18th February 2021

To our stakeholders:

I am pleased to confirm that Aqualis Braemar LOC reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,

David Wells
Chief Executive Officer

As a global company Aqualis Braemar LOC recognise the importance of human rights and take these very seriously. As a signatory of the United Nations Global Compact, we are committed to ensuring that we are not complicit in human rights abuses through our business operations, supply chain or stakeholder relationships. Although we take pride in the policies that we have put in place, we recognise that through our ESG journey there will be additional review and monitoring work for us to do, where we can make improvements for the good of our stakeholders. We value that our employees are a big part in driving the business forward.

Line management are accountable for policy implementation within regions and our Group functions, of HR and compliance, support management in the communication and training of these. We will, and have a process in place to, investigate all suspected violations of our policies in a fair manner.

Our newly issued Human Rights Statement is aligned with the Company’s Code of Business Conduct. Our Corporate Code of Conduct advocates high standards of honesty, integrity and ethical behaviour in our daily business and expects all representatives of our company to conduct their daily business in a safe, fair, honest, respectful and ethical manner.

We have reviewed and adapted some of our Company polices to align with our ESG principles and this includes issuing a new Human Rights statement.

During 2020 Aqualis Braemar LOC celebrated International Women in Engineering Day (INWED20). It is a campaign that brings together engineers and their supporters from across the world, joining to raise awareness of the opportunities and achievements of women engineers. At the Aqualis Braemar LOC group we wanted to take this opportunity to praise the excellent work that our female engineers do across the globe and celebrate their efforts to shape our world into a better, safer, more innovative, and exciting place to be. We are also looking to enrol female members of staff into GWEC’s development program Women in Wind, which will promote diversity not only in the workplace but in the industry that we work in as well as helping the development of our employees.

For 2021 Aqualis Braemar LOC intends to review and assess topics around the gender pay gap and look at our recruitment strategies to make sure we are upholding fair employment practices. We will be reviewing our internal appraisal review system and would like to further educate line management in recognising development needs for our employees, especially if more businesses adopt a more flexible approach. This will help with setting further goals for SDG 5 – Gender Equality. The business has a number of policies and handbooks across our regions. One target is to review these policies and investigate where we can make them a universal policy.

We value the diversity and inclusion of the people with whom we work and we are committed to equal opportunities. We prohibit discrimination, harassment, forced, trafficked and child and are committed to safe and healthy working conditions and the dignity of the individual. Workplace Integrity means fostering and protecting a corporate environment that is inclusive, safe, and professional.

We do not limit people´s opportunity to contribute or advance based on age, childcare responsibilities, disability, ethnicity, gender, gender expression, sexual orientation, religion, pregnancy, or other protected personal characteristics.

Please refer to our Group Equal Opportunities Policy (https://Aqualis Braemar LOC.sharepoint.com/:b:/r/Shared%20Documents/Group%20Policies/ABL%20Equal%20Opportunities%20Policy.pdf?csf=1&web=1&e=vBgkpT) and HSQE polices which have been newly rolled out to the business. Aqualis Braemar LOC also have a standalone Whistle Blowing Policy. (https://aqualisbraemar.sharepoint.com/:b:/r/Human%20Resources/ABL%20HR%20Policies%20%26%20Procedures/ABL-HRP-013_Whistleblowing%20Policy.pdf?csf=1&web=1&e=n6ZGed.)

Any breach of our Group policies is taken seriously and investigated appropriately and fairly.

We believe that a motivated and satisfied workforce is a key enabler of individual and business performance. As the business grows, we will be able to provide further career and development opportunities. We encourage our staff to participate in accredited training programmes to further their understanding of the business and their roles.

We have rolled out a specific online training course to the wider group around stress in the workplace and diversity and inclusion to encourage awareness. We have also developed a new training and competence procedure globally. We maintain that the newly adoptive way of homeworking will not hinder any employees' chances of further development and career opportunities within the organisation.

https://aqualisbraemar.sharepoint.com/:b:/r/Human%20Resources/ABL%20HR%20Policies%20%26%20Procedures/ABL-HRP-011_Training%20and%20Competence.pdf?csf=1&web=1&e=Mmrur3

2020 was a difficult year with much of our staff having to adapt to new ways of working and sometimes in unusual and difficult conditions. From this way of working, we have understood and realised that our workforce can be far more flexible, and our job roles are adaptable. Flexible work arrangements support our employees in their efforts to balance work commitments with their individual living circumstances and needs. We have therefore implemented more structured polices around flexible working and working from home.

We took a pro-active approach to the COVID-19 pandemic to ensure the health and safety of our employees and stakeholders. Our staff were encouraged to stay at home where possible, to host virtual meetings and restrict travel. We put in place a comprehensive “Return to Work” guide with a safety video and developed team bubbles so only a certain number of people occupied the office at any one time. We reminded staff of new office procedures to maintain hygiene.

Going forward into 2021 we aim to put in measures to monitor and report on the demographics of our management and employees by diversity factors.

Due to new ways of working moving forwards our company aim to put more focus on our wellbeing programs. We would like to look at the promotion of physical fitness, promotion of healthy and stress management and work life balance. We believe this will have a positive impact towards SDG 3 – Good Health & Wellbeing.

Under sections 3-3a and 3-3c of the Norwegian Accounting Act, AqualisBraemar LOC is required to report on its corporate responsibility. AqualisBraemar LOC recognise that Health, Safety and Environmental (HSE) matters are an integral part of its business performance and exemplary performance in the areas of HSE is essential to fulfil our vision and meet the expectations of our stakeholders.

At time of drafting we do not have a separate Environmental Policy, but we do have a Health, Safety and Environmental Policy Statement (https://aqualisbraemar.sharepoint.com/Shared%20Documents/Forms/AllItems.aspx?id=%2FShared%20Documents%2FGroup%20Policies%2FABL%20Integrated%20QHSE%20Policy%2Epdf&parent=%2FShared%20Documents%2FGroup%20Policies).

Our Aqualis Braemar LOC 2030 guiding purpose, created and committed to in 2019, (https://aqualisbraemar.com/wordpress/wp-content/uploads/2020/04/AB-Annual-Report-2019.pdf. Page 5) is that energy and the oceans are at the centre of our business; the sustainability of both is vital for the future of our company and the world in which we operate and live. Our purpose not only makes environmental sustainability a responsibility for us in the way we do business, but also recognises that our business impacts the wider world and that we need to take responsibility for that too.

Though we are a company without any operating assets, we take our environmental responsibilities very seriously and our quality management system (QMS), which is certified by LRQA, requires that all projects are reviewed for potentially adverse environmental risks.

Our Aqualis Braemar LOC 2030 strategy includes three guiding principles that puts environmental sustainability at the core of our business:

Principle 3. Explore opportunities to allow the company & our people engage in efforts to promote greater environmental responsibility in line with the 1992 Rio Earth Summit

Principle 4. Work towards a company-wide net zero carbon target to stay ahead of our markets & contribute to a net zero world

Principle 5. Continue to grow, innovate & develop new services to both accelerate & de-risk the energy transition & create business value

One of our Aqualis Braemar LOC 2030 principles is “4. Work towards a company-wide net zero carbon target to stay ahead of our markets & contribute to a net zero world”. To achieve this we have set a goal for 2021 is to establish a Group wide carbon neutral policy to reduce our greenhouse gas (GHG) emissions which will include appropriate science-based targets, strategies on how we will achieve these targets and an appropriate carbon footprint reporting and carbon accounting to enable measurement. We have identified a Group team to undertake this task.

Another Aqualis Braemar LOC2030 principle is “5. Continue to grow, innovate & develop new services to both accelerate & de-risk the energy transition & create business value”. We recognise that the biggest contribution we can make to tackling climate change is by helping our clients to develop and execute sustainable operations, programmes and projects or investments. As such we have set a goal of developing 2 new services that help achieve this, that can therefore deliver both a positive impact on the UNGC’s SGDs and climate change and deliver sustainable business value for our staff and shareholders. We are currently in the process of developing and investing in two new services that will be launched over Q2 and Q3 2021. One of the new services has a positively impact SDG 14 Life Below Water in the area of reducing risks of environmental damage and the other will positively impact SDG 13 Climate Action around measuring and reducing emissions.

A major part of our business is in the development and realisation of offshore wind and solar projects globally. Our consultancy services allow our clients to develop, finance and construct projects across the globe bringing clean secure offshore energy to coastal nations from Europe to Asia to the Americas and this has a positive impact on SDG 7 Affordable and Clean Energy.

In our Health, Safety and Environmental Policy Statement it states “We will identify health, safety, environmental and security risks, and ensure that appropriate controls and contingency plans are in place to address unforeseen events. Last year we compiled an environmental aspects & impact assessment register as part of understanding our risks.

At this moment around half of our group offices are covered by ISO 14001, this coverage came with a recent acquisition. We have set the target of 31st December 2021 to have all 67 group offices ISO 14001 certified.

Last year we compiled an environmental aspects & impact assessment register as part of understanding our risks for the first time. As part of rolling ISO 14001 across the whole group part of this system is to implement a group wide formal PDCA framework.

We are a global business and so international travel is a necessary part of our operations and business offerings. While we have always tried to promote virtual meetings and conference calls, the global pandemic forced us and the business world to look at ways to maintain business service and operations. As such our air travel has reduced significantly consequently reducing our carbon emissions considerably. We do not, as yet, have a carbon accounting system in place across the group, but as stated above this is a 2021 goal. A large part of our business is site attendance on vessels and offshore assets, we have reduced the need to travel while delivering the work by utilising more our global footprint and deploying virtual surveying. In this way we have more or less maintained business volumes but with less international travel associated. This way of working has changed behaviour and we expect much of this reduction to be maintained post-pandemic.

The Board of Directors has approved and implemented corporate governance principles endorsing and complying with the Norwegian Accounting Act (§ 3-3b) and the Norwegian Code of Practice for Corporate Governance (Code of Practice) issued by the Norwegian Corporate Governance Board.
Aqualis Braemar LOC is committed to conducting its business in a manner that adheres to the highest industry standards and strictly in accordance with applicable laws and regulations in the regions and countries where were operate.

The Group advocates high standards of honesty, integrity and ethical behaviour in its daily business and expects all representatives of AqualisBraemar LOC to conduct their daily business in a safe, fair, honest, respectful, and ethical manner.

A formal Code of Conduct has been established and has to be read, understood and accepted by all staff and contractors. The Code of Conduct sets the Group’s commitments, and all employees are required to uphold and comply with the code. The Code of Conduct prohibits giving anything of value, directly or indirectly to officials of foreign governments or political candidates or to any other person, in order to obtain or retain business. It is strictly prohibited to make illegal payment to government officials, or any other person of any country and guides staff if they feel they have something they feel they need to report (whistle blowing), it explains how to handle situations and how to report.

AqualisBraemar LOC has a corporate compliance officer, employees are provided training on compliance and are instructed to report suspected violations of the Group’s code.

All staff must complete e-learning modules that support our policies. Our goal is continuous improvement, and we are focusing on improving anti-corruption monitoring and reporting.

Our Code of Conduct states that our staff have the options to report to their line manager, our general Counsel or group operations director. We have recently created and published a Whistleblowing Policy that supports all grievances or suspected wrongdoing instances. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment, issues in the workplace and/or any breach of legal or professional obligations. This policy covers all employees, officers, consultants, freelancers, contractors, work experience or internship workers, volunteers, casual workers and agency workers of Aqualis Braemar LOC.

We stress confidentiality will be protected where appropriate and that we will not penalise or discriminate against anyone who provides information to the company relating to what they believe is corrupt or unethical practices.

Regarding taxation, our policy is full compliancy with all relevant domestic and international laws, rules and regulations. Management of our tax affairs is also consistent with our ethics policy and code of business conduct, which are built around fairness, openness, and honesty. As a listed company we must also demonstrate full compliancy in these areas.