ENVIRONMENT, SOCIAL & GOVERNANCE POLICY

Adopted by the Board of Directors on August 18, 2023

SUMMARY

The intent of this policy is to outline Pulsar Helium Inc. and its subsidiaries (collectively the “Company”) environmental, social and governance (“ESG”) guiding principles in a coherent, systematic manner, in the form of an ESG Policy, to inform stakeholders and interested parties and to define the policies that govern our actions as they relate to ESG matters.

DEFINITIONS

Environment, or the “E” in ESG, captures such topics as energy efficiencies, carbon footprints, greenhouse gas emissions, deforestation, biodiversity, climate change and pollution mitigation, waste management and water usage.

Social, or the “S” in ESG, covers such matters as labor standards, wages and benefits, workplace and board diversity and inclusion, racial justice, pay equity, human rights, talent management, community relations, privacy and data protection, health and safety, supply-chain management and other human capital and social justice issues.

Governance, or “G” in ESG, covers the governing of the “E” and the “S” categories, corporate board composition and structure, strategic sustainability oversight and compliance, executive compensation, political contributions and lobbying, and bribery and corruption.

CORE PRINCIPLES

In all our actions, we are guided by certain core principles as they relate to responsible exploration and development of the Company’s projects. These principles include, but are not limited to:

  • Our employees are guided by our core principles in their everyday behaviour as it relates to their own ideals and values, or they would not be working with the Company.

  • The Company recognizes that responsible corporate behaviour with respect to ESG factors can generally have a positive influence on long-term corporate performance.

  • Disclosure is the key metric that allows stakeholders and other interested parties to better understand, evaluate and assess potential risk and return, including the potential impact of ESG factors on the Company’s performance.

  • The Company’s investment analysis should incorporate ESG factors to the extent that they affect risk and return.

  • The Company acknowledges the division of authority and responsibilities among the three parties that are core to corporate governance – shareholders, directors and managers.

  • Employees, contractors, suppliers, federal, state and local governments and the impacted communities have a vested interest in positive corporate conduct and long-term business performance.

CORE VALUES

In order to live up to these core principles, the Company has defined certain core values in our Code of Conduct and Ethics Policy that are integral to the Company’s DNA:

Safety

The health and safety of our employees, contractors working for us, and the public is of the utmost importance.

Environmental Responsibility

We go above and beyond what is required. We find practical solutions to manage growth, while protecting and enhancing the natural environment.

Community Involvement

As proud members of the community, we actively strive to serve the community’s needs, and to collectively enhance prosperity and well‐being.

Transparency

We fulfill our commitments in an open and transparent manner. We aim to be accurate, consistent and straightforward in all information delivered to our stakeholders.

Accountability

As part of our corporate governance, we ensure that accountability guides all our actions, decisions, conduct and reporting.

Integrity & Performance

We hold ourselves to high moral standards and strive to fulfill our commitments in an effective and sustainable manner.

HEALTH & SAFETY POLICY

In order to align with our core values, the Company has established safety principles that are reflected in rigorous policies and standard operating procedures (“SOPs”) on site for the protection of the health and safety of people working at the Company’s projects (“Project”).

The Company believes that the health and safety of its employees is paramount to the successful operation of its business. Work-related injury or illness is unacceptable, and the Company is committed to the identification, elimination, or control of workplace hazards for the protection of all employees. The goal is to have zero lost time incidents. The Company is committed to implementing operational improvements that offer superior safety and occupational health management.

For the Company to succeed in fulfilling this policy, all employees must undertake their work in accordance with the Company’s policies to the best of their ability and to take all reasonable care for their own safety and health, as well as the health and safety of their work colleagues.

In order to achieve these objectives, the Company is committed to:

  • Providing the expertise and resources needed to maintain safe and healthy work environments.

  • Promoting occupational Health & Safety awareness so that it is always at the forefront of daily operations.

  • Establishing clearly defined safety and occupational health programs.

  • Measuring safety and health performance, and making improvements as warranted.

  • Operating in accordance with recognized industry standards, while complying with local and international applicable regulations and laws.

  • Investigating the causes of accidents and incidents and developing effective and immediate preventative and remedial actions.

  • Training employees to carry out their jobs safely and productively. No employee will be permitted to commence a job without the requisite training, including hazard recognition.

  • Providing necessary personal protection equipment, such as hard hats and safety glasses, and instruction in their use.

  • Maintaining a high degree of emergency preparedness.

  • Requiring that contractors and vendors comply with all Company health and safety standards.

  • Promoting the Health & Safety Policy as a way of life in all aspects at our work sites and in our family and local community.

ENVIRONMENTAL POLICY

The Company established environmental principles that are reflected in robust policies and SOPs on and off site to protect the natural environment. The Company’s commitment to the environment goes beyond just protecting the status quo – we are actively engaged in enhancing the ecosystem in which we operate, including implementation of a remediation project.

These principles, and the resulting policies and SOPs, will continue to be refined as the Company’s projects advance.

This Policy is a commitment to maintain sound environmental practices in all of its activities and to continuously improve the efficient use of resources, processes and materials. For the Company to succeed in fulfilling this policy, all employees are responsible for incorporating into their work the actions necessary to take all reasonable care for the protection of the environment, including:

  • Examine the potential impact to the environment of all proposed activities and take steps to minimize, mitigate or, where possible, eliminate that impact.

  • Operate in accordance with recognized industry standards, while meeting and complying with applicable federal, state and local regulations and laws.

  • On a regular basis, determine the Company’s impact to the environment and, through continuous improvement, strive to attain higher levels of environmental performance.

  • Minimize all hazardous and non-hazardous materials generation and properly dispose of all waste materials.

  • Maintain a high level of environmental protection by applying reasonable best practices and technologies that minimize impacts and enhance environmental quality with respect to water, air, vegetation, and wildlife.

  • Maintain dialogue with the communities and other stakeholders within the area of influence of the Company’s projects in order to understand their concerns, minimize negative impacts and to enhance environmental quality

  • Progressively rehabilitate disturbed areas where appropriate, incorporating new technologies where practical.

  • Train and educate all employees and contractors to understand their environmental responsibility related to all activities related to the Company’s operations and activities.

  • Require contractors and suppliers to operate according to Company’s environmental standards and procedures.

  • Consider environmental factors when purchasing equipment and materials and when engaging services.

SUSTAINABILITY GOALS

The Company recognizes that its goals, and those of the communities in which it operates, can be aligned to create mutual and lasting benefits. An important goal for the local communities surrounding the Company’s projects is for sustainable, well-compensated employment for those members of the community employed by the Company. In order to deliver against these aspirations, the Company aims to continue to encourage local hiring, contracting, provision of supplies and services focused on local communities in the project areas. In support of this, the Company has established an employment goal to encourage the hiring of qualified local people and work with nearby communities to lessen any negative social, lifestyle and economic impacts related to the Company’s projects.

The Company will minimize the Company projects footprint and related impacts by using existing infrastructure (paved and unpaved roads, power and water supply) and by locating new facilities on previously impacted ground to the maximum reasonable extent.

TRANSPARENCY & SUSTAINABILITY REPORTING

The Company will take a proactive approach to Transparency & Sustainability Reporting (“TSR”) with a goal of delivering continuous improvements in five benchmark criteria:

  • Safety & Health.

  • Conservation Management and environmental protection.

  • Energy & Waste.

  • Community.

  • Economic Sustainability.

ESG is in the Company’s genetics, and our leadership has a history of doing the right thing the right way for many years, long before ESG earned a globally recognized acronym. Now that ESG has moved to the fore of investor and other stakeholder attention, a plethora of reporting standards and ESG auditors has emerged that makes reporting to standardized benchmarks that satisfy a wide audience challenging. Nevertheless, as and if the Company advances the projects activities to development-focused activities, all of our actions will be guided by our core principles, we will live by our core values and we will conduct ourselves in accordance with our policies, including those that form part of this ESG Policy.

Going forward, we will provide regular updates on our environmental, social and governance-related actions, and will contextualize and report the Company’s performance with respect to reporting standards that are applicable to the resource extraction industry at various stages of the Company’s projects as they advance.

Policy Review

The Company will review this Policy regularly to ensure that it is achieving its purpose. Based on the results of the review, the Policy may be revised accordingly.