‘H2D Sustainability Limited’ – ESG Policy Framework

(Environmental, Social and Governance Policy)

(Legally Binding Policy for Employees, Contractors, and Representatives)

Effective Date: July 2025

Approved By: H2D Limited Board of Directors

Applies To: All employees, contractors, consultants, agents, and subsidiaries of H2D Limited at Smart Station, First Floor Incubator Building Masdar City, Abu Dhabi United Arab Emirates (“H2D Limited” or “the Company”), including operations within the EU, United Kingdom, United Arab Emirates, and Middle Eastern jurisdictions.\

1. Purpose and Commitment

H2D Limited is dedicated to advancing sustainable development through science-led innovation, circular economy principles, and responsible business practices. Our Environmental, Social and Governance (ESG) Policy Framework ensures that every decision we make aligns with our mission to create measurable positive impact for people, planet, and prosperity.

This framework forms part of all employment, supplier, and investment agreements and serves as a binding commitment to uphold responsible, transparent, and ethical operations.

2. ESG Governance Structure

Role Responsibility

Board of Directors Oversight and approval of ESG strategy, targets, and reporting.

Managing Director Ensures ESG integration into core operations and business

development.

ESG G Compliance Officer

Monitors implementation, audits data, and coordinates disclosures.

Department Heads Embed ESG practices into projects, supply chains, and client

services.

All Staff and Contractors Uphold the values and commitments outlined in this policy.

3. Environmental Policy

H2D Limited recognises that our operations and those of our clients have an impact on the environment. We are committed to minimising negative impacts and enhancing environmental performance through:

3.1 Climate Action G Decarbonisation

Comply with the UAE Net Zero Strategy and Science-Based Targets initiative (SBTi).
Measure and disclose Scope 1, 2, and 3 greenhouse gas emissions
Prioritise low-carbon operations, renewable energy procurement, and virtual collaboration to reduce travel
Integrate life cycle assessment (LCA) and carbon accounting into all consulting and product development
Partner with clients to design nature-based and circular economy solutions that accelerate

3.2 Resource Efficiency G Waste Management

Commit to zero waste to landfill by 2030 through reuse, recycling, and material
Apply eco-design principles to reduce energy and material intensity of
Maintain a sustainable procurement policy favouring suppliers with demonstrable environmental

3.3 Biodiversity G Nature Positive Operations

Support and align with Biodiversity Net Gain (BNG) and TNFD
Protect and restore natural habitats within our project areas and supply
Promote eco-innovation and green chemistry in client projects to replace harmful

3.4 Environmental Compliance

Adhere to all applicable laws and standards including the Environmental Protection Act 1GG0, REACH Regulation, and ISO 14001.
Conduct periodic environmental audits and publish findings in our annual ESG

4. Social Policy

H2D Limited’s success depends on the wellbeing, inclusion, and empowerment of its people and communities.

4.1 Human Rights and Labour Standards

Comply with the Modern Slavery Act 2015 and uphold the ILO Core Conventions.
Prohibit child labour, forced labour, and exploitative practices throughout our operations and supply chains.
Ensure equal opportunity, fair pay, and safe working conditions for all employees and

4.2 Diversity, Equity and Inclusion (DEI)

Foster a workplace that is inclusive, respectful, and free from discrimination or
Ensure recruitment, promotion, and pay decisions are based solely on merit, skill, and contribution.
Target gender balance and diverse representation at senior and board levels by

4.3 Health, Safety and Wellbeing

Comply with the Health and Safety at Work Act 1G74 and ISO
Maintain risk assessments, training, and emergency preparedness
Promote mental health awareness and access to confidential wellbeing

4.4 Community Engagement

Contribute to the communities in which we operate through education, environmental restoration, and
Support research and collaboration with universities and NGOs in sustainability, green chemistry, and
Prioritise local employment and procurement where

5. Governance Policy

Strong governance is essential to maintaining stakeholder trust and ensuring sustainable growth.

5.1 Ethics and Integrity

Uphold the H2D Limited Code of Conduct, including anti-bribery, anti-corruption, and fraud prevention clauses.
Prohibit facilitation payments and undisclosed gifts or
Require all directors and employees to complete annual ethics

5.2 Data Privacy and Information Security

Comply with the UAE GDPR and Data Protection Act 2018.
Protect confidential data using encryption, access controls, and secure
Conduct regular cybersecurity training and audits.

5.3 Transparency and Reporting

Prepare and publish an annual ESG G Sustainability Report, aligned with GRI, TCFD, and CSRD.
Disclose environmental and social performance metrics, improvement actions, and verified impact
Encourage supplier and partner transparency through our Supplier Code of

5.4 Anti-Corruption and Whistleblowing

Maintain a confidential whistleblowing mechanism for reporting unethical or unlawful
Protect whistleblowers from retaliation or
Investigate all reports promptly and

6. Supply Chain and Partner Expectations

H2D Limited expects all suppliers, subcontractors, and partners to comply with equivalent ESG standards. Contracts must include:

Adherence to H2D Limited ’s ESG, Anti-Bribery, and Human Rights
Demonstrable ESG performance indicators and transparent
Immediate notification of any breach or non-compliance.
Right for H2D Limited to audit or terminate the agreement upon serious ESG

7. ESG Performance and Continuous Improvement

7.1 Monitoring and KPIs

We track progress using measurable indicators including:

Carbon intensity (tCO₂e per revenue unit).
Waste diversion
Gender and diversity representation
Safety incident frequency
ESG training completion

7.2 Training and Awareness

All employees and contractors will receive mandatory ESG induction and annual refresher training, including topics such as sustainability, ethics, and inclusive behaviour.

7.3 Continuous Improvement

We are committed to continuous improvement through regular benchmarking, stakeholder engagement, and third-party verification.

8. Accountability and Enforcement

Violations of this policy constitute a breach of contract or company regulations. Disciplinary actions may include:

Formal warning or

Suspension of supplier
Legal action for damages or recovery of

The ESG C Compliance Officer reports annually to the Board on non-compliance, corrective actions, and progress toward targets.

9. Review and Revision

This policy will be reviewed annually or following significant changes in regulation or company operations to ensure ongoing alignment with best practices and stakeholder expectations.