Health, Safety & Environment Policy

Aghomi Energy Limited is committed to conducting all operations in a manner that protects the health and safety of our employees, contractors, clients, and the communities near our project sites, while minimising our environmental impact at every stage of every engagement.

We believe firmly that all injuries, occupational illnesses, and environmental incidents are preventable. This belief is not aspirational — it is the operating principle that shapes how we plan, staff, equip, and execute every project we undertake, from a single well campaign to a full pipeline construction programme. There is no project for which we relax this standard and no location where different rules apply.

Senior leadership at Aghomi Energy takes personal responsibility for the health, safety, and environmental performance of the business, and every person in our organisation is expected to take it seriously in their own area of work.

This policy applies to all Aghomi Energy Limited employees, whether permanent, contract, or temporary, and to all subcontractors and third-party service providers operating under our supervision or as part of any project we are responsible for delivering.

It applies across all project sites, locations, and regions where Aghomi Energy operates, including onshore facilities, shallow water installations, office environments, and transit routes used in the course of project mobilisation and demobilisation. No part of our operations is outside the scope of this policy.

Our specific, ongoing HSE objectives are:

• Achieve and maintain zero Lost Time Injuries (LTIs) across all projects
• Eliminate all fatalities and serious injuries from our operations
• Prevent all spills, releases, and environmental incidents through robust planning and active monitoring
• Achieve full compliance with all applicable Nigerian health, safety, and environmental regulations on every project
• Conduct formal HSE inductions for 100% of personnel before they begin work on any site
• Complete scheduled safety audits and reviews across all active projects without exception
• Investigate all incidents and near misses promptly, determine root causes, and implement corrective measures
• Promote a culture in which every team member feels empowered and supported in raising safety concerns

Management: The Managing Director and senior leadership team are responsible for ensuring that adequate resources — people, time, and budget — are allocated to HSE across all projects. They are responsible for setting the tone on safety, modelling safe behaviour, and holding the business accountable to the standards in this policy.

HSE Manager: The HSE Manager leads the development, implementation, and review of Aghomi Energy’s HSE management system. They are responsible for regulatory compliance, internal audit programmes, incident investigation, and the ongoing development of our HSE practices. They report directly to the Managing Director.

Project Managers and Site Supervisors: Those responsible for managing projects and supervising work on site are accountable for day-to-day HSE performance. They are responsible for conducting pre-task risk assessments, ensuring all personnel under their supervision have received appropriate inductions, maintaining a safe working environment, and escalating issues promptly.

All Personnel: Every person working under Aghomi Energy’s operations, including subcontractors, is expected to follow all applicable safety procedures and instructions, report hazards and near misses without delay, participate constructively in safety briefings, and refuse to carry out any work they believe is unsafe. The right to stop unsafe work is available to every person on site and must never be discouraged.

Aghomi Energy manages HSE risk through a structured, systematic process applied before and throughout every project. This process includes:

• Formal Hazard Identification and Risk Assessments (HIRA) prior to mobilisation and before any novel or high-risk activity commences
• Development of project-specific safe work procedures and method statements covering all significant activities
• Pre-task briefings (toolbox talks) before each work shift and before any activity where conditions have changed
• Formal Permit to Work systems for high-hazard activities including work at height, hot work, confined space entry, and electrical isolation
• Regular site inspections by supervisors and scheduled independent HSE audits

Risk assessments are not one-time exercises. They are revisited when site conditions change, when a near miss or incident occurs, and at regular intervals throughout the project lifecycle.

All incidents — including near misses, first aid cases, Lost Time Injuries, dangerous occurrences, and environmental releases — must be reported immediately to the site supervisor and the HSE Manager. There is no threshold below which an incident or near miss does not need to be reported.

We investigate every reported incident to identify the root cause and contributing factors. This is not about assigning blame. It is about understanding what happened so we can prevent it from happening again. Investigation findings are communicated to relevant teams and translated into practical corrective and preventive actions that are tracked through to completion.

Aghomi Energy supports a non-punitive reporting culture. Personnel are expected and encouraged to report hazards and near misses without fear of negative consequences. Concealing or discouraging the reporting of an incident is a serious disciplinary matter.

We are committed to protecting the environments in which we operate. This applies equally to sensitive ecological zones, agricultural land, and marine and freshwater environments. Our environmental obligations are not discharged by obtaining regulatory approvals — they continue throughout the life of every project.

• All projects with significant environmental dimensions will be supported by an Environmental Management Plan prepared in advance of mobilisation
• Waste management and disposal will follow applicable Nigerian regulatory requirements and industry best practice at all times
• Chemical and hydrocarbon storage will comply with secondary containment requirements to prevent ground and water contamination
• Spill response kits and trained spill response personnel will be maintained at all project sites where hydrocarbons are present
• Environmental monitoring will be conducted in accordance with the requirements of applicable assessments and approvals, and data will be reported honestly and on time

Communities in the vicinity of our project sites are not a compliance consideration — they are stakeholders whose safety and wellbeing are our genuine responsibility. We take a proactive approach to identifying and managing risks that our operations may pose to third parties, including local residents, road users, and those working near our sites.

Before commencing work in or near a community, we will communicate project activities and associated risks clearly, establish contact points for concerns and feedback, and implement appropriate exclusion zones and controls. We will engage host communities honestly and respectfully throughout every project and address legitimate safety concerns without delay.

No person will be deployed to a project site in any capacity without completing an appropriate HSE induction relevant to the activities they will be undertaking. Induction is not a formality — it is a substantive exercise designed to ensure every person on site understands the specific hazards they face and what is expected of them.

Beyond induction, we ensure that all personnel performing technical or high-risk activities hold the qualifications and certifications required for those activities. We invest in ongoing training and competence development across our teams. Training records are maintained for every individual and made available for inspection by clients or regulators on request.

HSE performance is included in the assessment of all employees. Consistently poor safety behaviour is addressed through our disciplinary process.

Aghomi Energy complies with all applicable health, safety, and environmental legislation and regulations in Nigeria. This includes, but is not limited to, requirements set by the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), the National Environmental Standards and Regulations Enforcement Agency (NESREA), the National Oil Spill Detection and Response Agency (NOSDRA), and relevant provisions of the Petroleum Industry Act and its subsidiary instruments.

We treat regulatory requirements as a minimum standard, not a target ceiling. In areas where industry best practice exceeds what is legally required, we will generally apply the higher standard. We maintain current registrations, certifications, and permits relevant to our operations and make these available to clients on request.

This policy will be reviewed annually by the Managing Director and the HSE Manager, and updated as necessary to reflect changes in our operations, applicable regulations, or industry best practice. Reviews may also be triggered by a serious incident, a significant change in the nature of our work, or recommendations arising from an external audit.

All revisions to this policy will be communicated to relevant personnel, and updated versions will be made available to clients and regulatory bodies on request. The policy is published on our website and forms part of our HSE management system documentation.

Questions or concerns about this policy should be directed to our HSE Manager at info@aghomienergylimited.com.