GroundWork believes in environmental, social and corporate governance stewardship

Introduction

Our commitment to managing material ESG factors

GroundWork recognizes that its operations can have both direct and indirect impacts on the environment and local communities and that certain environmental, social, and governance factors can pose risks to our clients, employees and financial performance. We also believe that effective management of these factors requires a proactive view and active management. What follows is our approach to those factors which we view to be most material to our business, in three groups:

1. ESG Factors Related to Our Products and Services

   GroundWork is committed to providing best-in-class meteorological products and services to our clients. In doing so, there are certain inevitable risks that we have identified will need to be managed effectively. As an equipment provider to utility-scale solar developers and operators, we are fully accountable for the lifecycle impacts of our products, including, but not limited to, product distribution, end-of-life product management, and waste generation. Through our software-based data quality and management program, we are also exposed to range of risks related to the implementation and use of our software products provided to the market. These risks, related to the product design & lifecycle management, supply chain management, hazardous waste & materials management, and data security, are highlighted below.

   1. Product Design & Lifecycle Management: GroundWork at times is responsible for managing the lifecycle impacts of our products and services, which occurs during production, product use-phase and at the end of life (for our Rey Program equipment). In our production facilities, in which we assemble, refurbish, package, and distribute our MET stations, we maintain best practices regarding the safety of employees and environmental impact of our distribution practices. GroundWork is thoroughly dedicated to the end-of-life sustainability of our applicable products. Our team trains field technicians in the proper processes of disposal for decommissioned GroundWork Rey Program equipment and tools, and our broad guidance is to prioritize the reuse of materials. Field Teams are permitted to give away batteries and solar panels used in remote power units to local technicians, landowners, or local community members. They are also permitted to take the materials themselves if they did not utilize air travel to the work site and can safely transport the materials to their residence. All metal materials are to be taken first to a metal recycle place locally, or if a recycling facility is not in close proximity, disposed of at a dump. Batteries (if not reused) are to be taken to a Walmart or AutoZone or similar for recycling.
   2. Supply Chain Management: We at GroundWork aim to uphold the highest ethical standards and strive to do business with suppliers who share these commitments. We believe GroundWork and our suppliers are jointly responsible for ensuring the social and environmental responsibility of our product, and we prioritize traceability and transparency across our supply chain. Our suppliers are expected to adhere to our Code of Conduct for Suppliers, which highlights our expected commitment to business ethnics, humane workplace practices, and health & safety. We seek out suppliers committed to environmental responsibility and ask each vendor about their in-house environmental practices (i.e. waste reduction), environmental certifications, and materials used in manufacturing products.
   3. Hazardous Waste & Materials Management: As a supplier to utility-scale solar developers, our products are exposed to environmental issues associated with hazardous and non-hazardous waste generation. In our Safety & Health Manual, we provide clear instructions on the proper handling of all combustible materials. While handling of these materials generally lies outside the GroundWork scope, we ensure the treatment, handling, storage, and disposal of any materials follows our Waste Disposal Plan and aligns with regulatory compliance.
   4. Data Security: Increasingly, all software-enabled businesses are exposed to threats from cyber-attacks and/or social engineering, and GroundWork is not an exception. Through our years of providing MET services, we have amassed a detailed and comprehensive data set for the solar power planning industry, which is a valuable asset for GroundWork. As we continue to expand our software offering, we are committed to an ever-improving security stance with continuous improvement of security controls, cyber security training, data ingestion and cleansing processes, parallel scheduling, and data analytics capabilities.

2. ESG Factors Related to Our People and Communities

   A deep commitment to social responsibility and to our people and our communities is core to who we are as a company. We believe people are at the heart of our business and we take pride in our outstanding work culture and strive to be the preferred employer to our workforce as well as a valued partner to our communities. Specifically, GroundWork is exposed to a range of social risks and opportunities, including those related to recruiting and maintaining a diverse and skilled workforce, the health, safety and human rights of that workforce, and engagement with the communities in which we operate. We believe that focusing on these issues makes GroundWork a better company and we focus our efforts in the following areas:

   1. Diversity, Inclusion and Equity: A core value of GroundWork is diversity in all its forms, whether race, color, creed, gender (including gender identity and gender expression), religion, marital status, registered domestic partner status, age, national origin or ancestry, physical or mental disability, medical condition, sex, genetic information, sexual orientation, or veteran status. Equal opportunity is integral to our recruitment process, as we view an inclusive community of diverse talent as a strong competitive advantage and supportive of the Company’s success. GroundWork is committed to providing a work environment free of harassment, disrespectful or other unprofessional conduct. The Anti-Harassment Policy outlined in our Employee Handbook prohibits discrimination and harassment in all aspects of the employment relationship and prohibits retaliation against individuals reporting concerns or violations of the policy. We seek to maintain a positive workplace, free from discrimination and harassment of any kind.Our commitment to diversity and inclusion applies to the highest levels of the organization, including at the board level, where we recognize that diversity strengthens board performance and promotes long-term shareholder value. To this end, GroundWork is committed to monitoring gender and racial diversity amongst the members of its board of managers and, where possible, seeking out board members who contribute perspectives not currently captured by board members.GroundWork is also dedicated to tracking pay equity for our team members to ensure a fair environment where all employees can grow and be rewarded fairly for their merit and contributions to the success of GroundWork. We have committed to an annual employee census study in which we review gender and racial pay equity to ensure that significant disparities do not exist at any level of the business. Where notable disparities are identified, we will take action to address those issues in line with the Company’s HR policies.
   2. Compensation and Benefits: We know that the first step in hiring and retaining the best talent is to offer inspiring and rewarding roles where people feel valued and part of the team. We offer competitive compensation and benefits to all regular full-time employees, including but not limited to paid holiday, paid time off, retirement savings plans, and medical, dental, and vision coverage among other benefits outlined in GroundWork’s Employee Handbook.
   3. Culture, Engagement and Growth: We believe in a fun, spirited work environment that rewards innovation, merit and collaboration at all levels. Every new employee is given a copy of the GroundWork Employee Handbook and Code of Ethics, which embodies the ethos of what GroundWork does every day. Our Code of Ethics serves as a guide for proper business conduct for all our employees and outlines our core principles: 1) Be Caring, 2) Be Safe, 3) Be Trustworthy, and 4) Be a Partner First. GroundWork operates an “open door policy” whereby employees can provide feedback, raise ideas, or voice concerns with company leaders at any time. We also aim to foster both personal and professional growth for employees at all levels of the organization through annual performance reviews, role-specific training, and professional development opportunities.
   4. Health and Safety: The health and safety of our employees, customers, and vendors is of the utmost importance to us. In accordance with GroundWork’s Safety & Health Manual, we are committed to ensuring the work of the Company is performed in the safest possible manner and consistent with local and federal regulations. Our Safety & Health Manual details Company policies concerning ergonomics, workplace violence, vehicle safety, and shop & field safety. We strictly follow applicable OSHA guidelines and supply our employees with full personal protective equipment for every role to minimize exposure to hazards that could cause workplace injuries. We are sure to routinely review information discovered through analyses to improve safety processes, such as incident analysis and employee concerns.
   5. Human Rights: GroundWork is dedicated to the preservation of basic rights and human dignity in our workplace and beyond. We are committed to meeting fundamental responsibilities in the areas of ethics, human rights, labor, safety, environment, and community, and hold our partners – including our employees, contractors, clients, suppliers – to the same set of principles. We support internationally recognized human rights principles that promote and protect human rights. Specifically, GroundWork seeks to align with:
      1. The OECD Guidelines for Multinational Enterprises, which are the most comprehensive international standard on responsible business conduct, covering key areas of business responsibility related to human rights, labor rights, bribery, consumer interests, and environmental protection.
      2. The UN Global Compact, which is a set of 10 principles for responsible business conduct related to human rights, labor, anti-corruption, and environmental protection.

      GroundWork views these frameworks as the minimum threshold of corporate responsibility and sets a higher bar for itself and its employees, as outlined in this document.

3. ESG Factors Related to Governance and Transparency

   We view good governance and transparency to our stakeholders as essential to creating and preserving value for GroundWork. This includes a sound approach to corporate governance that complies with all applicable laws, rules, regulations, and policies as well as unwavering adherence to our values. We focus our efforts in the following areas:

   1. Corporate Governance and Disclosure: We have an effective and highly skilled board of managers. A key fiduciary duty of our directors is to ensure that GroundWork is operated with the highest degree of equity, fairness, transparency, and ethics possible. To this end, we embrace board diversity in all its facets, and look to include a mix of experiences, expertise, and overall diversity of viewpoints. GroundWork will report relevant ESG and impact metrics to the board of managers, who will ensure accountability for ESG and impact metrics, thus fostering responsible corporate practices throughout the organization.
   2. Ethics and Competitive Behavior: Our board of managers and all employees, including senior management, conduct themselves in accordance with the highest moral and ethical standards, informed by robust employee conduct expectations detailed in our Employee Handbook and Code of Ethics. We are committed to ensuring a fair workplace for our employees as well as partners with whom we do business. We have strict policies to protect against discrimination, harassment, and retaliation. We have an open-door policy to encourage honest and direct communication to resolve issues and concerns in an expeditious manner.At a minimum, GroundWork operates to meet or exceed the requirements of all laws and regulations wherever we are operating, and in the event the Company operates unlawfully, employees are directed to report such instances to their managers or the board of managers. On our website, we include an Ethics Complaint Form for any employees, contractors, clients, or suppliers to disclose information in respect to workplace-related criminal or other irregular behavior. We also include our Code of Ethics, which serves as a guide for all employees, and emphasizes our company values of being Caring, Trustworthy, Knowledgeable, Trailblazing, Nimble, and Meticulous. Upholding high ethical standards is a core part of our identity at GroundWork.GroundWork is proud of our differentiated MET solutions provided to customers, but also recognizes that unethical behavior that unfairly suppresses competition will not be tolerated under any circumstances.
   3. Conflict of Interest: The Company demands all employees maintain the highest level of integrity and objectivity in performing their job duties. Employees are expected to conduct their business dealings with suppliers, vendors and customers in a manner that will avoid any conflict of interest, or even an appearance of a potential conflict of interest, between the employee’s interests and the interests of the Company. Any solicitation of, or requirement of, gratuities or gifts from suppliers, vendors, co-workers or from any other third party is strictly prohibited.It is essential for the protection of both the employee and the Company to avoid any situations which might constitute a conflict of interest such as employment by, or financial interest in, the business of a competitor, supplier, or customer of the Company. Therefore, the Company has adopted the following guidelines:
      1. As a condition of employment, no employee or any member of employee’s immediate family, without prior written consent of the CEO or HR Leader, may have any financial interest in any of the following:
         1. A business supplying the Company;
         2. A customer of the Company; or
         3. A competitor of the Company.

         The only exception to the above policy is for investment in securities of publicly traded companies in which the employee holds such securities purely for investment purposes in a personal trading account or 401(k) or similar retirement plan. An example would be Amazon.com, from whom the company purchases its AWS hosting and compute services. Employees are encouraged to speak with their manager if they have any concerns or questions about the implementation of the above policy.

      2. The Company will not rent, lease, or buy property from an employee or an employee’s relative without the prior written consent of the CEO, or in the case of the CEO, the board of managers.
      3. An employee may not do business with a relative on behalf of the Company without prior written consent of the CEO.
      4. An employee may not give or accept a materially significant gift, loan or unreasonable favors from a person having business relations with the Company. This does not prohibit small gifts or casual entertainment which are ethically proper. If a person offers an employee a gift or unreasonable favor, the employee has a duty to immediately report the incident to their direct manager or CEO.

Our DE&I Goals and Initiatives.

GroundWork will implement its DE&I mission through the following goals and initiatives:

• Representation and Recruitment: We are committed to attracting and retaining a diverse workforce that mirrors the communities we serve. We actively seek out talent from various backgrounds and ensure fair and equitable recruitment practices.
• Equitable Opportunities: We guarantee that all employees have equal access to growth opportunities, resources, and career advancement. We regularly review and adjust our policies to eliminate barriers and biases.
• Inclusive Culture: We strive to create an environment where all employees feel valued, respected, and included. We celebrate diversity and encourage collaboration across all levels of the organization.
• Accountability and Transparency: We hold ourselves accountable for our DE&I goals through regular reporting and transparent communication. We set clear metrics and benchmarks to measure our progress and share these with our employees.
• Community Engagement: We extend our DE&I commitment beyond our organization by partnering with diverse communities and supporting initiatives that promote equity and inclusion.
• Feedback and Improvement: We actively seek feedback from our employees to continually refine our DE&I policies and practices. We are committed to being responsive and making necessary adjustments to foster a more inclusive workplace.

By embedding these principles into our DE&I policy, we ensure that our commitment to diversity, equity, and inclusion is not only a priority but a reflection of who we are as a company. We live by our values of being Caring, Trustworthy, Knowledgeable, Trailblazing, Nimble and Meticulous. The following principles apply to our Code of Ethics and are part of our Social initiatives within our broader Environmental, Social, and Governmental (ESG) policy.

Implementing GroundWork’s DE&I Program.

ESG Committee: A group of employees, on a voluntary basis, will oversee the initiatives of the DE&I program. These volunteers will be responsible for setting up company actions related to DE&I, with the support of other entities, such as HR.

Company Engagement: All employees are offered a method to participate in the program. This includes, but is not limited to, sharing topics and personal experiences, mentoring opportunities, and providing feedback and evaluation of the program.

All Hands Meetings & Newsletters: Highlight a DE&I topic during each month’s GroundWork All Hands meeting and Company Monthly Newsletter. This moment can be kept brief and employees who are interested in more detail will be directed to resources that expand on each topic.

Training and Education: Management of different branches of the company will support reasonable requests from their internal groups to gain the means and education to embrace diversity, equity and inclusion.

Community Engagement: GroundWork seeks to collaborate with external companies, organizations and communities to promote DE&I beyond the workplace. This includes, but is not limited to, researching SEIA’s DEIJ certification and opportunities for DE&I speakers for education and Q&A sessions.

Metrics and Reporting: The ESG Committee will evaluate means to track how well the DE&I program is being implemented and what impacts its existence has on company performance. They will incorporate these metrics into our annual sustainability reporting. They will also incorporate employee feedback for visibility and program evolvement.