Environment Social and Governance (ESG) Policy

1. Introduction

Spotler Group BV is committed to conducting its business operations in a manner that promotes
environmental sustainability, social responsibility, and ethical governance practices. This
Environment, Social, and Governance (ESG) Policy reflects our dedication to integrating ESG
considerations into our decision-making processes and daily operations.

2. Scope

This policy applies to all individuals associated with (one of the companies of) Spotler Group BV,
including employees, managers, directors, volunteers, contractors, consultants, and agents.

3. Environmental Responsibility

• We are committed to minimizing our environmental impact by reducing resource consumption,
  energy use, waste generation, and greenhouse gas emissions.
• We comply with all relevant environmental laws, regulations, and standards and strive to exceed
  compliance wherever possible.
• We continuously assess and improve our environmental performance through the
  implementation of sustainable practices, technologies, and initiatives.
• We have a Spotler charity committee who is committed to do a check on all the above and comes
  with initiatives to lowering carbon emissions.

4. Social Responsibility

• We recognize the importance of supporting and contributing to the well-being of our employees,
  customers, communities, and society at large.
• We promote diversity, equity, and inclusion within our workforce and provide equal
  opportunities for all employees to develop and succeed. See also our Diversity & Inclusion policy
  or contact our D&I crew.
• We prioritize health and safety in the workplace and strive to create a safe and supportive
  environment for all employees.

5. Governance Practices

• We are committed to upholding high standards of corporate governance, transparency, and
  ethical conduct in all our business activities.
• We establish and maintain clear policies, procedures, and internal controls to ensure compliance
  with applicable laws, regulations, and ethical standards.
• We maintain accountability and integrity in our decision-making processes and disclose relevant
  information to stakeholders in a timely and transparent manner.

6. Compliance

We comply with all applicable ESG laws, regulations, and industry standards and continuously
monitor changes in requirements to ensure compliance.

7. Continuous Improvement

• We are committed to continuous improvement and will regularly review and update our ESG
  policies, practices, and performance metrics to reflect changing priorities and emerging best
  practices.
• We encourage innovation and collaboration to find sustainable solutions to environmental and
  social challenges and promote a culture of responsible stewardship.

8. Review and Revision

This Environment, Social, and Governance (ESG) Policy will be reviewed periodically and updated as
necessary to ensure its continued alignment with our values, goals, and best practices in ESG