Sustainability Policy

Purpose

Albion Marine Solutions is committed to integrating sustainability into its procurement practices and overall operations, in alignment with ISO 20400:2017 standards. This policy establishes our framework for making responsible, ethical, and environmentally conscious decisions that promote sustainable practices for our stakeholders and environment.

Scope

This policy applies to all employees, suppliers, contractors, and stakeholders involved in Albion Marine Solutions' operations and procurement processes.

Policy Principles

Albion Marine Solutions will uphold the following sustainability principles:

Ethical Conduct: We will ensure transparency, integrity, and compliance with Canadian laws, including environmental, labour, and human rights standards.

Environmental Responsibility: We will strive to minimize our environmental impact by adopting energy-efficient practices, reducing waste, sourcing sustainable materials, and supporting initiatives that protect natural resources.

Social Equity: We will promote fair labor practices, diversity, and inclusion, and prioritize partnerships with local and Indigenous businesses whenever possible, fostering economic and social equity.

Economic Efficiency: We will support value-for-money solutions that consider the lifecycle cost and sustainability impacts of goods and services, ensuring that economic decisions contribute to long-term sustainability.

Implementation

To ensure effective application of this policy, Albion Marine Solutions will:

• Conduct regular supplier assessments to evaluate their compliance with sustainability standards and principles.
• Provide training for employees in sustainable procurement practices to empower informed decision-making.
• Monitor and report on sustainability performance annually, tracking progress and identifying areas for improvement.
• Continuously improve our processes to align with evolving sustainability practices and the ISO 20400:2017 guidelines, ensuring that our approach remains relevant and effective.

Governance and Accountability

Responsibility for implementing and maintaining this policy lies with the Albion Management. All employees, suppliers, and contractors are expected to adhere to the principles and practices outlined in this policy. Regular reporting and communication will ensure transparency and accountability.

Review and Updates

This policy will be reviewed annually to ensure alignment with ISO requirements, ISO 20400:2017 standards, industry best practices, and Albion Marine Solutions’ organizational objectives. Any necessary updates will be made to reflect changing laws, emerging sustainability trends, and our evolving business needs.

Commitment

By adopting this Sustainability Policy, Albion Marine Solutions demonstrates its commitment to responsible procurement and sustainable business practices that have a positive impact on society, the environment, and future generations. We pledge to foster sustainability in all aspects of our operations, contributing to the well-being of our stakeholders and the global community.

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Anti-Bribery and Anti-Corruption Policy

Introduction and Purpose

This Anti-Bribery and Anti-Corruption Policy (the "Policy") establishes controls and procedures to ensure that Albion Marine Solutions and its subsidiaries and affiliates (collectively referred to as the "Company" or "Albion Marine Solutions") adhere to all relevant anti-bribery and anti-corruption laws and regulations.

This Policy aims to ensure that the Company, its employees, contractors, directors, officers, independent contractors, and any other individuals associated with Albion Marine Solutions (collectively referred to as "Employees") conduct business with integrity, responsibility, and transparency. All Employees must act ethically in all business transactions and avoid engaging in any form of bribery or corruption.

This Policy should be read in conjunction with Albion Marine Solutions’s Anti Bribery and Anti- Corruption Policy – DOC.PR-HSEQ-009-01 and the Employee Handbook, which outline the expected and required behavior of all Employees.

Legislation

Albion Marine Solutions and its Employees are subject to “The Corruption of Foreign Public Officials Act (Canada) (the “CFPOA”) (http://laws-lois.justice.gc.ca/eng/acts/c-45.2/index.html)” the primary anti- bribery and anti-corruption legislation. This legislation applies even when the Company operates internationally. For example, the CFPOA governs instances of bribery involving foreign public officials during transactions such as the importation of goods or services. Other countries, including the United States, also have similar laws, such as the Foreign Corrupt Practices Act.

This Policy is intended to ensure compliance with the CFPOA and to supplement its requirements. Additionally, bribery and corruption are prohibited under Canada’s Criminal Code, which makes it a criminal offense to offer or give bribes to government officials for any form of influence regarding government contracts or business activities.

Albion Marine Solutions and its employees must refrain from any behavior prohibited by anti-bribery and anti-corruption laws, with violations potentially resulting in criminal or civil penalties, as well as significant fines.

What is Bribery and Corruption?

Bribery is the act of offering or giving any loan, reward, or benefit (either directly or indirectly) to secure an unfair advantage in business dealings. Any attempt to offer such benefits constitutes bribery, which is prohibited by this Policy and Canadian law.

Corruption broadly refers to the misuse of one’s position or authority to obtain undue benefits. Some examples of bribery and corruption include, but are not limited to:

• Kickbacks (payments made to individuals in exchange for awarding contracts)
• Procurement fraud (such as collusion, overcharging, or selecting vendors based on non-ethical criteria)
• Payments to government officials to speed up or gain access to goods, services, or
• False financial reporting to mislead investors or
• Theft or embezzlement of public property or funds
• Obstruction of justice, including interfering with regulatory investigations

Bribes versus Gifts

Employees must never seek or accept favorable treatment in exchange for gifts. While giving and receiving gifts in business may be acceptable, they must not create a perception of favoritism or influence decisions. Gifts should be within the bounds of normal business practice, and if there is any doubt about the appropriateness of a gift, employees should refer to the Code of Ethics for guidance.

Maximum allowable Value of Gift is up to CAD $250, or equivalent in other currency.

Albion Marine Management can request invoices for gifts, if required and till such duration, such gifts will be kept in Albion Marine storage facility. All such gifts will be subject to donation for welfare and public welfare/charity, upon the decision of the Albion Marine Management.

Facilitation Payments

Facilitation payments, which are made to public officials to expedite routine government actions, are strictly prohibited. Payments for official government services, such as fees for permits or licenses, are not considered facilitation payments, provided they are publicly disclosed and transparent.

Political and Charitable Contributions

Political Contributions: In Canada, corporate political contributions to federal parties or candidates for office are prohibited. Employees may contribute personally to political causes, but such contributions must not be used to influence business decisions or be perceived as bribery.

Charitable Contributions: Charitable donations are encouraged, but employees must ensure that such donations are not used to conceal bribery or unethical conduct. All charitable contributions must be legal, ethical, and transparent.

Your Role and Responsibilities

Compliance with this Policy is a fundamental aspect of your role with the Company. If your conduct does not meet the standards outlined in this Policy or is deemed unethical or illegal, corrective actions, including termination, may be taken.

Albion Marine Solutions will provide mandatory Anti-Bribery and Anti-Corruption training for all employees. Employees are encouraged to seek guidance from the Legal & Risk Management team if they are uncertain whether an action may be considered corrupt.

All employees play a critical role in preventing bribery and corruption. If you suspect or observe any form of bribery or unethical behavior, including being offered a bribe or witnessing corrupt activity, you must report it immediately to your manager or through the Company’s Whistleblower Policy.

Employees who report violations in good faith will be protected from retaliation, and all reports will be managed confidentially as per the Whistleblower Policy.

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Equal Employment Opportunity and

Non-Discrimination Policy

Purpose and scope

The purpose of this Policy is to ensure no barriers or discrimination exist regarding any aspect of employment for Albion Marine Solutions Employees and job applicants, and to outline Albion Marine Solutions’s commitment to equal employment opportunities.

This Policy applies to all Albion Marine Solutions Employees and job applicants. Where a conflict exists between this Policy and any applicable collective bargaining agreement, the terms and conditions of the collective bargaining agreement will apply.

Policy

General provisions

• • Albion Marine Solutions is committed to being an equal opportunity employer, offering employment opportunities based on individuals' abilities, qualifications, and the necessary occupational criteria, in full accordance with all applicable federal, provincial, state, and local
  • Discrimination on the basis of race, national or ethnic origin, color, religion, age, sex, sexual orientation, gender identity, marital status, family status, veteran status, physical or mental disability, a criminal conviction for which a pardon has been granted, or any other legally protected characteristic is strictly prohibited in all areas of employment, including recruitment, training, compensation, benefits, promotion, transfer, and termination.
  • As an equal opportunity employer in Canada, Albion Marine Solutions complies with governmental reporting requirements by submitting workforce demographic and qualitative data. The company also develops and enacts Affirmative Action, Employment Equity, and Accessibility plans to fulfill its responsibilities for affirmative action, equal employment, and accessibility. Albion Marine Solutions continuously reviews its policies and initiatives to promote greater representation of designated, protected, and other legally protected

  Roles and responsibilities

• • Employees, leaders, and the Human Resources team are all accountable for upholding equal employment opportunities and fostering a non-discriminatory workplace.
  • Employees are expected to:
    1. Develop an understanding of and appreciate the diversity within Albion Marine Solutions and among its stakeholders.
    2. Acknowledge the importance of diverse perspectives and experiences and adapt approaches to meet the needs of individuals from various backgrounds.
    3. Manage differences respectfully in day-to-day interactions with others.
    4. Report inappropriate behaviors when necessary, utilizing the channels provided in this policy.
  • Leaders are expected to:
    1. Encourage and support practices that ensure all qualified individuals are given equal consideration for employment opportunities and practices.
    2. Lead by example by educating themselves about and adhering to diversity-related legal requirements, while also supporting employees in doing the same.
    3. Implement the company’s Equal Employment Opportunity obligations, Affirmative Action, Employment Equity, and Accessibility plans, as well as other diversity and inclusion strategies within their teams.
    4. Address and eliminate barriers contributing to inequity or disadvantage within their areas of responsibility.
  • Human Resources is responsible for:
    1. Collecting both qualitative and quantitative data to ensure compliance with diversity- related legal requirements.
    2. Analyzing the data to identify and eliminate discriminatory practices or obstacles, in line with legal obligations, collective bargaining agreements, or objective job requirements.
    3. Designing and overseeing the execution of Equal Employment Opportunity, Affirmative Action, Employment Equity, and Accessibility plans, along with other diversity and inclusion strategies.
    4. Enforcing the implementation of this Policy.
    5. Offering training, education, and coaching to help employees cultivate a respectful and inclusive work environment.
    6. Investigating any reports of inappropriate behavior that violate this Policy.

1. Resolution process

• • Allegations of discrimination are treated with the utmost seriousness and are addressed consistently, promptly, and respectfully, ensuring fairness and thoroughness by trained
  • Employees who feel they have experienced discrimination are encouraged to report their concerns through the Albion Marine Solutions Ethics Help Line or any other available reporting
  • Job applicants who believe they have been subjected to discrimination may submit a complaint to the Albion Marine Management over email and confidential disclosure process.
  • Complaints will be reviewed and evaluated by the Human Resources department, which may request additional information from the employee or applicant who filed the Based on the evaluation, Human Resources will decide whether an investigation is necessary or if an alternative approach is more suitable to resolve the issue. If an investigation is deemed appropriate, it will be conducted in collaboration with Albion Marine Solutions' Legal department. 
  • Throughout the complaint assessment and investigation process, confidentiality will be maintained to the greatest extent possible, in line with the Protection of Personal Information Policy, where applicable. Details of the investigation will be shared only with individuals who need the information to facilitate the investigation, decision-making, resolution, and corrective action, or as required by law.

Follow-Up action

• • Following the completion of an investigation, the Human Resources department may take appropriate action to confirm discrimination has stopped, no retaliation has occurred, and work groups are functioning effectively.

Resolution timelines

• • Albion Marine Solutions is committed to addressing discrimination complaints promptly, prioritizing their The time required to investigate and resolve each complaint varies based on its complexity, but every effort is made to conduct investigations efficiently and within a reasonable timeframe.

Your responsibility

Employees are required to adhere to all relevant provisions, as well as the spirit and purpose, of this corporate governance document, and to encourage others to do the same. Any suspected or actual violation of this document must be reported promptly through the available channels, enabling Albion Marine Solutions to investigate and address the issue appropriately. Employees who breach this document or knowingly allow others under their supervision to do so may face corrective action, which could include termination of employment or contracts, in accordance with the Company’s governance policies, employment practices, contracts, collective bargaining agreements, and procedures.

Interpretation and administration

The Company has exclusive authority to interpret, enforce, and modify this corporate governance document, and may update it as needed to reflect new legal requirements or change business conditions.

Non-retaliation

Albion Marine Solutions encourages and supports Employees and Contractors to report any suspected violations of corporate governance documents, relevant laws, regulations, and authorizations, as well as any hazards, potential hazards, incidents related to health, safety, or the environment, and near misses. Reports can be submitted through the available channels. Albion Marine Solutions takes all reports seriously, investigates them to uncover the facts, and, when necessary, makes improvements to its governance practices. Employees and Contractors who report in good faith will be protected from retaliation. Additionally, all Employees and Contractors must report any incidents of retaliation they or others have experienced for making a report. However, good faith reporting does not shield Employees and Contractors who make false or malicious reports, or those attempting to avoid accountability for their own negligence or misconduct by submitting a report.

Definitions

Affirmative Action refers to the implementation of measures designed to enhance the representation of historically underrepresented or excluded groups in the United States, such as women and minorities.

Designated or Protected Groups refers to those groups for which Albion Marine Solutions has legal obligations in Canada and the United States. In Canada, Designated Groups include women, Indigenous peoples, visible minorities, and individuals with disabilities. In the United States, Protected Groups include, but are not limited to, women, racial minorities, individuals with disabilities, protected veterans, and other groups safeguarded by federal or state law.

Employee refers to all full-time, part-time, temporary, and student employees of Albion Marine Solutions.

Employment Equity in Canada refers to the processes, actions, and strategies implemented to ensure the representation of Designated Groups at Albion Marine Solutions.

Equal Employment Opportunity (EEO) in the United States ensures that all employees or job applicants, regardless of race, color, gender, sexual orientation, marital status, religion, national origin, age, physical or mental disability, veteran status, or other legally protected grounds, are entitled to fair and equal opportunities in employment.

Good Faith Reporting means making an honest, fair, and reasonable report, made with integrity and without malicious intent or hidden motives.

Legal Requirements refer to applicable laws (acts and regulations), enduring conditions, and may include directives, guidelines, standards, and codes, provided they contain binding legal obligations for Albion Marine Solutions.

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Aboriginal and Indigenous Policy

Purpose

Albion Marine Solutions recognizes and respects the unique rights, culture, and contributions of Indigenous Peoples in British Columbia. This policy affirms our commitment to fostering respectful relationships, meaningful collaboration, and opportunities for Aboriginal and Indigenous communities in alignment with the principles of reconciliation and the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).

Scope

This policy applies to all employees, contractors, suppliers, and stakeholders involved in Albion Marine Solutions’s operations in British Columbia. It guides our interactions with Indigenous communities and supports the integration of Indigenous perspectives into our business practices.

Policy Principles

Albion Marine Solutions upholds the following principles:

• Respect for Indigenous Rights: Recognizing Indigenous Peoples’ inherent rights and treaty rights as outlined in Section 35 of the Canadian Constitution Act and BC’s Declaration on the Rights of Indigenous Peoples Act (DRIPA).
• Meaningful Engagement: Engaging with Indigenous communities early and continuously in decision-making processes that affect their lands, rights, and interests.
• Cultural Awareness: Promoting understanding and respect for Indigenous cultures, traditions, and knowledge systems within our organization.
• Economic Inclusion: Prioritizing opportunities for Indigenous Peoples through employment, training, procurement, and partnerships with Indigenous-owned businesses.

Implementation

To ensure effective application of this policy, Albion Marine Solutions will:

• Establish protocols for consulting and engaging with Indigenous communities on projects and
• Provide cultural awareness training to employees to enhance understanding and respect for Indigenous perspectives.
• Develop partnerships with Indigenous organizations to promote economic development and capacity building.
• Monitor and report on the outcomes of Indigenous engagement and inclusion initiatives.

Governance and Accountability

Responsibility for implementing and maintaining this policy lies with HR Manager/ Indigenous Relations Manager. All employees and contractors are expected to adhere to the principles and practices outlined herein.

Review and Updates

This policy will be reviewed annually or as required by changes in applicable laws and organizational objectives to ensure alignment with Indigenous rights and reconciliation goals.

Commitment

By adopting this policy, Albion Marine Solutions demonstrates its commitment to advancing reconciliation, fostering mutual respect, and contributing to the well-being of Indigenous communities in British Columbia.