PREAMBLE

Meridian Energy Group Inc., (“Meridian” or the “Company”) understands that large infrastructure and industrial Projects can have adverse impacts on people and on the environment. As developers of multiple large projects (“Projects”), the Company works with its partners and contractors (“Partners”) to identify, assess and manage environmental and social risks and impacts in a structured way, and on an ongoing basis. Such collaboration promotes sustainable environmental and social performance and leads to improved financial, environmental and social outcomes. Where appropriate, Meridian encourages its Partners to address potential or actual adverse risks and impacts identified during the Project Development and Commercial Operations Lifecycle.

Meridian will act in accordance with the applicable Equator Principles in order to ensure that its Projects are developed and operated in a manner that is socially responsible and reflects sound environmental practices. Meridian acknowledges that application of sound environmental and social management policies can contribute to delivering on the objectives and outcomes of the United Nations Sustainable Development Goals (“SDG”) as referenced in the Equator Principles 2020. Specifically, Meridian believes that negative impacts on Project-affected ecosystems, communities, and the climate can be effectively mitigated and, where residual impacts remain, a remedy for human rights impacts or offset to environmental impacts should be provided as appropriate.

Meridian’s Environmental and Social Management Plan is intended to serve as a common baseline and framework for Meridian’s employees and Partners to identify, assess and manage environmental and social risks when developing Projects. We commit to implementing the Equator Principles through our internal environmental and social policies. Meridian also acknowledges that it has broader responsibilities for identifying and managing adverse environmental and social risks and impacts and respecting Human Rights.

Meridian will review and update its Environmental and Social Management Plan on a periodic basis, as needed and no less than annually, based on implementation experience and in order to reflect ongoing learning, emerging good practices, and the advice of Meridian’s Environmental, Social and Governance Steering Committee.

Company Overview

Meridian was formed to beneficially change the refining segment of the energy industry that has been increasingly identified with air pollution and other harmful environmental impacts. The construction and operation of Meridian’s Refineries will utilize state-of-the-art technologies as this will improve the quality and viability of fuels and petroleum products manufactured in the United States.

Environmental and Social Management Components

As part of its fundamental project development strategies, Meridian will address relevant environmental and social risks and scale of impacts of proposed Projects. The Company’s assessment documentation will propose measures to minimize, mitigate, and where residual impacts remain, to compensate/offset/remedy for risks and impacts to workers, affected communities, and the environment, in a manner relevant and appropriate to the nature and scale of the proposed Project.

The assessment documentation will be an adequate, accurate and objective evaluation and presentation of the environmental and social risks and impacts, whether prepared by Meridian, consultants or external experts. Where appropriate, the assessment documentation will include an environmental and social impact assessment, and for minor projects or scope added to an existing project, a limited or focused environmental or social assessment may be appropriate, applying applicable risk management standards relevant to the risks or impacts identified. The depth and nature of the Climate Change Risk Assessment will depend on the type of Project as well as the nature of risks, including their materiality and severity.

The Assessment process will address compliance with relevant city, county, state and federal laws, regulations and permits that pertain to relevant environmental and social issues. Meridian operates in US markets with robust local, state and federal environmental and social governance, legislation systems and institutional capacity designed to protect their people and the environment. Meridian will, with supporting advice, where appropriate, evaluate each Project’s compliance with the applicable standards. This may include a review of a Project’s overall compliance with, or justified deviation from, the applicable standards, and Meridian may, at its sole discretion, undertake additional due diligence against additional standards relevant to specific risks of the Project and apply additional requirements.

For all Projects, Meridian will (with supporting advice, where appropriate) develop and maintain an Project Specific Environmental and Social Management Plan (“PESMP”) to identify, assess and manage risks and impacts in respect to that Project on an ongoing basis. If requested by its financial advisors, Meridian will provide an Equator Principles Action Plan (“EPAP”) to address any gaps in Meridian’s plans, systems or documentation.”

The purpose of the Environmental, Social and Governance Committee of Meridian Energy Group Inc., is to support the Company’s on-going commitment to environmental, health and safety, corporate social responsibility, corporate governance, sustainability, and other public policy matters relevant to the Company (collectively, “ESG Matters”). The ESGC is a cross-functional senior management committee of the Company. It will assist the CEO of the Company in (a) setting general strategy relating to ESG Matters, (b) developing, implementing, and monitoring initiatives and policies based on that strategy, (c) overseeing communications with employees, investors and stakeholders with respect to ESG Matters, and (d) monitoring and assessing developments relating to, and improving the Company’s understanding of ESG Matters.

Meridian is committed to the environmental and social conditions of the communities it will serve. Meridian has performed a baseline environmental assessment of its operations as part of its permitting processes and as a measure of assurance of corporate citizenship. The environmental and social stewardship will remain in a sustainable improvement path as part of Meridian’s corporate governance.

Meridian is having a positive impact on social conditions in the regions it conducts business. The development of Meridian’s facilities will create direct and indirect jobs making a significant contribution to the local economy. Meridian is actively promoting the participation of local businesses and service organizations. Meridian supports, and will comply with, the efforts of the U.S. State Department in preventing human trafficking as part of the Protocol to Prevent, Suppress, and Punish Trafficking in Persons. Human trafficking has a disproportionate impact on women, children, and vulnerable groups.

Meridian will demonstrate effective stakeholder engagement, as an ongoing process in a structured and culturally appropriate manner, with affected communities, workers and, where relevant, other stakeholders.

For Projects with potentially significant adverse impacts on affected communities, meridian will conduct an informed consultation and participation process. Meridian will tailor its consultation process to: the risks and impacts of the Project; the Project’s phase of development; their decision-making processes; and the needs of disadvantaged and vulnerable groups. This process will be free from external manipulation, interference, coercion and intimidation.

To facilitate stakeholder engagement, Meridian will, commensurate with the Project’s risks and impacts, make the appropriate assessment documentation readily available to the affected communities, and where relevant other stakeholders, in a culturally appropriate manner. Meridian will take account of, and document, the results of the stakeholder engagement process, including any actions agreed resulting from such process. Disclosure of environmental or social risks and adverse impacts will occur early in the assessment process, in any event before the Project construction commences, and on an ongoing basis.

Meridian recognizes that Indigenous Peoples may represent vulnerable segments of Project- Affected Communities. All Projects affecting Indigenous Peoples will be subject to a process of informed consultation and participation, and will need to comply with the rights and protections for Indigenous Peoples contained in relevant national law, including those laws implementing host country obligations under international law which include any of the following:

  • Projects with impacts on lands and natural resources subject to traditional ownership or under the customary use of Indigenous Peoples,
  • Projects with significant impacts on critical cultural heritage essential to the identity of Indigenous Peoples, or
  • Projects using their cultural heritage for commercial purposes.

For Projects that meet these special circumstances, Meridian may seek the participation of a qualified independent consultant to evaluate the consultation process with Indigenous Peoples, and the outcomes of that process, against the requirements of host country laws. Where Stakeholder Engagement, including with Indigenous Peoples, is the responsibility of the host government, Meridian will collaborate with the responsible government agency during the planning, implementation and monitoring of activities, to the extent permitted by the agency.

Meridian, as part of its ESMS, will establish effective grievance mechanisms which are designed for use by affected communities and workers, as appropriate, to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance. Grievance mechanisms will be scaled to the risks and impacts of the Project, and will seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate, readily accessible, at no cost, and without retribution to the party that originated the issue or concern. Grievance mechanisms will not impede access to judicial or administrative remedies. Meridian will inform Affected Communities and Workers about the grievance mechanisms in the course of the stakeholder engagement process.

Where deemed appropriate by Meridian, independent environmental and social consultants will be engaged to carry out an independent review of the Company’s assessment process including the ESMPs, the ESMS, and the stakeholder engagement process documentation in order to assist Meridian’s due diligence and determination of compliance to its Environmental and Social Management System.

An important strength of Meridian’s ESMS is the incorporation of covenants linked to compliance. For all Projects, where Meridian is not in compliance with its environmental and social covenants, Meridian will work on remedial actions to bring the Project back into compliance by working through an action plan developed by Meridian’s Environmental, Social and Corporate Governance Committee (“ESGC”).

The following Meridian reporting requirements are in addition to any disclosure requirements previously discussed.

  • Meridian will ensure that, at a minimum, a summary of the Company’s principal ESG documentation and policies is accessible and available online and that it includes a summary of Human Rights and climate change risks and impacts when relevant.
  • Meridian will report publicly, on an annual basis, GHG emission levels (and, if appropriate, the GHG efficiency ratio) during the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually.
  • Meridian will share commercially non-sensitive Project-specific biodiversity data with the Global Biodiversity Information Facility (“GBIF”) and relevant national and global data repositories, using formats and conditions to enable such data to be accessed and re-used in future decisions and research applications.

Meridian will, at least annually, report publicly on transactions that have reached Commercial Operations and on its ESMS implementation processes and experience.

An alternatives analysis requires the evaluation of technically and financially feasible and cost-effective options available to reduce Project-related GHG emissions during the design, construction and operation of the Project. This analysis may endeavor to ascertain the best practicable environmental options and will include consideration of alternative energy sources if applicable. Where an alternatives analysis is required by a regulatory permitting process, the analysis will follow the methodology and time frame required by the relevant process. The alternatives analysis will include comparisons to other viable technologies, used in the same industry and in the country or region, with the relative energy efficiency, GHG efficiency ratio, as appropriate, of the selected technology. Following completion of an alternatives analysis, Meridian will provide, through appropriate documentation, evidence of technically and financially feasible and cost-effective options and justification on why the alternative technologies were not selected.

GHG emissions will be calculated to allow for aggregation and comparability across Projects, organizations and jurisdictions. Public reporting requirements can be satisfied via state or federal regulatory requirements for reporting or environmental impact assessments, or voluntary reporting mechanisms such as the Carbon Disclosure Project, where such reporting includes emissions at Project level. Where appropriate, Meridian will publish a summary of the alternatives analysis. In some circumstances, public disclosure of the full alternatives analysis or Project-level emissions may not be appropriate.

The climate change risk assessment for a given Project will address the current and anticipated climate risks (transition and/or physical) of the Project’s operations, and Meridian’s plans, processes, policies and systems to manage these risks (i.e. to mitigate, transfer, accept or control). This assessment will also consider the Project’s compatibility with national climate commitments, as appropriate.

The Company will report annually and as per the requirements detailed in all of the appropriate sections of the ESMP.

Data and implementation reporting will be published on Meridian’s website, in a single location and in an accessible format. Meridian will specify the reporting period (i.e. start and end dates) for all data and implementation reporting.

Meridian will report internally on its ESMP implementation, including:

  • The mandate of the ESMP Reviewers (ESGC);
  • The MOM from scheduled and non-scheduled ESGC assemblies.
  • The respective roles of the ESGC, business lines, and senior management in the transaction review process.

This list below provides an overview of issues that may be addressed in the assessment documentation for a given Project. Note the list is for illustrative purposes only. The assessment process of each Project may or may not identify all of the issues listed or be relevant to every Project. The assessment documentation may include, where applicable, the following:

  1. assessment of the baseline environmental and social conditions
  2. consideration of feasible environmentally and socially preferable alternatives
  3. requirements under host country laws and regulations and applicable international treaties and agreements
  4. protection and conservation of biodiversity (including endangered species and sensitive ecosystems in modified, natural and Critical Habitats) and identification of legally protected areas
  5. sustainable management and use of renewable natural resources (including sustainable resource management through appropriate independent certification systems)
  6. use and management of dangerous substances
  7. major hazards assessment and management
  8. efficient production: total energy consumed, delivery and use of energy
  9. pollution prevention and waste minimization, pollution controls (liquid effluents and air emissions), and waste management
  10. greenhouse gas emissions level and emissions intensity
  11. water usage, water intensity, water source
  12. land cover, land use practices
  13. consideration of physical climate risks and adaptation opportunities, and of viability of Project operations under changing weather patterns/climatic conditions
  14. cumulative impacts of existing Projects, the proposed Project, and anticipated future Projects
  15. consideration of actual or potential adverse Human Rights impacts and if none were identified, an explanation of how the determination of the absence of Human Rights risks was reached, including which stakeholder groups and vulnerable populations (if present) were considered in their analysis
  16. labor issues and occupational health and safety
  17. consultation and participation of affected parties in the design, review and implementation of the Project
  18. socio-economic impacts
  19. impacts on Affected Communities, and disadvantaged or vulnerable groups
  20. gender and disproportionate gender impacts
  21. land acquisition and involuntary resettlement
  22. impacts on Indigenous Peoples, and their unique cultural systems and values including impacts to lands and natural resources subject to traditional ownership or under customary use
  23. protection of cultural property and heritage
  24. protection of community health, safety and security (including risks, impacts and management of Project’s use of security personnel)
  25. fire prevention and life safety