Environmental Policy

1. Purpose

This policy sets out the environmental commitments of Green Earth Group N.V. (“the Company”) and the standard that every environmental, carbon and impact claim made by or for the Company must meet. It also tells our stakeholders and partners what environmental standards we hold ourselves to and what we expect of them.

Green Earth develops nature-based projects that restore ecosystems. Our work starts from nature. Preserving natural resources, promoting biodiversity and supporting a sustainable balance between society and the environment form the basis of our vision. We aim to reduce our own ecological footprint and to enhance the natural environments in which we operate.

The policy gives a framework for setting environmental goals, putting effective measures in place and monitoring progress. It aims to build awareness, accountability and action on environmental issues among our employees, our partners and the wider community.

What we say about our results is part of our environmental record. A compelling message must not outrun the evidence. One overstated claim can cost the trust on which every verified credit, report and investor relationship depends.

2. Scope

This policy applies to all of the Company’s operations and to every level of the organisation, from senior management to frontline staff. This includes:

• all our sites and logistics facilities;
• joint ventures in which we have operational control;
• our carbon project development and ecosystem restoration work; and
• our day-to-day business activities.

The claims standard in section 6 applies wherever we make an environmental, carbon or impact claim. This includes websites, proposals, pitch decks, contracts, investor materials, impact reports, labels, social media, advertising, press statements, speeches, applications, certificates, dashboards, imagery, case studies, AI-generated material, partner content and private sales communications that may influence a decision.

3. Our environmental commitments

Compliance. We comply with all relevant environmental laws, regulations and standards, at local and international level. Where possible, we aim to exceed these requirements.

Environmental management. We continuously improve our environmental management systems and processes. We use current technologies and good practice to reduce our environmental impact, improve efficiency and use resources sustainably.

Employee engagement and competence. We involve our employees in environmental issues and give them the training and skills they need to apply this policy. We encourage everyone to contribute and to build sustainability into their daily work.

Collaboration. Environmental challenges are global. We work with other organisations, in our sector and beyond, and take part in partnerships and initiatives that promote environmental care and share good practice.

Responsibility to future generations. Our commitment goes beyond legal compliance. The decisions we make today shape the world we leave behind. Our ambition is not only to sustain the environment but to enrich it for those who come after us.

4. Partners and value chain

We strongly encourage our partners, including suppliers, contractors and other participants in our value chain, to follow the principles of this policy. We aim to work with partners who share our commitment to reducing environmental impact, and we help them understand and apply this policy. The Responsible Business Partner Policy sets out what we expect of our suppliers.

Partner content that describes our products, projects or results must meet the claims standard in section 6.

5. Monitoring, reporting and transparency

Tracking progress. We maintain a monitoring system that measures our environmental performance, identifies where we can improve and allows us to act promptly when needed. Regular reviews and audits of our operations keep us on track towards our goals.

Transparency. We report our environmental performance regularly to our stakeholders, including employees, partners, customers and the public. We share our progress, our challenges and our plans. All such reporting must meet the claims standard in section 6.

Responding to stakeholders. We engage in dialogue with stakeholders to understand their views and address their concerns. We provide timely, accurate and relevant information in response to questions and feedback about our environmental impact and sustainability work.

6. Environmental, carbon and impact claims

What we say about Green Earth products, projects, organisations, carbon, climate, nature, communities, livelihoods, finance and other impact must be accurate, specific, evidenced, understandable and kept up to date.

6.1 What every material claim states

Every material claim must identify:

• what is claimed, and about which entity, product, project, geography or population;
• the period, unit, boundary and baseline;
• the method, the evidence status, the uncertainty and the limitations; and
• the responsible owner.

Words and visuals must match the strength and maturity of the evidence. They must not create a broader overall impression than the verified facts support.

6.2 Carbon and environmental claims

• Keep outcomes distinct. Estimated, modelled, validated, verified, issued, transferred, retired, avoided, reduced, removed, stored and projected are different claims.
• Identify the applicable methodology, project boundary, period, material assumptions and uncertainty, and the registry or assurance status where relevant.
• State whom the claim concerns: the Company or another Green Earth entity, a project, a customer, a financial instrument or a specific unit.
• Do not present the same outcome as belonging to more than one party.

6.3 Social and community claims

• Statements about farmers, communities, jobs, income, inclusion, gender, wellbeing, land, consent, benefit sharing or livelihoods need a defined measure and appropriate evidence.
• Individual stories do not prove outcomes for a whole population.
• Images, names, quotations and case studies need the necessary rights and consent. They must respect people’s dignity, give adequate context and protect people from foreseeable harm.

6.4 Financial and investment claims

• Statements about price, revenue, yield, return, savings, asset value, liquidity, listing, funding, risk or future performance state their assumptions and uncertainty.
• They are reviewed by Finance and Legal, and by an authorised investment reviewer where applicable.
• Targets, scenarios, aspirations and forecasts are labelled as such and are never presented as guaranteed results.

6.5 Who reviews and approves a claim

A material claim is never approved by its own author.

The Company’s internal content approval procedure sets out the steps.

6.6 Evidence and records

For every claim, we keep: the exact published claim and its version; the source data; the calculation; the boundary; the assumptions; the methodology; the assurance; rights and consents; the reviewers; the approval; the channel; the publication date; the owner; the review or expiry date; and any linked corrections. Every public statement must be traceable to evidence that existed when it was made.

6.7 Review and correction

• Review a claim when its data, methodology, verification, project status, the applicable law or standard, a contract, ownership or the audience context changes.
• Correct, qualify, suspend or withdraw a claim promptly when it is wrong, unsupported, outdated, duplicated or misleading, or when it is used outside its approved context.
• Keep the record of each decision and correction.

6.8 Examples of claims we do not make

• Calling estimated or projected tonnes “verified” or “removed”.
• Claiming the same outcome for the Company and for a customer.
• Using one farmer’s story as proof for a whole community.
• Presenting a target or forecast as if it were a result.

7. Roles and responsibilities

• The Board (the management board of the Company) oversees this policy; the Chief Executive Officer approves it on the Board's behalf.
• The executive directors and senior management set our environmental goals, manage environmental risks and make sure we meet our commitments. They review our environmental performance regularly and promote continuous improvement across the organisation.
• The Chief Executive Officer is accountable for this policy.
• The Head of Legal owns this policy and keeps it up to date.
• Everyone who works for the Company applies this policy in their own work. Anyone who prepares, reviews or publishes a claim follows section 6.

8. Reporting concerns

Anyone can ask a question or raise a concern about our environmental impact or about a claim we have made. Email contact@green.earth or use the contact form at https://www.green.earth/contact.

Complaints are handled under the Complaints Policy. Staff can report suspected wrongdoing under the Whistleblower and Non-Retaliation Policy, which is available to all staff. Anyone outside Green Earth can report suspected wrongdoing by email to contact@green.earth.

9. Approval and review

The Chief Executive Officer approves this policy on behalf of the Board. The Head of Legal owns it and reviews it at least every two years.

History: first issued on 30 September 2021 and revised on 24 May 2023 by the Company, then named DGB Group N.V. The 2023 version was presented to and approved at the 2023 Annual General Meeting. This version combines that policy with the Company’s standard for environmental, carbon and impact claims.

10. Related documents

• Code of Conduct
• Responsible Business Partner Policy
• Occupational Health and Safety Policy
• Terms of Reference Health, Safety and Environment (HSE) and Sustainability Committee
• Complaints Policy
• Whistleblower and Non-Retaliation Policy
• Privacy Notice