Sustainability Policy

Definitions

‘Sustainability’ in the context of this document is defined as meeting the needs of the present without compromising the ability of future generations to meet their needs through actions that consider people, planet, and profit holistically.

Policy

Principles:

Frontline Analysts Limited is committed to sustainability throughout all aspects of the organization. It is at the forefront of our decision-making processes and an integral part of our company culture. In the professional services industry, business travel and office buildings are the main sources of emissions. With this in mind, we have committed to:

• Encouraging low-carbon transportation and/or virtual arrangements for business travel where applicable;

• Minimizing waste and preserving natural resources in office buildings;

• Considering direct and indirect emissions in present and future office locations;

• Facilitating shorter commutes, sustainable transportation, and remote work arrangements for colleagues;

• Integrating sustainability into decision-making processes;

• Measuring and offsetting carbon emissions on a periodic basis, and procuring renewable energy where applicable;

• Building local partnerships with community organizations where we operate;

• Complying with all applicable environmental laws and regulations;

• Continuously seeking opportunities to lower our environmental footprint;

• Reviewing our sustainability strategy on a periodic basis.

Governance:

The Sustainability Governance Committee consists of senior executives and staff members that meet on a yearly basis to conduct a formal review of the sustainability strategy. The goal of these meetings is to find opportunities to reduce the company’s environmental footprint while considering employee wellbeing, the local community, and customer satisfaction. They are responsible for the implementation of the procedures necessary to meet the policy objectives above. The procedures include, but are not limited to, the minimization of carbon intensive trips, waste reduction, energy conservation, renewable energy procurement, and waste diversion.

Procedures

The Sustainability Governance Committee will ensure that:

• Colleagues travel only when necessary, and when they do preference is given to sustainable transportation such as walking, biking, buses, shuttles, and trains;

• Incentives are provided to encourage public transit, and offices do not have car parking spaces to discourage personal vehicle use;

• Flights that are required for business travel are kept as short as possible and intermodality that incorporates low-carbon transportation such as trains is encouraged;

• Offices minimize energy use through the installation of energy efficient technologies, proper ventilation and insulation, and by encouraging behaviors to conserve energy, where applicable;

• Carbon emissions are measured and offset on an ongoing basis through Woodland Trust, an organization that plants trees promoting natural carbon storage, to achieve net zero carbon emissions;

• Office locations are chosen with sustainability in mind, prioritizing walkability, public transit accessibility, shorter travel distances, and/or lower traffic;

• Renewable energy is procured to power offices where applicable;

• Relationships with community organizations are maintained and contributions are made to support their work;

• Appropriate receptacles are installed and maintained for recycling, compost, and waste in offices in order to increase waste diversion;

• Waste reduction is achieved through the elimination of single-use materials and digitization in offices where applicable, and reuse is encouraged;

• All colleagues are aware of the company’s environmental policy and procedures;

• Management is aware of all applicable environmental laws and regulations;

• The Sustainability Governance Committee meets annually to review sustainability strategy and adjust it as needed.