GNL Guatemala S.A. is a developer, owner, operator, and industrial manager of energy and infrastructure assets across Guatemala.

At GNL Guatemala S.A., our Management System provides the framework through which we govern, develop, execute, and manage our LNG-to-Power activities. It establishes clear principles, responsibilities, controls, and performance standards to ensure that our operations are conducted safely, efficiently, responsibly, and in compliance with applicable laws, regulations, contractual obligations, and internationally recognized industry practices.

Governance and Accountability

The Company will maintain a clear governance structure defining decision-making authority, accountability, responsibilities, and reporting lines across the organization. Management is responsible for establishing corporate objectives, allocating appropriate resources, monitoring performance, managing risks, and ensuring compliance with Company policies and applicable requirements. Roles and responsibilities will be clearly defined across employees, management, contractors, EPC/EPCM partners, consultants, suppliers, and operators, ensuring that accountability is embedded throughout the organization.

Integrated Management System

Our Management System will integrate the principal disciplines required for the effective governance and operation of LNG and power infrastructure, including:

• Corporate Governance and Compliance
• Project and Operational Management
• Quality Management
• Environment, Safety and Occupational Health
• Process Safety and Asset Integrity
• Risk Management
• Contractor and Supplier Management
• Emergency Preparedness and Business Continuity
• Performance Monitoring and Continuous Improvement

The system will progressively align with internationally recognized standards, including ISO 9001 for Quality Management, ISO 14001 for Environmental Management, and ISO 45001 for Occupational Health and Safety Management.

Risk-Based Management

Risk management is an integral component of how GNL Guatemala S.A. makes decisions and manages its operations. The Company will systematically identify, assess, mitigate, monitor, and communicate risks throughout the Project lifecycle. This approach will cover technical, operational, process-safety, environmental, financial, commercial, regulatory, contractual, and organizational risks. For LNG and natural gas infrastructure, particular attention will be given to major accident prevention and process safety through appropriate engineering studies and risk assessments, including HAZID, HAZOP, QRA, fire and explosion assessments, and other specialized safety studies, as applicable.

Quality and Operational Excellence

GNL Guatemala S.A. will establish processes to ensure that engineering, procurement, construction, commissioning, operations, and maintenance activities consistently meet defined technical and quality requirements. Quality Assurance and Quality Control (QA/QC) principles will be embedded throughout project execution, supported by document control, inspection and testing, supplier qualification, non-conformance management, audits, corrective actions, and lessons learned. The Company's objective is to achieve high levels of reliability, availability, efficiency, and operational performance throughout the life of its assets.

Safety, Health and Environmental Management

Protecting people, communities, the environment, and our assets is fundamental to our Management System. The Company will establish comprehensive Environment, Safety and Health requirements covering employees, contractors, suppliers, visitors, and other stakeholders involved in our activities. The Company will promote a strong safety culture in which every employee and contractor has both the responsibility and authority to identify hazards, report incidents and near misses, and stop work when conditions present an unacceptable risk.

Process Safety and Asset Integrity

Given the nature of LNG, natural gas, and power generation infrastructure, Process Safety and Asset Integrity will represent fundamental elements of our Management System. Management controls will address LNG handling and transfer, cryogenic systems, storage and regasification, natural gas transportation, hazardous areas, fire and gas detection, emergency shutdown systems, pressure containment, fire protection, rotating equipment, electrical systems, and other safety-critical infrastructure.

Contractor and Supply Chain Management

Our contractors, EPC/EPCM partners, equipment manufacturers, suppliers, consultants, and operators are an extension of our operational organization and will therefore be expected to comply with the Company's applicable management-system requirements. Contractors and suppliers will be selected and monitored based on technical capability, quality, QESH performance, experience, financial capacity, regulatory compliance, and ability to meet Project requirements.

Emergency Preparedness and Business Continuity

The Company will maintain appropriate emergency preparedness and response capabilities for credible scenarios associated with LNG, natural gas, marine operations, power generation, construction, and related infrastructure. Emergency Response Plans will establish clear command structures, communication protocols, evacuation procedures, resources, training, and coordination mechanisms with port authorities, emergency services, government agencies, local communities, and other relevant stakeholders.

Our Management Commitment

Our approach is founded on five core principles: Accountability, Risk Management, Operational Excellence, QESH Performance, and Continuous Improvement. These principles guide how we make decisions, manage our people and contractors, protect our assets and the environment, and deliver safe, reliable, efficient, and sustainable LNG-to-Power infrastructure for Guatemala.

To maintain high standards of corporate governance and support the successful development of its LNG-to-Power infrastructure, GNL Guatemala S.A. ("the Company") will establish and implement a comprehensive Enterprise Risk Management (ERM) Framework across all departments, management levels, projects, and business activities. ERM will be an integral part of the Company's Management System and decision-making processes, applying throughout the entire project lifecycle — from business development, feasibility and permitting through engineering, financing, procurement, construction, commissioning, commercial operations, maintenance, and eventual decommissioning.

The purpose of the ERM Framework is to provide the Board of Directors, executive management, employees, shareholders, and relevant project teams with a consistent and transparent methodology for identifying, assessing, managing, monitoring, and communicating risks while also recognizing opportunities capable of creating and protecting long-term stakeholder value.

Enterprise-Wide Risk Governance

The Board of Directors will maintain oversight of the Company's principal risks, while executive management will be responsible for ensuring that appropriate risk-management processes and controls are implemented throughout the organization. Individual risks will have clearly identified risk owners, responsible for implementing mitigation measures, monitoring exposure, and reporting material changes to management. A corporate Risk Register will consolidate the Company's principal risks and will be periodically reviewed and updated as the Project progresses.

Risk-Based Decision Making

Major decisions — including project configuration, technology selection, contracting strategy, LNG sourcing, financing structure, execution schedule, capital commitments, and Final Investment Decision (FID) — will be evaluated considering their potential impact on the Company's risk profile, assessed according to their likelihood, potential impact, mitigation measures, residual exposure, and potential consequences for cost, schedule, safety, environment, revenues, financing, and operational performance.

Project Development and Execution Risk

GNL Guatemala S.A. will actively manage the interfaces between the LNG receiving and storage facilities, regasification infrastructure, natural gas transportation facilities, power generation plant, electrical substation and transmission infrastructure, marine and port facilities, and associated utilities. Particular attention will be given to interface risks that could affect the critical path of the Project, including engineering completion, permitting, land and port access, procurement of long-lead equipment, construction sequencing, commissioning, grid interconnection, and achievement of Commercial Operation Date (COD).

Commercial and Offtake Risk

The Company will evaluate risks associated with Power Purchase Agreements (PPAs), electricity tenders, capacity commitments, dispatch assumptions, electricity pricing, counterparty creditworthiness, payment security, contractual performance obligations, and potential changes in the Guatemalan electricity market. Commercial agreements will be evaluated not only according to expected returns but also according to their ability to provide predictable and bankable long-term cash flows.

LNG Supply and Commodity Risk

The Company's risk-management strategy will address LNG availability, commodity-price exposure, transportation costs, shipping availability, supplier concentration, contractual flexibility, delivery schedules, weather disruption, cargo diversion, and geopolitical or international market disruptions. GNL Guatemala S.A. intends to maintain flexibility to source LNG from multiple potential supply markets, particularly the U.S. Gulf Coast and other suitable LNG supply sources within the Gulf of Mexico and Caribbean region.

Financing and Financial Risk

The ERM Framework will address risks related to development funding, project financing, interest rates, foreign exchange, refinancing, liquidity, cost escalation, construction contingencies, debt-service obligations, covenant compliance, and potential delays in financial close. Financial models will be periodically stress-tested against changes in key assumptions, including LNG prices, electricity prices, CAPEX, interest rates, construction delays, plant availability, dispatch factors, and operating costs.

Regulatory, Permitting and Compliance Risk

GNL Guatemala S.A. will systematically monitor the legal and regulatory environment applicable to the Project, managing risks associated with environmental approvals, energy-sector regulations, electricity-generation requirements, grid interconnection, port and maritime authorizations, construction permits, land rights, tax matters, customs requirements, LNG importation, and other applicable governmental approvals.

Technical, Process Safety and Asset Integrity Risk

Risk-management activities will include appropriate technical and safety studies throughout engineering and operations, including HAZID, HAZOP, Quantitative Risk Assessment (QRA), fire and explosion studies, marine risk assessments, emergency-response planning, and other specialized assessments, as appropriate.

Environmental and Social Risk

The Company will identify and manage potential impacts associated with marine and coastal activities, biodiversity, emissions, water use, wastewater, waste management, noise, dredging, land use, construction activities, local communities, and other relevant environmental and social matters.

Counterparty, Contractor and Supply Chain Risk

The Company will conduct appropriate technical, commercial, financial, compliance, and QESH assessments of material counterparties, including EPC/EPCM contractors, technology providers, equipment manufacturers, LNG suppliers, shipping companies, operators, financial institutions, consultants, and other strategic counterparties.

Operational Resilience and Business Continuity

Business continuity and emergency-response arrangements will consider potential disruptions involving LNG supply, marine operations, terminal facilities, power generation equipment, transmission infrastructure, extreme weather, natural hazards, cybersecurity, telecommunications, utilities, critical suppliers, and other operational dependencies.

Risk Monitoring and Key Risk Indicators

The corporate Risk Register will identify, as appropriate: Risk → Cause → Potential Consequence → Probability → Impact → Risk Rating → Mitigation Measures → Risk Owner → Target Date → Residual Risk. Management will periodically report material risk exposures and mitigation progress to the Board of Directors.

Risk Appetite and Risk Tolerance

The Company may accept certain measured commercial or development risks when they provide an appropriate risk-adjusted return. However, it will maintain a substantially lower tolerance for risks capable of causing serious harm to people, major environmental impacts, regulatory non-compliance, loss of asset integrity, corruption, or material damage to the Company's reputation and ability to operate.

Through its Enterprise Risk Management Framework, GNL Guatemala S.A. seeks not to eliminate all risk, but to understand, allocate, mitigate, monitor, and manage risk intelligently.

Creating Shared Value with Our Communities. At GNL Guatemala S.A. ("the Company"), Corporate Social Responsibility ("CSR") is an integral part of how we intend to develop and operate our LNG-to-Power business. The Company recognizes that the long-term success of the Project depends not only on technical, operational, and financial performance, but also on building relationships based on trust, respect, transparency, and shared value with the communities where we operate.

The Company's CSR strategy will focus on initiatives capable of generating sustainable and measurable benefits, with particular emphasis on Education, Technical Training, Local Employment, Local Procurement and Entrepreneurship, Community Infrastructure, Health and Safety, Environmental Stewardship, and Community Engagement.

Education and Opportunities for Future Generations

Education will be one of the core pillars of GNL Guatemala S.A.'s community-development strategy. The Company will support programs designed to improve access to education, strengthen educational infrastructure, reduce barriers to learning, and provide young people in surrounding communities with better opportunities for their future — including rehabilitation of local schools, educational materials and equipment, and support for computer and digital-learning facilities.

Technical and Vocational Training

GNL Guatemala S.A. intends to use this opportunity to contribute to the development of a stronger local skilled workforce. Training may include areas such as welding and industrial fabrication; electrical and instrumentation works; mechanical maintenance; civil construction; industrial piping; equipment operation; logistics and warehousing; occupational health and safety; environmental monitoring; port and marine-support activities; and other technical skills required during construction and operations.

Local Employment and Workforce Development

GNL Guatemala S.A. recognizes that one of the most significant potential socioeconomic benefits of the Project will be the creation of direct and indirect employment opportunities during development, construction, commissioning, and operations, with particular attention to qualified candidates from communities surrounding the Project.

Local Procurement and Development of SMEs

GNL Guatemala S.A. will seek opportunities to incorporate qualified local businesses, contractors, entrepreneurs, and small and medium-sized enterprises (SMEs) into the Project's supply chain, in areas such as transportation, accommodation, catering, construction support, equipment rental, maintenance, waste management, security, logistics, and professional services.

Community Infrastructure and Quality of Life

In consultation with communities and relevant authorities, the Company may support initiatives related to schools, community facilities, access to potable water, sanitation, public spaces, local roads, lighting, digital connectivity, and other essential community infrastructure.

Health, Safety and Community Well-Being

GNL Guatemala S.A. may collaborate with local institutions and organizations on programs related to preventive health, occupational safety awareness, emergency preparedness, road safety, and community emergency-response capabilities.

Environmental Stewardship

The Company will seek to minimize the environmental footprint of its activities and promote responsible management of the marine, coastal, terrestrial, and ecological environment surrounding the Project, including environmental education, coastal and community clean-up programs, waste-reduction and recycling campaigns, and mangrove or ecosystem conservation initiatives.

Stakeholder and Community Engagement

The Company will establish mechanisms to communicate with communities, understand their concerns, identify priorities, provide information regarding Project activities, and respond appropriately to potential social impacts — beginning during project development and continuing throughout construction and operations.

Community Grievance Mechanism

The Company intends to establish an accessible Community Grievance Mechanism through which individuals and organizations can raise concerns or complaints related to Project activities. Grievances will be documented, evaluated, addressed, and monitored through a defined process designed to provide appropriate and timely responses.

Creating Shared Value

Our ambition is for the LNG-to-Power Project to become not only a strategic energy infrastructure project for Guatemala, but also a catalyst for sustainable economic and social development in Izabal and the communities surrounding Puerto Santo Tomás de Castilla.

Respect, Transparency and Shared Responsibility. In fulfilling our ambition to be a trusted energy provider, employer, investment platform, and long-term partner, GNL Guatemala S.A. ("the Company") is committed to respecting and protecting the legitimate rights and interests of the stakeholders who contribute to, participate in, or may be affected by our activities.

Who Are Our Stakeholders?

Our principal stakeholders include: shareholders and investors; lenders and financial institutions; employees and their families; contractors, consultants, and suppliers; LNG suppliers and shipping partners; EPC/EPCM contractors and technology providers; electricity customers, utilities, and offtakers; port and maritime authorities; national and local government institutions and regulators; municipalities and public authorities; host and neighboring communities; local businesses and entrepreneurs; educational and technical institutions; environmental and civil-society organizations; and other individuals or organizations that may be directly or indirectly affected by our activities.

Shareholders and Investors

The Company recognizes the rights of its shareholders and investors to receive appropriate and reliable information regarding the Company's performance, governance, material risks, and strategic direction, subject to applicable confidentiality obligations and legal requirements.

Employees

GNL Guatemala S.A. will seek to provide a professional working environment based on respect, equal opportunity, merit, safety, integrity, professional development, and fair treatment. Employees will have the right to raise legitimate concerns regarding safety, ethics, compliance, workplace conduct, or other matters without fear of inappropriate retaliation.

Health and Safety

Every employee, contractor, supplier, visitor, and individual participating in our operations has the right to expect that reasonable and appropriate measures are taken to protect their health and safety. Personnel working on the Project will have the responsibility and authority to stop work when they reasonably believe that an activity presents an unacceptable risk to people, the environment, or Project assets.

Contractors, Suppliers and Business Partners

Procurement and contracting processes will be based on appropriate criteria including technical capability, commercial competitiveness, quality, safety performance, environmental performance, compliance, experience, and financial capacity. The Company will not tolerate bribery, corruption, fraud, conflicts of interest, or other improper business practices.

Customers and Offtakers

GNL Guatemala S.A. will seek to develop long-term commercial relationships based on reliability, transparency, contractual performance, competitive energy supply, and security of service.

Host Communities

Community members have a legitimate interest in understanding how Project activities may affect their environment, livelihoods, infrastructure, safety, employment opportunities, and quality of life. The Company will seek to maintain open, respectful, and continuous dialogue with host and neighboring communities.

Government, Regulators and Public Institutions

GNL Guatemala S.A. will maintain relationships with public institutions based on legality, transparency, professionalism, institutional respect, and cooperation.

Environmental Rights and Responsibilities

GNL Guatemala S.A. will seek to prevent, minimize, mitigate, and appropriately manage environmental impacts associated with its activities, including impacts related to marine and coastal environments, biodiversity, emissions, water resources, waste, noise, land use, and construction activities.

Access to Information and Transparency

Subject to legitimate requirements regarding commercial confidentiality, personal information, cybersecurity, contractual restrictions, and legally protected information, the Company will seek to provide relevant stakeholders with timely, accurate, understandable, and appropriate information regarding matters that materially affect them.

Right to Raise Concerns and Grievances

GNL Guatemala S.A. will establish accessible mechanisms for receiving and addressing grievances, complaints, ethical concerns, and other stakeholder issues, handled fairly, confidentially where appropriate, and without improper retaliation.

Human Rights

GNL Guatemala S.A. will conduct its activities with respect for internationally recognized principles concerning human dignity and fundamental rights, consistent with applicable Guatemalan legislation and the Company's corporate policies.

Our Commitment

At GNL Guatemala S.A., protecting stakeholder rights means more than meeting minimum legal requirements. It means developing relationships based on trust, dialogue, accountability, mutual respect, and responsible performance.

Building Trust Through Accurate, Timely and Responsible Communication. At GNL Guatemala S.A. ("the Company"), transparency is a fundamental principle of our Corporate Governance Framework and an essential element in building and maintaining the confidence of our shareholders, investors, lenders, employees, business partners, government authorities, host communities, and other stakeholders.

Corporate Disclosure Framework

The Company will comply with applicable disclosure and reporting requirements established by Guatemalan laws, regulatory authorities, financing agreements, corporate documents, contractual obligations, and other applicable requirements. Material information will be communicated through appropriate channels and within applicable reporting periods.

Financial Reporting and Audited Financial Statements

GNL Guatemala S.A. will seek to ensure the timely preparation and issuance of its annual financial statements and, where applicable or required, their examination by an independent external auditor.

Transparency with Shareholders and Investors

The Company will seek to provide appropriate information concerning financial performance and position, material capital expenditures and commitments, Project development and execution progress, significant financing arrangements, material contracts, principal corporate and Project risks, significant changes to Project scope, schedule, or investment requirements, corporate governance matters, and material related-party transactions.

Transparency with Lenders and Financial Institutions

Subject to applicable financing arrangements, lenders may receive periodic information regarding Project progress, CAPEX, construction schedule, financial performance, debt-service capability, material contracts, insurance, QESH performance, environmental and social matters, regulatory compliance, and material Project risks.

Material Project Developments

The Company will establish processes for identifying and appropriately communicating significant developments, which may include Power Purchase Agreements (PPAs), electricity tender awards, LNG supply agreements, EPC/EPCM contracts, major equipment procurement, port agreements, land arrangements, environmental approvals, generation licenses, transmission and interconnection agreements, financing commitments, Financial Close, Final Investment Decision (FID), commencement of construction, major commissioning milestones, and Commercial Operation Date (COD).

Enterprise Risk Management Disclosure

Material risks identified through the ERM process will be appropriately communicated to the Board and relevant decision-makers, including the nature of the risk, potential impact, probability, mitigation measures, responsible risk owner, residual exposure, and changes in risk profile.

Anti-Bribery, Anti-Corruption and Ethical Conduct

GNL Guatemala S.A. will maintain a zero-tolerance approach toward bribery, corruption, fraud, kickbacks, and other improper business practices.

Confidentiality and Responsible Disclosure

GNL Guatemala S.A. will maintain appropriate safeguards for information that is legitimately confidential, including commercially sensitive information, LNG pricing and supply terms, PPA negotiations, financing terms, proprietary engineering information, personal data, cybersecurity information, and confidential information belonging to business partners.

Reporting Concerns and Whistleblower Protection

Employees, contractors, and other relevant stakeholders will be provided with appropriate channels to raise concerns regarding suspected misconduct, fraud, corruption, conflicts of interest, financial irregularities, safety matters, environmental issues, or other potential violations of Company policies or applicable law.

Our Commitment to Transparency

For GNL Guatemala S.A., Disclosure and Transparency are not simply reporting obligations — they are fundamental elements of responsible corporate governance and long-term stakeholder trust. Our objective is to ensure that shareholders, investors, lenders, employees, authorities, customers, business partners, and host communities can have confidence in the integrity of our management and the reliability of the information we provide.

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