Environmental, Social & Governance ("ESG”) Brief

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Our ESG Strategy

We believe our commitment to sustainability promotes the financial health of our business, the quality of service we provide and value creation for our employees, communities, customers and investors. Looking to the future, we are mindful that social responsibility and environmental stewardship are inherent in the NexGen purpose and everything we do.

An inherently sustainable business model

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NexGen Networks is a premiere global network service provider committed to environmental, social, and governance (ESG) principles within its core business model. Our approach to ESG is deeply integrated into our business strategy, reflecting our dedication to sustainability, corporate responsibility, and ethical governance. NexGen Networks is proud to be an ESG-focused company dedicated to environmental, social, and governance excellence. We are pleased to announce that a comprehensive ESG Report for the year 2023 will be available in 2024. Thisreport will showcase our commitment to sustainability, corporate responsibility, and ethical governance, highlighting our achievements and initiatives in these critical areas. This current brief outlines how our business model aligns with ESG principles and contributes to a sustainable future.

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Environmental Responsibility

NexGen Networks' business model prioritizes environmental sustainability.

Energy Efficiency:

• Data centers and network infrastructure are energy efficient, reducing carbon emissions and energy consumption.
• We continuously invest in energy-efficient technologies, optimizing our operations for minimal environmental impact.

Renewable Energy Adoption:

• Part of our business model involves transitioning to renewable energy sources for our operations.
• We actively seek opportunities to invest in and procure renewable energy, such as wind and solar power, contributing to a cleaner energy mix.

Put the the customer at the center

Customer centricity is a way of doing business that fosters a positive customer experience at every stage of the customer journey. We put the customer at the forefront of everything we do by listening, learning and acting on custromer feedback.

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Unlocking Sustainability Through Innovation

Every day, NexGen is empowering our customers to create a positive impact. There are many ways we do this—and one valuable way is by supporting the sustainability goals of our customers. We enable our customers to adopt new technologies to manage their modernization and transformation journeys, while building solutions that drive efficiencies and growth. We empower our customers to imagine exciting new possibilities and foster bold innovation across industries and sectors— innovation that amplifies human progress. We play a key role in supporting smart industries of the future. By providing unity, access, speed, security and digital inclusion, we are meeting the needs of our customers in a rapidly evolving digital world and driving change for good.

Providing unity, access, speed and security

Working toward a more sustainable and equitable future requires organizations of all kinds to take a more strategic and collaborative approach. That’s the spirit in which we work with our customers and partners to build a more sustainable world through our technology. As a customer-centric company committed to furthering human progress through technology, our purpose has never been more critical. NexGen delivers on this vision by offering unity, access, speed and security.

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Sustainably meeting the growing demand for connectivity

Our strategies for reducing emissions and sourcing renewable energy are made with foresight, accountability and a long-term view. We are driving steady progress toward our carbon neutral by 2025 goal and are focused on making decisions that are good for both the environment and our business.

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Enabling a new wave of innovation

Bold innovation is at the heart of forward-thinking, resilient and successful businesses that are creating positive change. By empowering innovation, NexGen is helping build businesses that serve the world. We are enabling our customers to leverage and benefit from solutions to create better experiences for their customers.

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Empowering People

We want our employees to be proud to work with us and fully engaged with our efforts to make the world a better place. That means creating a positive culture, in which everyone feels empowered to achieve change. We engage and inspire others to pursue careers in tech, empower our employees to thrive and belong, and support community volunteerism by giving to the most vulnerable and the traditionally excluded.
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Talent, Recruitment and Retention

We employ people from around the world and one of our strengths as a company is their diversity. The mix of viewpoints, talents, experiences, backgrounds and beliefs at NexGen are respected and valued—and underpin our journey to amazing things. Our approach Our “one company, one culture” strategy helps us have a common language and set of behaviors for discussions, actions and decisions. Our Approach is two-pronged: we develop programs to equip our diverse leaders to lead inclusively; and we also seek to evolve our talent practices. We gauge the progress and capabilities of our people by tracking and analyzing data from various sources, including annual talent reviews and hiring and promotion trends. We are committed to providing equal opportunities for all employees. Our human resources policies strive for the highest standards covering recruitment, hiring, promotions, job assignments and all other aspects of employment.

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Recruitment

Every day we work hard to bring more diverse talent to NexGen and to provide outstanding opportunities for advancement to all employees—starting with a fair and unbiased application process. Our recruitment strategies, technologies and talent attraction initiatives connect people from all walks of life to our purpose and career opportunities.

We have an extraordinary vision for our forthcoming internal talent marketplace and we leverage:

• Leading candidate assessment technologies to reduce the impact of bias on talent selection
• Advanced technology for candidate lead generation and superior candidate experiences
• External diverse talent attraction strategies and toolkits
• A spirit of transparency and inclusion throughout our recruitment processes
• Emerging partners and technologies in the University Relations space to maximize our reach across hundreds of colleges and universities, including many diverse institutions
• Sponsorships and other opportunities for diversity recruitment advertisements, events, forums and trainings
• Data-driven approaches to decision making and prioritization

We have implemented diverse interview panels, which address unconscious bias in our recruitment process. We have also developed a non-biased pre-hire assessment process.

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Training and leadership development

At NexGen, a person’s career aspirations are our inspirations. Our equitable and inclusive talent practices aim to bring together the best mix of talent for the brightest ideas, the greatest achievements and the shared passion to transform industries across the globe. The continuous integration of the unique qualities of each employee with different perspectives of newly hired talent accelerates our innovation and cutting-edge technologies—all with the shared purpose and passion for furthering human progress through technology.

We have implemented “unconscious bias” training for our global workforce and maintain a dedicated internal channel on our learning platform that offers relevant videos, books and courses. These resources address a wide range of topics, including emotional and mental health, multicultural lessons in leadership, and today’s racial landscape. Developing strong leaders who can move our company forward is a priority for NexGen. As we look to the future, we continue to build opportunities to enable and build our diverse talent pipeline. Our Mentoring Circles offer a collection of mentoring relationships that build the competencies of our future leaders. Our leadership development programs are also designed to provide our people with tools, training and resources to engage, influence, coach, drive change and increase a growth mindset across our employee base.

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Employee engagement survey

We understand the importance of listening to our employees to make NexGen a great place to work. Our employee engagement survey is a vital part of this, which is why we continually improve it. In the latest survey, we saw an increase in our company’s overall engagement from 67 percent to 69 percent. For this voluntary survey, we also added new items to provide us insight on topics such as our employees’ well-being or how they align with the NexGen purpose. Well-being and diversity, inclusion and belonging are important aspects of the employee experience. We recorded a score of 77% for overall well-being as an organization, with 86% of our employees feeling that they had trusting relationships at work and 80% feeling positive about themselves at work. 86% of employees gave highly favorable responses about being themselves, feeling part of a team and feeling comfortable voicing their opinions.

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Diversity, inclusion and belonging

At NexGen, we celebrate the rich diversity of our global workforce and are determined to create an inclusive company that offers equal opportunities for all. We are committed to fighting racism, prejudice and bias in our workplaces, implementing initiatives to increase representation and reaching out to groups traditionally excluded from technology careers.

Our Approach

We know that diversity stimulates creativity, spurs innovation and drives profitability, which is why we are committed to creating inclusive, welcoming workplaces where everyone can feel at home and be their authentic selves. Realizing greater ethnic, racial and gender diversity at all levels is an ongoing process that requires honesty, openness and listening. We need to understand our prejudices and biases and commit to evolve—as individuals, as teams and as a company. We do this by regularly evaluating our progress.

Commitment to pay equity

We are deeply committed to providing our people with “equal pay for equal work.” It is not only the right thing to do—it creates a healthy working environment and ensures we can attract and retain diverse talent now and into the future. We have implemented tools and processes to review compensation decisions for pay equity as they are made.

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Employee well-being and benefits

Our people are the heart of what we do, so our approach to engagement and rewards is designed to help our employees live a healthy life, manage their finances and support the people in their lives.

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Our Approach

We invest in the physical, mental and emotional well-being of our people through a broad range of benefits. We want our people to thrive, feel valued and be satisfied at work. Our employee wellness programs are designed to support people to adopt and maintain a healthy lifestyle and look at the whole person. We consider work–life integration as well as our employee’s families. Our employees’ place of work varies depending on their role and circumstances. In response, we have adopted a hybrid approach to well-being and provide consistent education to ensure our people know about our full range of benefits, so they are able to access the right service when they need it.

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Wellness programs

The health, safety and well-being of our employees, business partners and global communities is our top priority. We are committed to better-than-industry-average safety performance and continuing our investments in programs and training to support health and safety. We offer consumer-driven health insurance plans as well as dental and vision plans. Our other health promotion programs include private medical, disability and travel accident insurance, dental and vision care.

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Benefits

We offer progressive employee benefits that recognize the diverse needs of our people and their families. These include:

• Paid time off (PTO) & Flexible time off (FTO)
• Maternity and Parental leave
• Healthcare benefits
• Mental health benefits
• Disability accommodations

Community Engagement

For us, working with our communities is about having a positive influence on the world. We encourage our employees to volunteer and give to causes that are important to them, supporting their passions through matching charitable donations.

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Our vision

To support our communities while building a sense of community.

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Our mission

To multiply our impact by supporting people’s passions, empowering the next generation of innovators and providing for the basic needs of communities.
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Our Approach

We make strategic investments that create lasting positive impacts in the communities we serve. Our goal is to be a trusted community partner around the globe. We direct our charitable giving to three focus areas:

• The interests and passions of our employees
• Young people, who are the next generation of innovators
• The basic needs of our local communities

More and more employees want to work for companies that actively support their communities.

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Building strong governance & transparency in this section

We believe in principles of strong corporate governance. Our culture of honesty, integrity and doing the right thing help us build trust and protect the interests of our company and partners. Our highly competitive business thrives from a results-focused team that is motivated and inspired by skilled leadership and driven by ethical and meaningful business objectives.

Corporate Governance

Our commitment to acting responsibly flows from the Principles upon which NexGen was built. Fairness, honesty, integrity and our commitment to excellence support our approach to governing for the benefit of all.

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Our Approach

Responsible corporate citizenship is the foundation of our business. We have adopted sound corporate governance practices that protect the interests of our customers, employees and our partners. NexGen’s management team evaluates our ESG program and identifies meaningful environmental, social, governance and financial factors. They also routinely assess our disclosure and communication plans for their strength and effectiveness.

Ethics and Compliance

NexGen’s culture is grounded in integrity, honest communication and mutual respect.  

Our commitment to ethical and responsible corporate conduct is reflected in our Unifying Principles:

• Fairness
• Honesty & integrity
• Commitment to excellence
• Positive attitude
• Respect
• Faith
• Perseverance

These principles are the values on which NexGen was built, and they guide our interactions with customers, employees, business partners, elected officials and the public.

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Our Approach

We continue to evolve, communicate and enforce our global Code Of Conduct and compliance with laws everywhere we do business. Our range of initiatives, policies and processes cover everyone that works with or for NexGen, including our agents, contractors, partners, suppliers & vendors. We have zero tolerance for forced or child labor, human rights violations, bribery, corruption, money laundering or engagement with blocked parties or sanctioned countries. In addition, we remain committed to supporting diversity, upholding human rights, international trade compliance, antitrust and fair competition laws, and transparency in political contributions. In response to the constantly changing business landscape, we develop targeted training. As part of our Code of Conduct training, we include information on sustainable supply chains and procurement practices to ensure we partner with ethical third parties, international trade compliance training for our non-U.S. sales teams and anti-corruption training.

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Ethics and Compliance Program

Our global corporate Ethics and Compliance program—communicates the ethical and legal standards that govern our business conduct. We regularly review and improve it. In 2022, we audited several areas of the program, including the whistleblower program. We brief all audit results and actions to the Audit Committee. Looking ahead, our Ethics and Compliance group will focus on topics including education, continual risk assessments and automation, by:

• Making training and communication more engaging.
• Carrying out focused risk assessments.
• Automating various functions, including elements of our sanctions compliance program and vendor risk assessments.

Global Code of Conduct

Our Code of Conduct, provides detailed guidelines and ethical standards for employees worldwide, including executive management, and offers resources to help our people seek guidance and report concerns. All employees must complete our Code of Conduct annually.

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Commitment to human rights

NexGen is committed to proactively addressing human rights issues and risks within our business, and in our relationships with third parties. Our Code of Conduct and Supplier Code of Conduct address topics relating directly to human rights, while our Human Rights Policy—outlines our expectations in areas including:

• Privacy and data security
• Individual rights
• Freedom of association
• Diversity, inclusion and fair treatment
• Working conditions including our prohibition of forced and child labor

We train our employees to recognize and report concerns in these and related areas. Our Modern Slavery Statement, describes how we combat modern slavery and human trafficking in our business and supply chains globally, and how we plan to build on these efforts.

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Anti-bribery, anti-corruption and anti-money laundering

Our Anti-Corruption Policy and Supplier Code of Conduct require all our people and the third parties with whom we do business to adhere to all applicable anti-bribery and anti-corruption laws, including the Foreign Corrupt Practices Act and the United Kingdom Bribery Act. We train all our employees annually on anti-corruption laws and policies. Our strict anti-bribery policy defines appropriate interaction with government officials and the program is regularly audited to ensure continued compliance. We also strictly prohibit financial crimes such as money laundering, the facilitation of tax evasion, terrorist financing, securities fraud and market manipulation. Our Insider Trading Policy informs our employees about what constitutes insider trading and our zero-tolerance approach to it.

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Anti-competitive behavior

We support fair competition in the global marketplace. We recognize the benefits of a free market ensuring competition for consumers, and we strongly oppose anticompetitive practices that stifle economic growth. Our policies require compliance with all antitrust and fair competition laws. We reinforce our policies through training, communication initiatives, and provide scenario-based examples.

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Supplier management

Delivering our services and building network resiliency means working closely with an ecosystem of suppliers around the world. We work diligently to partner with the right suppliers—those with the capabilities we need as well as the commitment to meet the same high standards to which we hold ourselves.

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Cybersecurity, data and customer privacy

We value the trust our customers place in us, and we are passionately committed to handling, managing and securing their information in an appropriate, safe and ethical manner.

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Our vision for cyber defense:

• Integrate security in everything that NexGen does and continue to be viewed as a world-class organization
• Move to a service-oriented organization that is easy to consume and will deliver above expectations
• Innovate and continue to move our talent up the value chain
• Measure everything we do and continuously improve on what matters

Our Approach

As a company that enables the global transmission of large amounts of information, maintaining the security and integrity of information and systems is a priority for our operational risk management work.

In addition to securing our network, we protect the data and information we collect, store, use and share. Employee and customer data is encrypted, consistent with industry standards or legal requirements, both at rest and in transmission. We develop and adopt rigorous policies and standards and implement training for our employees and contractors to ensure they are adhered to, in addition to role-based security training as needed. Our people play a vital role in the protection of NexGen assets, so in addition to training, we publish monthly articles about relevant security topics and engage with Cybersecurity Awareness Month every year.

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Cybersecurity

NexGen thinks of cybersecurity as an enterprise-wide responsibility, subject to risk control and monitoring at various levels throughout the company. We regularly assess our program, including the adequacy and effectiveness of our internal controls, emerging developments and threats, and response and contingency plans, and cybersecurity notables are reported to the Risk and Security Committee. NexGen shares information with, and receives information from, the U.S. government, primarily through the Department of Homeland Security’s Cybersecurity & Infrastructure Security Agency (CISA), which is the national coordinator for sharing threat information and initiatives to assure infrastructure security and resiliency.

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We have developed a detailed plan to enhance our cyber and resilience strategy. Across People, Process and Technology focus areas, we will make financial and human capital investments, such as:

• Developing cybersecurity knowledge and training at senior leadership levels
• Building strong partnerships between business units
• Continuing to shift to cloud and hybrid hosting models
• Adopting robust security compliance programs
• Using a layered security architecture
• Aligning with the National Institute of Standards and Technology (NIST) cybersecurity framework
• Building strong vendor relationships and partnerships

Data privacy

Our data minimization policy is designed to comply with applicable state, federal and other international jurisdictions’ laws and ensure appropriate protections when sharing information with third parties, including vendors. As part of the Enterprise risk management (ERM) process, the Risk and Security Committee receives reports on data privacy protection efforts and controls.

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Control and risk management process

We have developed a robust, comprehensive information security program, based on leading information security standards, that includes components focused on technical, administrative and organizational measures to help us prevent, detect and respond to potential security incidents. At least annually, we engage internal or fully accredited external auditors and consultants to assess and enhance our program.

Cybersecurity and data privacy audits and monitoring

Our Cybersecurity program is a partnership between Business Continuity and Global Security, as well as other internal executives. We conduct annual exercises at both team and management levels. In 2024, we plan to enhance the program and carry out further exercises.

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Customer privacy

Like many companies, we have access to information about our customers that is used to support our products and services. We also share customer data where appropriate to meet our business goals or fulfill legal obligations. We take all legally required and reasonable actions to protect this information and expect those we share it with to appropriately protect it as well. The NexGen Privacy Notice describes how we use and protect the data we collect about customers and their privacy options.

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Employee & Contractor Training

At NexGen, we believe security is everyone’s responsibility. Our Security Awareness is designed to help employees and contractors recognize and appropriately respond to potential cyber and data security risks for our customers, vendors and the company– covering many core information security topics including data security, hacking risks, malware and phishing. As email-based attacks and phishing are frequent forms of security risks, we also conduct regular phishing simulations.

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Business Continuity Management

Our Business Continuity Management (BCM) program is designed to safeguard our employees, assets, and our reputation in the event of an accident, incident or critical business disruption. By aligning to the company’s goals and using a proven standards-based framework, our BCM program supports an environment of prevention, collaboration, communication and response. This enables us to effectively adapt, respond and recover if a major incident occurs.  Our BCM adheres to ISO 22301:2012, the International Standard for BCM and engages internal and external auditors to assess the program’s efficacy and compliance with customer requirements. Our BCM supports our vision, strategy and corporate objectives by:

• Annually evaluating the purpose and operations of every business unit in the company by identifying threats, hazards and potential impacts to critical business priorities
• Developing strategies for mitigation, continuity and recovery
• Maintaining uninterrupted service whenever possible and, when necessary, coordinating recovery from business disruptions safely and quickly
• Enabling continuous improvement by periodically reviewing program strategy and performance

Disclaimer

The information in this brief is subject to change, and NexGen Networks will not necessarily disclose such changes. The information may be updated, amended, supplemented or otherwise altered by subsequent reports or filings by NexGen.

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The contents of this voluntary ESG brief are informed by various frameworks, including standards and recommendations. These various frameworks define significant concepts differently and we do not attempt to reconcile such differences in our overarching ESG approach. We plan to continue enhancing our ESG-related disclosures and increasing alignment with the referenced frameworks, even as such frameworks continue to rapidly evolve. As disclosure frameworks or reporting requirements change worldwide, the information we share and the way it is shared may change over time.

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References in this ESG brief to certain data points should not be construed as a characterization regarding the “materiality” of such information, as evaluated in the context of U.S. securities laws. Except for historical and factual information, the matters set forth in this ESG brief identified by words such as “will,” “should,” “expects,” “anticipates,” “believes,” “plans,” “intends” and similar expressions are forward-looking statements within the meaning of the “safe harbor” provisions of the Private Securities Litigation Reform Act of 1995.

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These forward-looking statements are subject to a number of risks, uncertainties and assumptions, many of which are beyond our control. Actual events and results may differ materially from those anticipated by us in those statements for several reasons, including those discussed in this ESG brief and elsewhere. You should not place undue reliance on these forward looking statements, which speak only as of the date of this ESG brief. Unless legally required, NexGen Networks undertakes no obligation and expressly disclaims any such obligation to update publicly any forward-looking statements, whether as a result of new information, future events or otherwise.

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Message from our CEO

‍Jeffrey Barth, President & CEO

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At NexGen Networks, we view ESG as an integral part of our identity anda driving force behind our mission. Our journey towards sustainability, corporate responsibility, andethical governance is deeply ingrained in our corporate culture. We have madesignificant strides in aligning our operations with ESG principles, recognizingthe profound impact these principles have on our stakeholders, the environment,and society at large. In the realm of environmental responsibility, we have prioritized energyefficiency, renewable energy adoption, waste reduction, and carbon footprintreduction. Our commitment to sustainable practices extends to our sourcing ofrenewable energy to power our operations. Our goal of achieving carbon neutrality by 2025 is a testament of our dedication to reducing our environmental footprint. NexGen Networks places great emphasis on social responsibility, embracing diversity and inclusion, fostering employee wellbeing, engaging with local communities, and upholding ethical practices. Our workforce diversity is a source of strength, and we are dedicated to creating a workplace where every individual feels valued and respected. Furthermore, we actively contribute to the betterment of the communities where we operate through various community engagement initiatives. Strong governance practices are the bedrock of our corporate governance. We maintain a governance structure that promotes transparency, accountability,and ethical conduct. Transparency is at the heart of our commitment to ESG. We will be undergoing a third-party verification to ensure the accuracy and credibility of our ESG data and reporting. As we move forward, NexGen Networks remains unwavering in its commitment to ESG principles. We will set ambitious goals, invest in innovative technologies, enhance diversity and inclusion, and collaborate with stakeholders to advance our ESG initiatives. We will release a comprehensive ESG report for the year 2023, providing a detailed account of our progress and achievements. I would like to express my gratitude to our employees, partners, and the communities we serve. Your trust and support are in valuable as we continue our journey to a sustainable and responsible future.

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Best regards,

Jeffrey Barth