ENVIRONMENTAL AND SOCIAL POLICY FRAMEWORK - UBITS

1. Introduction

UBITS LEARNING SOLUTIONS HOLDINGS LIMITED (the “Company”) is committed to effective management practices to reduce or mitigate exposure of environmental and social risk throughout its operations, including its supply chain, its sites of operation and human resources matters, and customer relationships.  The Environmental and Social Policy Framework (the “Framework”) is global and applies to all of our business operations in all jurisdictions and seeks to be consistent with the precautionary principle of “do no harm”.

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2. Policy Objectives

Our objective is to comply with all applicable environmental, health, safety, and labor laws and regulations across our jurisdictions.  Over time, we will seek to converge our internal policies and procedures to good international industry practice such as the IFC Performance Standards.

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The Company aims to:

• Ensure the safety of its products and operations in order to operate in an environmentally and socially responsible manner.
• Develop processes and practices, which reduce or mitigate environmental and social risks and impacts to an acceptable level.
• Ensure that its employees and contractors work in a safe environment and are provided fair working conditions.
• Not engage with suppliers or potential customers when the Company due diligence indicates that the counterparty principal business activities or environmental and social practices are materially inconsistent with the Framework.

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3. Engagement, Reporting, and Inspection

• Employee, Contractor, and Supplier Engagement

We will engage with and educate our employee base, contractors, and suppliers on our commitment to the Framework, and, where possible, seek to require adherence to similar principles to the Framework from contractors and suppliers.

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• Industry, Government, and International Body Engagement

We may engage with industry bodies, government agencies and other relevant organizations to promote environmental and social care, increase knowledge and disseminate best practices.

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• Reporting

Promptly after the Company or any of its subsidiaries obtains knowledge thereof, the Company will furnish or cause to be furnished to the Board of Directors, or a subset thereof (such subset to include a Series C Director), a notice of the occurrence of any accident or event directly or indirectly caused by the Company or any of its subsidiaries or affecting any worker engaged in their official duties that results in the loss of life or that has any significant social, labor, health and safety, security or environmental incident, accident or circumstance relating to the Company or any of its subsidiaries (an “E&S Event”).  Exhibit A contains an incident reporting framework.

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• Inspection

If there is an E&S event, upon the written request of a Riverwood Director, the Company will provide reasonable access to management and company premises to investigate the event to the reasonable satisfaction of the Riverwood Director.

Exhibit A: Incident Reporting Framework

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