OBJECT 

Establish corporate guidelinesto ensure the contribution of Promigas and its related companiesto sustainable development, based on the implementation of best environmental management practices and the improvement of the environmental performance of the activities carried out, in line with the Principles of the Global Compact and the Sustainable Development Goals. 

SCOPE 

This Policy applies to all current and future activities, facilities, and projects of Promigas and all related companies over which Promigas has control or operational control. In companies not operated or controlled by Promigas, our commitment is to exercise our influence, to the best of our abilities, to motivate them to act consistently and coherently with our policies. It includes the phases of design; construction; operation; maintenance; closure and dismantling of gas infrastructure, renewable energy, and electricity; location repairs; energy services; and other services provided by companies directly or through contractors. It also applies to activities carried out along with stakeholders in the value chain. 

GENERAL TERMS 

The Environmental Policy conveys the commitment undertaken by Promigas S.A. E.S.P. and its related companies to ensure an operation responsible with the environment and with its different stakeholders and constitutes a guideline for all the activities towards the development of the business affairs. ​

The Environmental Policy is governed by the Promigas Corporate Policy, in compliance with the strategic objectives and material issues of the integrated management model with a sustainable approach, defined in the Corporate Strategic Configuration (GLA-168). In line with the Code of Conduct GNA-755, the Human Rights Policy PNA-1895, and the decision to contribute from our work to achieve the Sustainable Development Goals included in the UN 2030 Agenda. 

This policy is approved by the Vice-Presidency of Legal Affairs and Sustainability and constitutes a framework of action that favors the recognition of the impact that business decisions and daily operations can have on the sustainable development of society, through the generation of economic, social and environmental value.

CONTENT 

1. ENVIRONMENTAL POLICY 

Promigas is committed to implementing the highest environmental management standards to ensure that its activities identify, avoid, minimize, control, and, should these not be possible, restore and compensate any possible impacts of its operations on the environment by applying the mitigation hierarchy to achieve, as far as possible, the no net loss of biodiversity.

In accordance with the foregoing, Promigas is committed to contributing to sustainable development and the generation of economic, social and environmental value to society, based on the conservation of the environment well-being, in strict compliance with environmental legislation and the voluntary principles embraced such as the principles of the Global Compact and the United Nations Climate Care initiative and the Sustainable Development Goals, for which it has expressed its decision to contribute to the achievement of the goals of the global agenda.

In compliance with this commitment, it establishes that all actions undertaken by Promigas and its affiliated companies, contractors and suppliers of significant goods and services to achieve compliance with the environmental policy, shall fulfill the following guidelines:

✓ To comply with the environmental legislation applicable to our activities and the environmental commitments agreed upon with our clients 
✓ To guarantee preservation of strategic ecosystems, minimizing the layout of new projects in declared environmental protection zones, prioritizing the passage through areas already intervened and reducing impact on environment and biodiversity. 
✓ To implement measures and goals to prevent, minimize, restore and compensate for the potential environmental and social impacts that may be generated by the activities, products and services of current operations, as well as those generated by the development of new businesses or by the acquisition of new projects, considering the perspective of life cycle, carbon footprint management, integral management of waste, preservation of biodiversity and the alignment to the circular economy strategy, using products, technologies and procedures that contribute to this purpose. 
✓ To promote and strengthen a culture of care for the environment, the rational use of resources, the prevention and minimization of impacts on the environment, protection of biodiversity and  mitigation of climate change among stakeholders, especially employees, contractors and other members of the value chain. 
✓ To disclose or train in a timely manner our employees and contractors with the guidelines for the improvement in environmental performance and compliance with the policy, to improve the understanding of the impact of their activities on the environment and society and incorporate good management practices that include the best way to avoid, mitigate, restore and compensate them. 
✓ To implement actions to reduce and reuse solid waste in our activities. 
✓ To select goods and services suppliers committed to compliance with environmental legislation, the adoption of best environmental practices in their distribution and logistics chains and the implementation of actions to minimize environmental and social impacts during their services provision, all this through HSE plans, a requirement established in the HSE manual for suppliers (PME-913). 
✓ To evaluate the environmental performance of our activities (own or suppliers’) in order to ensure compliance with commitments, avoid deviations from standards and identify opportunities for continuous improvement regarding environmental performance. 
✓ To apply environmental due diligence in any procurement process or in making strategic decisions for participation in new businesses, in order to guarantee knowledge of the environmental risks and impacts resulting from new businesses and define the measures to be implemented to bring them to the environmental standards established by the organization. 
✓ To communicate to our stakeholders and mainly to the communities in the regions where we operate, the environmental impacts and the result of our environmental management and performance 

OUR COMMITMENTS 

1. COMMITMENT TO BIODIVERSITY 

We incorporate biodiversity conservation as a criterion from the early stages of project planning and design and during project construction, operation, maintenance, closure and decommissioning. Also, we commit ourselves to the implementation of the following actions within the mitigation hierarchy to ensure no net loss of biodiversity resources and achieve zero net deforestation for all projects in our sphere of influence: 

a. Avoid, during the design phase, layouts and locating new projects in protected or strategic areas to preserve biodiversity. For this we define the following measures within our commitment: 

 ✓ Do not carry out activities within IUCN-listed protected areas Category I-IV.
 ✓ Avoid installing and operating infrastructure within IUCN Category I-IV World Heritage areas and protected areas. When the declarations of these areas are issued after the development of projects, there must be joint actions with the environmental authorities to ensure that the appropriate conservation measures. 
✓ Develop an environmental diagnosis of alternatives to define the best layout, location, and construction method of projects to ensure the lowest environmental impact and enhance positive impacts on biodiversity. 
✓ Prioritize the use of areas or corridors already intervened for locating new projects or for the expansion or modification of existing ones. 
✓ Conduct environmental impact assessments to identify the main ecosystems, habitats, and species, as well as threat categories according to the International Union for Conservation of Nature (IUCN), their value and importance in biodiversity, the impact generated, and the delimitation of the intervention areas, and define prevention, management, protection, restoration, and compensation measures to reduce the loss of biodiversity. 

b. Minimize interventions during the construction, operation, and maintenance of projects, by: 
✓ Implementing actions that aim to avoid deforestation, reduce tree felling, especially in key areas of biodiversity, acquisition of products from sources with forest certification, among others. 
✓ Taking measures to ensure the conservation of biodiversity, such as implementing wildlife passage in areas of biological corridors, shooing, and rescue and relocation (including nests) of species of fauna and flora. 
✓ Controlling and monitoring service providers’ compliance with the provisions of this policy in the development of infrastructure construction or maintenance activities and action in accordance with the best environmental practices. 
✓ Evaluating the impact of activitiesthrough biodiversity monitoring and other actionsto ensure the effectiveness of the measures implemented for the conservation of Biodiversity. 
✓ Reducing natural resource intervention areas in the right-of-way of existing networks that cross areas that are now protected by IUCN Category I-IV while conducting infrastructure maintenance activities.

 c. Repair or restore the intervened areas 
✓ Reshaping the intervened soil, reusing the removed organic plant material to promote natural regeneration. 
✓ Restoring the intervened areas with shrub and tree species compatible with the ecosystem and that do not pose a threat to the biological diversity of the area being 

d. Carry out effective compensation in strategic ecosystems against significant and negative residual impacts that could not be avoided, minimized, or rehabilitated, aimed at: 
✓ Implementing compensation plans for loss of biodiversity and changes in land use and to avoid deforestation.
 ✓ The expansion of natural reserve areas and support for the preservation of the existing biodiversity in the areas of operation. 
✓ Voluntary participation in biodiversity conservation projects, works on partnerships and joint efforts with private entities, authorities, unions or universities and other organizations, seeking to maximize results in the actions undertaken and ensure the care for biodiversity, promote the generation of knowledge, and contribute to position the importance of caring for biodiversity as a strategic element for the countries of operations. 
✓ The contribution to restoring the protected areas of the region where we operate, in line with the environmental management plans of the protected areas or the plans of the environmental authorities. 
✓ The participation of communities in actions to protect and care for biodiversity, supporting economic development activities seeking to reduce pressure on the use of natural resources. 


2. COMMITMENT TO COMBATING CLIMATE CHANGE 

We are aware that climate change is one of the main environmental, social, economic, political and ethical challenges that the world is facing, and we know of the consequences that this phenomenon has on a large part of the global ecosystems. 

Aware of the connection between the businesses of Promigas and aspects related to climate change and of the risks and opportunities arising from it, Promigas is committed to minimizing the risks caused by its activities and enhancing opportunities in developing the business strategy and the management model with a sustainability approach where environmental responsibility and the climate component play an important role. 

We are committed to being carbon neutral in our Scope 1 and 2 by 2040 and to achieving a 50% reduction in our emissions intensity compared to 2021 for Scope 1 and 2, as well as to adapting our infrastructure to climate events, raising stakeholder awareness of the challenges posed by climate change and seeking new growth opportunities to consolidate a sustainable company. 
For this we contemplate: 

✓ Periodic review and updating of the Climate Strategy of PROMIGAS and its related companies. As a result, we commit ourselves to the development of an Action Plan that: (1) allows achieving the objectives set forth in said strategy, (2) defines goals based on scientific and sector surveys, and their verification mechanisms, and (3) commits Promigas and its ENVIRONMENTAL POLICY © Promigas S.A. E.S.P. 2023 6 de 6 related companies to this plan. 
✓ Our carbon footprint measurement and certification to ISO 14064 
✓ The development of an Emissions Reduction Plan that allows us to achieve our greenhouse gas (GHG) emissions reduction goals, promoting the efficiency, competitiveness and sustainability of our business. 
✓ The design and deployment mechanism of an internal carbon price (ICP) model, aimed at creating awareness of the decision-makers on the vulnerability of new investments in face of current or eventual climate regulations.

The company’s climate strategy must consider at least the following aspects: 
• Mitigation Strategy 
• Adaptation Strategy 
• Communications Strategy 
• Sustainable Growth Strategy, including an analysis of scenarios and risks and opportunities of climate change 


3. RESPONSIBILITIES 

The Environmental Policy shall be administered in Promigas by the Sustainability and Environment Management, who will lead its implementation, control, surveillance, monitoring and continuous improvement. It shall be updated according to changes in the Strategic Planning and Top Management guidelines or at least every 3 years in compliance with the Document Management Standard GNA-002-S1. Any changes to the Policy shall be reviewed and approved in accordance with Annex 1 of the Policy Management Standard GNA-769. 

It is the responsibility of each of the companies to implement the necessary actions for the fulfillment of this policy, as well as the communication and dissemination of its contents through appropriate means so that it will be known at all levels and by internal and external stakeholders.

All employees are responsible for implementing the guidelines of this policy, as well as the actions derived for its compliance. Any concerns about its content and commitments shall be forwarded to your immediate supervisor or policy administrator.