Governance

Our longstanding commitment to ethical behavior and doing the right thing is fundamental to how we do business. We are committed to transparency in governance and have mature programs and processes in place to inform our employees about expected behavior and our commitment to compliance with all applicable laws. All officers and employees must adhere to our Code and review and certify compliance. We also expect our suppliers and contractors to share our commitment.

Ethics and Compliance
Sentinel Peak employees are required to confirm their written acknowledgement with best practice code of conduct standards which includes areas such as:

Conflicts of Interest
Employees must not engage in any activities or relationships, including personal investments, which might directly or indirectly result in a conflict of interest, or impair their independence of judgment. If a conflict is identified and deemed permittable by legal and executive management, employees are required to sign individually tailored disclosure and commitment forms, to abide by determined protocols and Company policy, and the related engagements are then monitored by Legal and Human Resources.

Whistleblower Reporting
We strive to create an environment in which everyone feels comfortable raising concerns. Since 2018, Sentinel Peak has engaged Lighthouse Services to provide anonymous, independent third-party ethics hotline services available to employees, suppliers, communities, and anyone else to report a concern or suspected violation of our code. All issues raised are logged in a database and tracked until resolved. This reporting can be accessed at www.lighthouse-services.com/sentinelpeakresources.

We do not tolerate retaliation against anyone who raises questions or concerns; anyone who promptly and in good faith reports an alleged violation of the Code, the Company’s policies and procedures or the applicable laws or regulations; or anyone who participates or cooperates honestly and completely in the investigation of a report.

Cybersecurity and Data Privacy
Sentinel Peak is committed to adopting cybersecurity protocols to safeguard our digital data and continually advance the security of our systems and data source integrity. Some of our recent and ongoing activities include

• • Vulnerability assessment and processes in place to handle cybersecurity threats.
  • Holistic security solution in place across the entire enterprise with active threat monitoring.
  • Weekly Cybersecurity reports automated to management.
  • Quarterly Cybersecurity End User testing and corresponding training.
  • Patch management in place on all devices within the environment.
  • Disaster Recovery capabilities in place utilizing cloud service will ensure Business Continuity.

Public Policy and Advocacy
Sentinel Peak operates within a complex, regulated industry. As such, we believe it is vital to be engaged with our federal, state and local governments as well as industry working groups. Sentinel Peak works transparently with lawmakers and regulators at all levels of government to keep them apprised of impacts that existing and proposed laws and regulations may have on our industry and to understand their regulatory priorities. Regulatory initiatives include a significant CCS pilot project; a Hopkins solar panel project; and exploring utilizing renewable natural gas from dairy farms in San Joaquin thermal recovery projects.