Disclosure and Transparency

Disclosure and Transparency 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. The Company is committed to maintaining appropriate standards of disclosure, accountability, accuracy, integrity, and transparency throughout the development, financing, construction, commissioning, and operation of its LNG-to-Power infrastructure. Our approach is based on the principle that material information should be appropriately identified, verified, communicated, and reported in a manner that enables relevant stakeholders to make informed decisions, while respecting legitimate requirements relating to confidentiality, commercially sensitive information, personal data, contractual restrictions, and legal obligations. Corporate Disclosure Framework GNL Guatemala S.A. will establish appropriate policies, responsibilities, procedures, and internal controls governing the preparation, review, approval, and disclosure of material corporate information. 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. Responsibility for corporate disclosure will be clearly assigned within the organization to ensure that information released by the Company is accurate, consistent, appropriately authorized, and supported by reliable information and documentation. Financial Reporting and Audited Financial Statements The Company is committed to maintaining appropriate financial records and accounting controls that accurately reflect its financial position, transactions, assets, liabilities, revenues, expenditures, and capital commitments. 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. Financial reporting will be prepared in accordance with the accounting framework applicable to the Company and the requirements of relevant authorities, shareholders, investors, and financing institutions. The Company will also maintain appropriate internal financial controls designed to support the accuracy, completeness, traceability, and reliability of financial information. Transparency with Shareholders and Investors Shareholders and investors should have access to sufficient, relevant, and reliable information to understand the Company’s financial position, strategy, material risks, Project progress, and significant corporate decisions, subject to applicable confidentiality requirements. The Company will seek to provide appropriate information concerning matters such as: * Financial performance and financial position; * Material capital expenditures and commitments; * Project development and execution progress; * Significant financing arrangements; * Material contracts and commercial agreements; * Principal corporate and Project risks; * Significant changes to Project scope, schedule, or investment requirements; * Corporate governance matters; * Material related-party transactions; and * Other events capable of materially affecting the Company or its shareholders. Information provided to shareholders will be governed by applicable corporate documents, shareholder agreements, legal requirements, and established governance procedures. Transparency with Lenders and Financial Institutions As an infrastructure developer, GNL Guatemala S.A. recognizes the importance of transparency in establishing the credibility and bankability of its LNG-to-Power Project. The Company will seek to maintain constructive and transparent relationships with banks, development finance institutions, export credit agencies, institutional investors, and other potential financing partners. 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. The objective is to ensure that financing partners receive appropriate information to understand Project performance and evaluate material changes in risk exposure. Material Project Developments Given the scale and complexity of an integrated LNG-to-Power project, material developments may occur throughout the Project lifecycle. 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). Material delays, significant cost increases, major contractual disputes, serious QESH incidents, regulatory developments, or other events capable of materially affecting the Project will also be subject to appropriate internal escalation and disclosure requirements. Project Cost and Schedule Transparency The Company will maintain appropriate systems for monitoring Project costs, commitments, expenditures, contingencies, and schedule performance. Management reporting will compare actual Project performance against approved budgets and schedules and identify material variances requiring management attention. Significant deviations in CAPEX, development expenditure, procurement costs, construction progress, critical-path activities, commissioning, or expected COD will be escalated through the Company’s governance structure according to defined thresholds. This approach will enable the Board and management to identify emerging issues early and take timely corrective action. Enterprise Risk Management Disclosure Transparency is closely connected to the Company’s Enterprise Risk Management (ERM) Framework. Material risks identified through the ERM process will be appropriately communicated to the Board and relevant decision-makers. Risk reporting will include, where appropriate, the nature of the risk, potential impact, probability, mitigation measures, responsible risk owner, residual exposure, and changes in risk profile. Particular attention will be given to risks associated with LNG supply, commodity prices, PPAs and offtake, financing, permitting, EPC/EPCM execution, construction, technology, transmission, process safety, environmental and social matters, counterparties, cybersecurity, and business continuity. QESH and Operational Performance GNL Guatemala S.A. recognizes that transparency should extend beyond financial performance. The Company will establish appropriate reporting mechanisms for Quality, Environment, Safety and Health (QESH) performance throughout Project development, construction, commissioning, and operations. Relevant indicators may include occupational incidents, process-safety events, environmental performance, regulatory compliance, audits, corrective actions, contractor safety performance, asset reliability, and other material operational indicators. Serious incidents will be reported and investigated in accordance with applicable legal, regulatory, contractual, and Company requirements. Environmental and Social Transparency The Company will seek to maintain appropriate transparency regarding the environmental and social impacts associated with its activities. Relevant environmental and social information will be communicated to authorities, lenders, communities, and other stakeholders as required by applicable legislation, permits, financing standards, and Project commitments. Where appropriate, the Company may communicate information concerning environmental monitoring, mitigation measures, community-development programs, stakeholder engagement, grievance mechanisms, local employment, local procurement, and other material ESG-related matters. This approach is intended to strengthen trust and demonstrate that environmental and social commitments are supported by measurable actions and performance. Related-Party Transactions and Conflicts of Interest Transactions involving directors, shareholders, executives, affiliates, or other related parties will be handled in accordance with applicable laws and the Company’s corporate-governance requirements. Material related-party transactions should be appropriately documented, reviewed, approved, and disclosed to the relevant corporate bodies as required. Directors, officers, and employees will be expected to disclose actual or potential conflicts of interest and avoid participating in decisions where their personal interests could improperly influence their responsibilities to the Company. Procurement and Contracting Transparency Given the significant value of contracts associated with LNG terminals, power-generation facilities, pipelines, transmission infrastructure, and major equipment, procurement integrity will form an important component of the Company’s transparency framework. Material procurement and contracting activities will be conducted according to appropriate authorization procedures, technical and commercial evaluation criteria, delegated authorities, and documentation requirements. The Company will seek to ensure that significant contracts are awarded based on legitimate business considerations including technical capability, commercial competitiveness, quality, QESH performance, experience, financial capacity, compliance, and ability to deliver. Anti-Bribery, Anti-Corruption and Ethical Conduct Transparency cannot be separated from ethical business conduct. GNL Guatemala S.A. will maintain a zero-tolerance approach toward bribery, corruption, fraud, kickbacks, and other improper business practices. Appropriate policies and controls will address interactions with public officials, procurement activities, gifts and hospitality, conflicts of interest, third-party intermediaries, sponsorships, donations, and other areas presenting elevated compliance risks. Employees and relevant business partners will be expected to comply with the Company’s ethical standards and applicable anti-corruption legislation. Confidentiality and Responsible Disclosure Transparency does not require the unrestricted disclosure of all Company information. 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. The Company will therefore seek an appropriate balance between transparency and the protection of legitimate corporate, contractual, commercial, and privacy interests. Access to confidential information will be controlled according to business need, contractual obligations, and applicable legal requirements. Records and Document Management Reliable disclosure depends on reliable records. The Company will establish document-management and record-retention procedures to maintain appropriate corporate, financial, technical, contractual, regulatory, environmental, safety, and Project documentation. Material decisions and approvals will be appropriately documented to provide traceability, accountability, and an auditable record of the Company’s activities. Document control will be particularly important throughout engineering, procurement, construction, commissioning, and operations, where accurate technical records are essential for quality assurance, asset integrity, regulatory compliance, and safe operations. 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. Concerns raised in good faith will be evaluated appropriately and, where necessary, investigated. The Company will seek to protect individuals who report legitimate concerns in good faith from inappropriate retaliation. Governance, Assurance and Accountability The Board of Directors and executive management will have responsibility for promoting a culture in which transparency and accountability are embedded in decision-making. Management will periodically evaluate the effectiveness of the Company’s reporting, internal controls, risk-management processes, and disclosure practices. Internal reviews, external audits, independent technical assessments, lender due diligence, QESH audits, and other assurance mechanisms may be utilized as appropriate to provide confidence in the reliability of information and the effectiveness of Company controls. 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. Through accurate financial reporting, disciplined Project controls, responsible disclosure of material developments, transparent risk management, strong ethical standards, and open engagement with our stakeholders, the Company seeks to establish the governance foundation required for a major international LNG-to-Power infrastructure project. 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. By integrating transparency with our Corporate Governance, Enterprise Risk Management, QESH, Corporate Social Responsibility, Stakeholder Engagement, and Project Management systems, GNL Guatemala S.A. seeks to develop a business that is not only commercially successful, but also accountable, bankable, responsible, and worthy of long-term stakeholder confidence.