care are central to our legal practice, reflecting the values expected in professional sport and ensuring our ESG commitments strengthen trust across the sector.
• Consultative engagement – publishing this roadmap as a draft ensures stakeholders can shape, challenge and validate our ESG journey.
• Group mentorship – guided by Enigma Healthcare’s ISO-certified ESG systems within Enigma Holdings Group, ensuring our approach is benchmarked against established best practice while scaled proportionately for a microenterprise.
• Agile footprint – as a micro law firm, we operate without large estates or owned buildings, relying instead on remote working and onsite client presence. This minimises our environmental impact and supports flexible, low-carbon operations.
• EDI contribution beyond employment – our HR legal services actively promote equality, diversity and inclusion within client organisations, extending our impact beyond internal policies to the wider sector.
5. Immediate Next Steps (Next 90 Days)
1. Approve and publish ESG and Sustainability policy documents.
2. Create the ESG risk register and governance calendar.
3. Complete baseline carbon footprint.
4. Roll out core EDI, safeguarding, and ethics training.
5. Begin first annual ESG reporting cycle.
6. Publish this roadmap and invite stakeholder feedback.