1. Introduction & Purpose

This Environmental, Social & Governance (ESG) Policy (the "Policy") articulates Nexly Corporation's ("Nexly" or the "Company") commitment to operating as a responsible corporate citizen, integrating environmental, social, and governance considerations into its business strategy and operations. Located at 701 South Street Suite 100, Mountain Home, AR 72653, Nexly recognizes the importance of addressing the environmental and social impacts of its activities while upholding the highest standards of corporate governance. This Policy is designed to:

• Minimize Environmental Impact: Minimize the environmental impact of our operations, products, and services, and contribute to the preservation of natural resources and the fight against climate change.
• Promote Social Responsibility: Promote social responsibility through ethical labor practices, diversity and inclusion, community engagement, and respect for human rights.
• Uphold Good Governance: Maintain the highest standards of corporate governance, including transparency, accountability, and ethical conduct.
• Create Long-Term Value: Create long-term value for our stakeholders, including shareholders, employees, customers, communities, and the environment.
• Comply with Applicable Laws and Regulations: Comply with all applicable laws, regulations, and industry standards related to ESG.
• Communicate Transparently: Provide transparent and timely information to stakeholders on our ESG performance.
• Continuously Improve: Continuously improve our ESG performance.

This Policy applies to all Nexly employees, officers, directors, contractors, and other individuals and entities acting on behalf of the Company. This Policy is to be read in conjunction with other Company policies, including, but not limited to, the Ethical Sourcing Policy, the Anti-Discrimination & Equal Opportunity Policy, the Data Privacy Policy, the Information Security Policy, the Code of Conduct, and the Environmental Policy.

2. Environmental (E) - Stewardship & Sustainability

Nexly is committed to minimizing its environmental impact and to contributing to a more sustainable future. Our environmental goals include, but are not limited to:

• 2.1. Climate Action:
  • GHG Emissions Reduction: Reduce greenhouse gas (GHG) emissions from our operations and supply chain by [Specify Target Percentage, e.g., 30%] by [Specify Target Year, e.g., 2030], compared to a [Specify Base Year, e.g., 2023] baseline.
  • Renewable Energy: Increase our use of renewable energy sources to [Specify Target Percentage, e.g., 50%] of our electricity consumption by [Specify Target Year, e.g., 2028].
  • Carbon Offsetting: Invest in carbon offsetting programs and/or carbon removal technologies to address any unavoidable emissions.
  • Tracking and Reporting: Track and report on our GHG emissions annually.
• 2.2. Resource Conservation:
  • Energy Efficiency: Implement energy-efficiency measures to reduce energy consumption in our facilities. [Specify Percentage, e.g., 15%] by [Specify Year, e.g., 2028].
  • Water Conservation: Conserve water resources by implementing water-saving practices in our operations. [Specify Percentage, e.g., 10%] by [Specify Year, e.g., 2028].
  • Waste Reduction: Minimize waste generation and promote waste reduction, reuse, and recycling. Divert [Specify Percentage, e.g., 75%] of waste from landfills by [Specify Year, e.g., 2028].
  • Sustainable Materials: Prioritize the use of sustainable materials in our products and packaging, where feasible.
• 2.3. Environmental Compliance & Management:
  • Environmental Regulations: Comply with all applicable environmental laws and regulations.
  • Environmental Management Systems: Implement environmental management systems (e.g., ISO 14001) where appropriate.
  • Supplier Engagement: Work with suppliers to minimize their environmental impact. Follow the Ethical Sourcing Policy, [Link to Ethical Sourcing Policy].

3. Social (S) - People & Communities

Nexly Corporation is committed to creating a positive social impact through ethical labor practices, diversity and inclusion, community engagement, and respect for human rights.

• 3.1. Employee Well-being and Development:
  • Safe and Healthy Workplace: Provide a safe and healthy work environment. See also the Employee Health & Safety Policy [Link to Health and Safety Policy].
  • Fair Labor Practices: Provide fair wages, benefits, and working conditions.
  • Employee Development: Offer opportunities for employee development and training.
  • Work-Life Balance: Promote work-life balance.
  • Mental Health Support: Provide mental health resources.
  • Flexible Work: Promote flexible work options.
• 3.2. Diversity, Equity & Inclusion (DEI):
  • Commitment: Foster a diverse and inclusive workplace. See also the Diversity, Equity & Inclusion Policy [Link to DEI Policy].
  • Equal Opportunity: Ensure equal opportunity in all aspects of employment.
  • Non-Discrimination: Prohibit discrimination and harassment.
  • Employee Resource Groups: Support Employee Resource Groups (ERGs).
• 3.3. Human Rights:
  • Respect for Human Rights: Respect and uphold human rights in all of our operations.
  • Prohibition of Forced Labor and Child Labor: Prohibit forced labor and child labor in our operations and supply chain. Follow the Ethical Sourcing Policy, [Link to Ethical Sourcing Policy].
• 3.4. Community Engagement:
  • Community Support: Support the communities in which we operate through philanthropy, volunteering, and other initiatives.
  • Local Partnerships: Partner with local organizations to address social and environmental issues.
• 3.5. Supplier and Vendor Social Responsibility:
  • Supplier Standards: Enforce ethical standards and monitor supply chain partners.

4. Governance (G) - Integrity & Accountability

Nexly Corporation is committed to maintaining the highest standards of corporate governance, including transparency, accountability, and ethical conduct.

• 4.1. Board of Directors:
  • Independent Oversight: The Board of Directors provides independent oversight of the Company's ESG performance.
  • ESG Integration: The Board will integrate ESG considerations into its decision-making processes.
• 4.2. Ethics and Compliance:
  • Code of Conduct: Adhere to the Company's Code of Conduct, which outlines the ethical principles that guide our business conduct.
  • Ethics Hotline: Provide an Ethics Hotline for employees to report concerns. Follow the Ethics Hotline/Speak Up Policy [Link to Ethics Hotline Policy].
  • Anti-Corruption: Prohibit bribery, corruption, and other unethical practices.
  • Compliance: Compliance with all applicable laws and regulations.
• 4.3. Transparency and Disclosure:
  • ESG Reporting: Regularly report on our ESG performance.
  • Stakeholder Communication: Communicate our ESG performance to our stakeholders, including shareholders, employees, customers, and the public.
  • Information Accuracy: Ensure that all information is accurate, truthful, and verifiable.
• 4.4. Risk Management:
  • ESG Risk Assessment: Identify and manage ESG-related risks. See also the Risk Management Policy [Link to Risk Management Policy].
  • Risk Mitigation: Implement risk mitigation strategies.
• 4.5. Data Protection and Privacy:
  • Data Privacy: Protect the privacy and security of all data. Follow the Data Privacy Policy [Link to Data Privacy Policy].
• 4.6. Insider Trading, Stock Manipulation, and Corporate Waste:
  • Compliance: Nexly has strong controls.

5. Implementation & Governance Structure

The implementation of this ESG Policy will be overseen by:

• 5.1. ESG Committee (or equivalent): (If applicable, or alternatively, a designated senior management group)
  • Committee Responsibilities: The ESG Committee will be responsible for developing, implementing, and monitoring the Company's ESG strategy.
  • Committee Composition: The ESG Committee will be comprised of [Specify Members and their Titles, e.g., the CEO, CFO, Head of Sustainability, Head of HR, Legal Counsel, and other relevant senior leaders]. The Chair of the ESG Committee will be [Specify Title, e.g., the CFO or a designated senior leader].
  • Activities: The ESG Committee will:
    • Define ESG goals, targets, and metrics.
    • Oversee the development and implementation of ESG initiatives.
    • Monitor and measure the Company's ESG performance.
    • Prepare and/or oversee ESG reporting.
    • Review and update this Policy regularly.
• 5.2. Cross-Functional Collaboration: Successful implementation of this Policy requires collaboration across all departments and functions of the Company.
• 5.3. Resources: Nexly will provide the resources necessary to support the implementation of this Policy.
• 5.4. Third-Party Involvement: Nexly will work with stakeholders, vendors, suppliers, and other business partners to ensure compliance with its ESG guidelines.

6. Reporting & Disclosure

Nexly Corporation is committed to transparency and will regularly report on its ESG performance.

• 6.1. Reporting Frequency: Nexly will publish an annual ESG report, or integrate ESG performance information into its existing reporting.
• 6.2. Reporting Framework: The Company will align its ESG reporting with recognized reporting frameworks, such as the Sustainability Accounting Standards Board (SASB), the Task Force on Climate-related Financial Disclosures (TCFD), or the Global Reporting Initiative (GRI), and may seek independent verification of the report.
• 6.3. Report Content: The ESG report will include, but not be limited to, the following information:
  • The Company's ESG goals, targets, and metrics.
  • The Company's performance against its ESG goals.
  • A description of the Company's ESG initiatives.
  • Disclosures on key ESG risks and opportunities.
• 6.4. Stakeholder Engagement: The Company will engage with its stakeholders to gather feedback on its ESG performance and to inform its ESG strategy.
• 6.5. Regulatory Reporting: The Company will disclose all required information.

7. Policy Review & Amendments

This ESG Policy will be reviewed and updated regularly to ensure its continued relevance, effectiveness, and alignment with best practices.

• Review Frequency: This Policy will be reviewed at least [Specify Frequency, e.g., annually] or more frequently as needed.
• Review Process: The review process will involve:
  • Input from Stakeholders: Seeking input from relevant stakeholders, including the ESG Committee (or equivalent), management, employees, and external experts.
  • Performance Evaluation: Assessing the Company's ESG performance against its goals and objectives.
  • Benchmarking: Reviewing industry best practices.
  • Legal and Regulatory Review: Ensuring compliance with all applicable laws, regulations, and industry standards.
• Policy Amendments and Communication: Any amendments to this Policy will be approved by [Specify Approving Authority, e.g., the Board of Directors or the Executive Leadership Team] and communicated to all employees through [Specify Communication Channels, e.g., company-wide email, intranet posting, training sessions].
• Policy Ownership: The ESG Committee (or equivalent), with support from Legal Counsel, is responsible for maintaining and updating this Policy.

**Acknowledgement:** By engaging in any activity on behalf of Nexly Corporation, all employees, contractors, and vendors are deemed to acknowledge that they have read, understood, and agree to support and abide by the terms and conditions outlined in this Environmental, Social & Governance (ESG) Policy.