ESG Policy

E1.1 Net Zero Target Hedron Holdings is committed to achieving net zero greenhouse gas emissions across its direct operations (Scope 1 and Scope 2) by 2040, with an interim target of 50% reduction by 2030 against a 2024 baseline.

E1.2 Paris Agreement Alignment Our climate strategy is aligned with the objectives of the Paris Agreement to limit global warming to 1.5°C. We support Bangladesh's Nationally Determined Contribution (NDC) under the UNFCCC.

E1.3 Energy Transition Contribution Our Energy division develops utility-scale solar and battery storage infrastructure as a direct contribution to Bangladesh's energy transition. We are committed to:

• Increasing renewable energy share in Bangladesh's national grid
• Enabling industrial decarbonisation through clean energy access
• Developing battery storage to reduce fossil-fuel peaking plant dependency

E1.4 TCFD Disclosure Hedron Holdings adopts the TCFD framework for identifying, assessing, and disclosing climate-related risks and opportunities in our operations and financial planning.

E2.1 We set annual energy consumption reduction targets and monitor performance quarterly across all facilities.

E2.2 All new facilities and infrastructure developed by Hedron Holdings are designed to meet or exceed applicable green building standards.

E2.3 Our Energy Transportation division is committed to progressively reducing the carbon intensity of fuel logistics by optimising routes, increasing inland waterway utilisation (lower per-tonne-km emissions than road transport), and transitioning fleet assets to cleaner fuels where commercially feasible.

E3.1 All land-use decisions — including site selection for solar projects, logistics infrastructure, and facilities — are subject to Environmental and Social Impact Assessments (ESIAs) conducted in accordance with IFC Performance Standard 6 (Biodiversity) and applicable Bangladesh environmental regulations.

E3.2 No Net Loss Policy Where impact on biodiversity cannot be avoided, we implement mitigation and offset measures to achieve biodiversity neutrality.

E3.3 Exclusion Zones We do not develop on Ramsar wetlands, protected areas, UNESCO World Heritage sites, or critical biodiversity habitats as defined under IFC Performance Standard 6.

E4.1 Pollution prevention hierarchy: avoid → reduce → reuse → recycle → responsible disposal.

E4.2 Our Energy Transportation division maintains strict protocols for petroleum fuel handling, storage, and transportation, including spill prevention and response plans compliant with Bangladesh Environment Conservation Act 1995.

E4.3 Construction and operational waste is managed through licensed contractors in compliance with Bangladesh Solid Waste Management rules.

E4.4 Battery technology selection: Our Energy division uses LiFePO₄ chemistry — selected in part for its superior environmental profile: zero toxic heavy metals, low thermal runaway risk, and recyclability. End-of-life battery management plans are embedded in all BESS project contracts.

E5.1 Water risk assessments are conducted for all project sites located in water-stressed areas.

E5.2 Our inland waterway operations comply with all applicable Bangladesh water quality and navigation standards. We maintain a zero discharge policy for petroleum products into inland waterways.

E5.3 Water consumption and recycling rates are monitored and reported annually across all facilities.

S1.1 Hedron Holdings respects and upholds worker rights under the Bangladesh Labour Act 2006, ILO Core Conventions, and all applicable labour standards.

S1.2 We provide:

• Safe working conditions compliant with OHS regulations
• Fair compensation at or above statutory minimum wages
• Equal opportunity employment free from discrimination
• Formal employment contracts for all staff
• Full leave entitlements including maternity/paternity leave
• Freedom of association and collective bargaining rights

S1.3 Forced Labour & Modern Slavery Zero tolerance across all operations and supply chains. No forced labour, child labour, human trafficking, or any form of modern slavery is tolerated at any level of our business.

S1.4 All suppliers and contractors certify labour standards compliance as a condition of engagement.

S2.1 Target: Zero lost-time injuries and zero fatalities across all operations.

S2.2 Safety framework includes:

• Site-specific health and safety management plans
• Mandatory safety inductions for all site personnel
• Regular audits and inspections
• Near-miss reporting and root cause analysis
• Emergency response plans for all facilities
• Appropriate personal protective equipment (PPE)

S2.3 Special protocols apply to petroleum fuel handling in our Energy Transportation division — including driver certification, vehicle inspection schedules, hazardous materials training, and route risk assessments.

S3.1 Community Consultation For all projects with potential community impacts, we conduct free, prior, and informed consultation in accordance with IFC Performance Standards 5 and 7.

S3.2 Grievance Mechanism We maintain an accessible, transparent grievance mechanism for project-affected communities. Grievances are logged, investigated, and resolved within defined timelines.

S3.3 Local Employment We are committed to maximising local employment and procurement in communities where we operate, particularly during construction and operational phases.

S3.4 Community Development Where we operate in communities with significant social needs, we invest in development initiatives aligned with:

• SDG 4: Quality Education
• SDG 7: Affordable and Clean Energy
• SDG 8: Decent Work and Economic Growth

S4.1 We are committed to building a diverse and inclusive workplace that reflects the diversity of Bangladesh's society.

S4.2 Active commitments:

• Gender parity in recruitment, retention, and advancement
• Equal pay for equal work — with regular pay equity audits
• Inclusive policies for employees with disabilities
• Diverse representation in leadership positions

S4.3 Women in Infrastructure Recognising the underrepresentation of women in infrastructure sectors, Hedron Holdings maintains targeted initiatives to recruit, develop, and retain women professionals across Energy, Transportation, and Technology divisions.

S4.4 We publicly report diversity metrics annually — including gender ratios by level, pay gap data, and senior leadership representation.

S5.1 Hedron Holdings conducts human rights due diligence across operations and supply chains in accordance with the UN Guiding Principles on Business and Human Rights (UNGPs).

S5.2 Our due diligence process includes:

• Human rights risk mapping for new projects
• Supplier screening for human rights compliance
• Contractual requirements for subcontractors
• Ongoing monitoring and corrective action
• Annual reporting on performance and remediation

S5.3 Where human rights violations are identified, Hedron Holdings takes immediate corrective action and, where harm has occurred, contributes to remedy in accordance with the UNGPs.

G1.1 Board Oversight The Board of Directors bears ultimate accountability for ESG performance, reviewing and approving ESG strategy, targets, and performance annually.

G1.2 ESG Committee A dedicated committee reporting to the Board is responsible for developing and implementing the ESG framework, monitoring performance, overseeing reporting, and engaging stakeholders.

G1.3 Management Accountability ESG targets are embedded in performance frameworks of all senior management. Division heads are accountable for ESG performance in their areas.

G1.4 Governance Documents Hedron Holdings maintains:

• Board Charter
• Code of Conduct
• Delegation of Authority Matrix
• Conflict of Interest Policy
• Whistleblower Policy
• Related Party Transactions Policy — all reviewed annually.

G2.1 Zero Tolerance Hedron Holdings maintains zero tolerance for all forms of bribery, corruption, facilitation payments, and unethical business conduct — at every level of the organisation and supply chain.

G2.2 Applicable Law

• Anti-Corruption Commission Act 2004 (Bangladesh)
• Prevention of Corruption Act 1947 (Bangladesh)
• UK Bribery Act 2010 (where applicable)
• US Foreign Corrupt Practices Act (where applicable)

G2.3 Anti-Corruption Controls

• Mandatory annual anti-corruption training for all staff
• Enhanced due diligence for high-risk third parties
• Gifts and hospitality policy with defined thresholds
• Segregation of duties in procurement and approvals
• Internal audit programme covering corruption risk areas

G2.4 Gifts & Hospitality No employee may offer, give, request, or accept gifts or hospitality that could be perceived as influencing a business decision, is directed to a government official (beyond nominal ceremonial value), or is not disclosed and approved through our Gifts Register.

G2.5 Political Contributions Hedron Holdings does not make political contributions — directly or indirectly — to any political party, candidate, or organisation in any jurisdiction.

G3.1 Hedron Holdings maintains a confidential and independently managed reporting channel for concerns about:

• Suspected corruption or bribery
• Violations of law or Hedron Holdings policy
• Unethical or unsafe conduct
• Environmental incidents or violations
• Any other matter of concern

G3.2 All reports are investigated promptly. Strict confidentiality is maintained throughout.

G3.3 Non-Retaliation Hedron Holdings prohibits all retaliation against good-faith reporters. Retaliation is itself grounds for disciplinary action up to termination.

G3.4 Contact the reporting channel at: compliance@hedronholdings.com

G4.1 ESG standards are applied to our supply chain through:

• A Supplier Code of Conduct with minimum ESG standards
• Supplier pre-qualification requiring ESG disclosure
• Periodic audits for high-risk or high-value suppliers
• Contractual ESG compliance obligations
• Preference for ISO 14001-certified suppliers

G4.2 We are committed to progressively improving supply chain ESG performance through capacity building, collaboration, and transitioning away from non-compliant suppliers.

G4.3 Conflict Materials Hedron Holdings does not knowingly source materials from conflict-affected or high-risk areas in violation of applicable international standards.

G5.1 Annual ESG Report covers:

• GHG emissions, energy, water, and waste data
• Social metrics: diversity, safety, community investment
• Governance: board composition, compliance incidents
• Progress against ESG targets
• Key ESG risks and opportunities

G5.2 Reporting Frameworks

• Global Reporting Initiative (GRI) Standards
• TCFD Recommendations
• UN Sustainable Development Goals (SDGs)
• IFC Performance Standards

G5.3 Independent Verification Selected metrics — including GHG emissions — are subject to third-party verification by an accredited verifier.

G5.4 Transparency Commitment Hedron Holdings reports honestly on both achievements and areas for improvement. We do not make unsubstantiated ESG claims.

Institutional clients and investors may request Hedron Holdings' ESG data room and due diligence materials by contacting: esg@hedronholdings.com

Annual targets for all KPIs are set by the ESG Committee and approved by the Board. Performance is reported in the Annual ESG Report, published each June.

Next ESG Report: June 2026