Environmental and social policy

EPIGRAPHS

“Unus pro omnibus, omnes pro uno – we believe that the master key for any organisation to satisfy its customers and deliver maximum value is commitment to the continuous personal and professional development of the entire team. For this reason, we have developed our own meritocracy model based on ‘one for all, all for one’, where every employee is directly responsible for the results achieved by the team, which should work at its best possible performance—efficient, creative and dedicated”

“For us, Sustainability is the simultaneous development of environmental, social and economic aspects. Our commitment is the continuous development of this triangle.” NewSun Team

I. OBJECTIVE

"To provide individual and corporate clients with renewable and clean electrical energy, substantially contributing to the sustainable development of the ecosystem and promoting the continuous improvement of environmental performance in our activities and of the team as a whole" NewSun Team.

1.1. NEWSUN Commitments

(I) Consider, in planning and decision-making processes, the variables of quality, environment, occupational health and safety, and social responsibility in all NEWSUN activities and its subsidiaries, providing the necessary resources for the implementation of ecologically sound actions and ventures, disseminating this culture throughout the supply chain and among partners.

(II) Support and invest in Research, Development and Innovation projects that lead to technological progress focused on new renewable energy sources, the improvement of existing technologies and global eco-efficiency.

(III) Promote and encourage renewable energy generation initiatives through Remote Self-Consumption, Distributed Generation and energy conservation, seeking the rational use of natural resources, the minimisation of environmental impacts and the conservation of biodiversity, within a business strategy focused on sustainability.

(IV) Promote actions, within its area of influence, that contribute to defining strategies for nature conservation and human and cultural valorisation, with respect for the principle of environmental unity, expressed in the diversity and integrity of society and natural ecosystems.

(V) Ensure that technical and administrative procedures, as well as the organisational structure, meet the requirements established in ISO 14001 and OHSAS 18001, incorporating these into ventures in which NEWSUN has majority control and influencing their application in those in which it holds minority participation, aiming at continuous improvement and standards of excellence in its activities and results.

(VI) Ensure compliance with current legislation, such as laws, decrees, regulations, ILO Conventions, the Universal Declaration of Human Rights and United Nations Conventions, related to the environment, occupational health and safety and social responsibility, internalising the principles of business ethics in the development of its activities.

(VII) Maintain an open communication channel with our clients, employees, governmental or non-governmental bodies, neighbouring communities and the media, providing information relating to environmental, occupational health and safety and social responsibility issues arising from the Company's activities.

(VIII) Ensure appropriate procedures from project development through to the disposal of unusable products, as well as preventing pollution and encouraging the practice of recycling and material reuse.

(IX) Promote compliance with NEWSUN's Environmental, Social Responsibility, Health and Safety and Quality Policies and Guidelines by critical suppliers and service providers.

1.2. HUMAN RIGHTS AND EMPLOYMENT RELATIONS

(I) Incorporate human rights concepts broadly, considering political, social and economic rights—including labour rights—and extending this across the entire value chain.

(II) Aims to guarantee a dignified working environment in a globalised world without discrimination on grounds of sex, colour, race, belief or sexual orientation; fair remuneration; labour safety; health conditions; the eradication of forced labour, child labour, slavery-like conditions, among others

(III) Ethical guidance and principles for the protection of investors/clients, helping to defend clients' rights in an impartial and independent manner through the Ombudsman.

2.1. SITE SELECTION

(I) Each area, whether rural or not, is and must be thoroughly analysed by NewSun's experienced field team, in order to achieve the venture's objectives and ensure proper environmental protection.

(II) In site selection, primary aspects must be taken into account, ordered by priority: annual solar incidence; analysis of local environmental quality; assessment of the need for forest relocation; logistics; ease of lorry transit; access to transmission lines suitable for electricity injection from the planned plant.

(III) Analyse the surroundings and the region's expansion policy where the area is located; simulate the territorial evolution of the region over the 30 years of plant operation.

(IV) Ensure that the area is suitable for the activity, taking into account all the aforementioned environmental aspects and the potential future appreciation of the area—a factor also crucial to the venture and its investors.

(V) Finally, plan the exit and withdrawal plan at the end of the 30 years in a safe, sustainable manner that does not emit any type of waste or substrate into the soil, air or nearby water sources, and ensure that the land is fertile, healthy and suitable for the development of native or non-native vegetation and for the reproduction of animal species for which the area in question is their natural habitat.

2.2. SUSTAINABLE OPERATIONS

It is known that solar photovoltaic energy generation is a sustainable activity in itself and a renewable and clean source of electrical energy; therefore, the entire NewSun team, its subsidiaries and its contractors must pay attention to:

(I) Maintain a clean and organised working environment, respecting professional boundaries in interpersonal relationships to ensure, above all, a healthy corporate environment that promotes the personal and professional development of all employees and of the team itself.

(II) Follow the Code of Ethics and consistently contribute to the continuous learning and evolution of the team, aiming for maximum efficiency of each employee and of the team as a whole.

(III) Each employee should be a source of positive energy and productivity for the team.

(IV) Promote intrapreneurship in a sustainable and balanced manner alongside standard day-to-day activities.