Stakeholder Engagement Policy

This Stakeholder Engagement Policy was last updated on 21 October 2026.

1. Purpose

Green Earth engages with relevant stakeholders to understand material interests, risks, impacts and opportunities and to take them into account in appropriate business decisions. This Stakeholder Engagement Policy (the "Policy") establishes a proportionate and auditable mechanism for doing so, consistent with B Lab's Purpose and Stakeholder Governance requirements, as part of Green Earth's work towards B Corp certification, and with Green Earth's existing Academy policies and procedures.

Stakeholder engagement supports informed decision-making. It does not transfer management authority, create a general right of approval or establish a stakeholder veto over Green Earth's strategy, operations, financing, commercial terms or communications.

2. Scope

This Policy applies to Green Earth Group N.V. (the "Company") and its controlled entities (together, "Green Earth"), and to employees and contractors acting on their behalf when they identify, consult or respond to stakeholders. It is a group-level framework. More specific Academy procedures govern field engagement, FPIC, farmer grievances, staff grievances, surveys, certification, investor disclosure and contractual relationships.

3. Definitions

Board: the management board of the Company, made up of executive directors and non-executive directors. The Company has a one-tier board; it has no supervisory board.
FPIC: free, prior and informed consent.
Stakeholder: a person or group that affects, or is affected by, Green Earth's activities, including the groups listed in section 6.

4. Governing principles and limits

Consideration, not delegation. Green Earth considers material stakeholder input in good faith. Stakeholders remain advisory unless a binding law, contract or approved procedure expressly provides otherwise.
Management retains authority. The Board, the Chief Executive Officer and authorised managers retain responsibility for decisions and may balance stakeholder input against legal duties, safety, environmental integrity, commercial viability, confidentiality, certification requirements and the interests of other stakeholders.
No automatic entitlement. This Policy does not create voting rights, representation rights, ownership rights, approval rights, third-party beneficiary rights, compensation rights or a duty to accept any proposal.
Proportionate engagement. The form and frequency of engagement depend on the stakeholder group's relevance, the likely impact of the matter and existing operational processes. Green Earth is not required to consult every stakeholder on every decision.
Documented response. Material input is recorded, reviewed and either reflected in action or closed with a reason proportionate to the matter.
Confidentiality and market conduct. Engagement does not override privacy, contractual confidentiality, intellectual-property restrictions or listed-company disclosure and market abuse rules, including the Insider Trading Regulations.
Non-retaliation. Concerns raised in good faith are handled without retaliation through the applicable Academy grievance or alert procedure.

5. Mandatory exceptions

The limits above do not reduce rights or obligations that already arise under law, contract, certification rules or an approved Academy procedure. In particular:

FPIC. Where the Academy FPIC procedure applies, affected communities or land users must give free, prior and informed consent before the relevant activity proceeds. This consent applies to the affected land, people and material project change; it is not a general right to control Green Earth's wider business.
Contracts and land rights. Signed farmer, landowner, customer, supplier and financial agreements remain binding according to their terms.
Grievances and appeals. Staff and enrolled farmers retain the reporting, response and escalation rights set out in the applicable Academy policies and procedures.
Law and certification. Local law, corporate governance rules and applicable Verra, CCB, Gold Standard or other certification requirements take precedence where they impose a higher or more specific obligation.

6. Stakeholder groups and engagement mechanisms

The following groups are covered by at least one engagement mechanism. The mechanisms below consolidate existing Green Earth practices; they do not require parallel processes where reliable information already reaches the responsible function.

Stakeholder group	Primary mechanisms	Minimum review or trigger	Internal owner (post)
Employees and regular contractors	Team meetings; manager conversations; twice-yearly staff experience survey where applicable; staff grievance and alert channels	Ongoing; themes reviewed at least twice a year	Chief of Staff
Customers and corporate partners	Account dialogue; service feedback; complaints; contract and delivery reviews	Ongoing and at material relationship reviews	Head of Business Development Green Earth
Suppliers and implementation partners	Due diligence; contractual reviews; performance and risk discussions	On onboarding, on material change and at periodic reviews based on risk	Director of Technical Operations
Investors and financial partners	Regulated disclosures; shareholder meetings; investor relations contacts; formal KYC and transaction processes	According to law, the reporting calendar and transaction need	Chief Executive Officer
Farmers, land users and affected communities	Information meetings; surveys; field visits; FPIC where required; grievance route; community representatives	As required by project stage; annual survey in active areas where applicable; additional engagement for material change	Venture Manager
Local authorities and public bodies	Permitting, statutory consultation, project coordination and issue-specific meetings	As legally or operationally required	Country Director (Kenya); Country Director (Uganda)
Environment and future generations	MRV data; impact assessments; certification audits; incident and grievance trends; scientific and regulatory evidence	Continuous monitoring; periodic management and certification review	Director of Technical Operations

7. Decision-making mechanism

Green Earth uses the following mechanism to demonstrate that stakeholder interests are considered in decision-making:

Identify. The responsible owner identifies the affected stakeholder group and the material issue, using existing operational data, surveys, meetings, complaints, audits and certification records.
Assess. Input is assessed for relevance, evidence, severity, likelihood, urgency, legal or contractual status and consistency with Green Earth's purpose and strategy.
Decide. The authorised manager or the Board decides whether to accept, partly accept, defer or decline the input. Decision authority does not pass to the stakeholder.
Record. For material matters, the owner keeps proportionate evidence of the input, the assessment, the decision, the owner and any action or reason for no action.
Respond. Where appropriate and lawful, Green Earth communicates the outcome or next step to the stakeholder group. Confidential or market-sensitive reasoning may be withheld.
Review. Management reviews material themes and actions at least quarterly through an existing management forum. The Board, or a committee of the Board that it designates, reviews overall stakeholder engagement at least once a year.

8. Materiality and prioritisation

Green Earth is not required to treat all views as equally important. Priority is based on the nature and scale of the actual or potential impact, legal and contractual obligations, the vulnerability of affected people, environmental severity, likelihood, urgency, strategic relevance and the quality of available evidence. Severe impacts receive greater weight even when they are less likely. Conflicting interests are balanced by the authorised decision-maker and documented for material matters.

9. Records and evidence

Evidence may include meeting notes, attendance records, surveys and findings, CRM entries, grievances and resolutions, FPIC records, contracts, audit findings, management minutes, action trackers and communications back to stakeholders. Records are stored in the system designated by the responsible function and retained according to applicable legal, contractual and Academy retention requirements.

For certification purposes, the evidence should show both that relevant stakeholders were heard and how material input was considered. It need not show that every request was accepted.

10. Roles and responsibilities

Post	Responsibility
Board, or a committee of the Board that it designates	Annual oversight of purpose, social and environmental impact and stakeholder engagement. Approval of this Policy.
Chief Executive Officer	Accountable for this Policy. Escalation of material cross-group issues and evidence that the governance review took place.
Head of Legal	Owns this Policy, keeps it under review and answers questions about its interpretation.
Compliance Officer	Supports the escalation of material cross-group issues and keeps the evidence of the annual governance review.
Country Directors and the owners named in section 6	Apply this Policy through existing procedures, maintain records and escalate material matters.
MRV Managers and Carbon Certification Manager	Ensure that project consultation, FPIC and certification evidence meet the applicable standard.
All employees and contractors	Engage respectfully, make no unauthorised commitments, protect confidential information and route grievances correctly.

11. Approval, review and publication

This Policy is approved by the Chief Executive Officer on behalf of the Board.
The Head of Legal reviews this Policy at least once a year, and after a material change in Green Earth's structure, stakeholder profile, legal obligations or certification requirements.
Material changes require approval by the Board.
Employees are informed through the Academy or another designated internal channel.
External publication, if required, must use an approved public version and comply with Green Earth's information-sharing and listed-company disclosure rules.

12. Related Academy documents

FPIC — Free, Prior and Informed Consent
Farmer Grievance and Dispute Policy
Farmer Grievance Reporting
Grievance and Complaints (Staff) Policy
Alert Report — What to Report Policy and Alert Report Submission
How to Do a Survey
Large Landowner Engagement and Agreement
Carbon Project Design Document (PDD) — How to Initiate and Manage
Organogram and Company Information Sharing with External Parties

13. Interpretation

If this Policy conflicts with law, the Company's articles of association or governance documents, a binding contract, or a more specific approved Academy procedure, that higher or more specific authority prevails. Questions about interpretation are referred to the Head of Legal before any commitment is made to an external stakeholder.