Modern Slavery Report 2024

A PDF of this statement is available for download here.

This report (the “Report”) has been prepared by Metergy Solutions Inc., (“Metergy” and throughout thisReport “our” and “we”) for the financial year ended December 31, 2024, pursuant to the Fighting AgainstForced Labour and Child Labour in Supply Chains Act (the “Act”). This is Metergy’s second report underthe Act.

Metergy recognizes its responsibilities to ensure that modern slavery is not occurring in any part of our business or supply chain. We are committed to conducting business in an ethical and responsible manner,including by carrying out our activities in a manner that respects and supports the protection of humanrights, including but not limited to:

1. operating with leading health and safety practices to support the goal of zero serious safety incidents;
2. fostering a positive work environment based on respect for meritocracy, valuing diversity and having zero tolerance for workplace discrimination, violence or harassment; and
3. the prohibition of human trafficking, forced labour and child labour.

We recognize that the risks of human rights violations, human trafficking and modern slavery are complexand evolving, and we will continue to work on addressing them in our business. Our approach and processes are periodically reviewed and, where appropriate, updated as necessary to reflect changes in circumstances and practice.

Summary of Key Activities in 2024

In 2024, Metergy took several proactive steps to strengthen its approach to identifying, mitigating, andmanaging risks related to modern slavery within its operations and supply chain. These initiatives reflect our ongoing commitment to uphold human rights and ethical practices in every aspect of our business.
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a. Combined Human Rights and Anti-Modern Slavery Policy
‍Metergy developed and implemented a Human Rights and Anti-Modern Slavery Policy that codifies our approach to respecting fundamental human rights and our efforts to identify and prevent humanrights violations within our business and supply chain. This policy applies to all Metergy directors, officers, employees and temporary workers and outlines a zero-tolerance approach for all forms of modern slavery, including forced labour and child labour.

‍b. Vendor Code of Conduct
‍Metergy also finalized a Vendor Code of Conduct. This document clearly communicates o expectations for ethical business conduct, labour practices, and respect for human rights among all suppliers and third-party service providers.

‍c. Risk Assessment QuestionnaireTo enhance visibility into our supply chain and assess the level of modern slavery risk in ouroperations Metergy launched its first Modern Slavery Questionnaire in 2024. This questionnairewas distributed to select, existing vendors based on geographic and sector-based riskassessments.

The questionnaire covers areas such as:

• Labour recruitment practices;
• Use of subcontractors;
• Policies and procedures related to modern slavery;
• Training and grievance mechanisms;.
• Transparency and audit readiness.

Responses to the questionnaire are being used to inform risk profiling and guide future engagement, audits, and capacity-building efforts with vendors.

Our Business Activities

Metergy is a market-leading provider of turnkey submetering solutions for developers and propertymanagers. Services include: a) submeter supply, installation, commissioning, reading and reverification; b)resident billing and collections; and c) utility energy solutions.

ASSESSING MODERN SLAVERY RISK

Our approach to addressing forced labour and child labour is designed to be commensurate with the risks we face, which vary based on several factors, including jurisdiction, industry and sector.

MODERN SLAVERY RISK PROFILE

1. Third-Party Vendors

Given the nature of our business, third-party suppliers and vendors used across Metergy’s businesses generally fall under the below categories:

• Outsourcers: Where a business activity or professional service is outsourced to another organization.
• Vendor Software Providers: This includes off-the-shelf software, that is hosted in Metergy data centers, including hardware vendors used to facilitate business processes.
• Cloud/Hosted IT Services: Encompasses a range of IT services provided in various formats.
• Professional Services: Includes consulting, legal, human resources, accounting, training, tax, audit, banking and education.
• Suppliers: This includes suppliers and vendors of components and finished goods required for submetering services.
• Contractors: Includes entities that provide installation services relating to submetering equipment such as electricians or plumbers.

Metergy continuously strives to achieve excellence with respect to our contracting practicesbecause we believe that adequately compensated and trained workers, operating in fair workingconditions deliver high-quality products and services. We believe that the risk of modern slaverywithin the majority of our third-party vendors is low. This assessment is based on the regulatedindustries and jurisdictions in which they operate and the skill of the professionals providing suchservices. However, we acknowledge that, to a lesser extent, we may engage with suppliers whomay be considered higher risk in terms of modern slavery. We recognize that each of our suppliershas its own supply chain, and our vendor assessments consider this risk where appropriate andpossible. We currently have limited visibility of the extended supply chains, excluding circumstances where subcontractors or materials require our approval.

2. Employees

Our people drive our success. Metergy has human resources policies, procedures and processesin place designed to protect against human trafficking and modern slavery in Metergy’s employeepopulation. These include:

• employment conditions;
• processes for reporting and resolving employee concerns and grievances;
• non-discriminatory hiring practices;
• employment screening (including work eligibility checks); and
• appropriate workplace behavior.

Through our Positive Work Environment Policy, all employees are responsible for creating ar espectful environment and are required to identify and report workplace discrimination, violence and harassment as it occurs. In addition, Metergy’s Human Rights and Anti-Modern Slavery Policyoutlines the rights and responsibilities of all employees and reinforces our zero-tolerance stancetoward modern slavery in any form within our operations.

Based on the above, we consider that there is a low risk of modern slavery within employee population of Metergy.

MANAGEMENT OF MODERN SLAVERY RISKS

1. Governance

We recognize that strong governance is essential to sustainable business operations, and we aimto conduct our business according to the highest ethical and legal standards. Our approach toaddressing modern slavery is designed to be commensurate with the risks we face, which varybased on several factors, including jurisdiction, industry and sector. Key supporting policies and guidelines (together, the “Policy Framework”) include, but are not limited to:

HUMAN RIGHTS AND ANTI-MODERN SLAVERY POLICY
‍This policy aims to codify our approach to minimizing the risk of human rights violations and modern slavery within our business and supply chain. The policy is intended not only to ensure compliance with legal obligations, but also to promote a culture of respect, transparency, and continuous improvement in the protection of human rights.

‍CODE OF BUSINESS CONDUCT AND ETHICS
‍Metergy’s Code outlines our commitment to conducting business in an ethical and responsible manner, including by carrying out our activities in a manner that respects and supports the protection of human rights.

‍WHISTLEBLOWER POLICY
‍Metergy is committed to conducting business with honesty and integrity and employees are expected to maintain high standards. This Policy clearly sets out the expectations of reporting and responsibilities, and outlines whistleblowing procedures addressing how to raise a concern, confidentiality, as well as remediation, external disclosures and our zero tolerance for retaliation or malicious acts.

‍VENDOR CODE OF CONDUCT
‍In connection with any vendor engagement, employees are required to comply with Metergy’s policies and procedures, including those in relation to anti-modern slavery. Our Vendor Code ofConduct sets out our expectations of vendors that provide goods or services to Metergy.

‍POSITIVE WORK ENVIRONMENT POLICY
‍This Policy outlines our commitment to providing a workplace free of discrimination, violence and harassment and summarizes the responsibilities of employees to understand: (i) what constitutes workplace discrimination, violence and harassment; (ii) their obligations to maintain an environment where these behaviors are not tolerated; and (iii) how to report incidents following proper procedures.

‍ANTI-BRIBERY AND CORRUPTION POLICY
‍This policy is designed to prevent payment of bribes or facilitation payments in furtherance of business (including bribes that may contribute to modern slavery).

Preventing the onboarding of those involved in financial crime, such as bribery and facilitation payments, identifying suspicious or criminal activity and making reports to the relevant authorities not only supports the fight against bribery and corruption, but also the fight against modern slavery by association.

Our Policy Framework is reviewed periodically and updated as necessary.

2. Training

To ensure ongoing awareness and compliance, all employees are required to review and attest to the Positive Work Environment Policy, the Code of Business Conduct and Ethics and the HumanRights and Anti-Modern Slavery Policy on an annual basis. This attestation process serves as botha reaffirmation of Metergy’s values and a mechanism for reinforcing a culture of accountability andethical conduct.

In 2024, Metergy achieved full employee participation in the attestation process, with all employee sconfirming their understanding of and commitment to the principles outlined in the aforementionedpolicies.

We continue to raise awareness and commit to providing human rights training to new employees as part of the onboarding process and ensure that they access ongoing training, as necessary.

3. Remediation

We have not found any evidence of modern slavery. Where possible, we will seek to use our leverage to address any issues that we discover.

4. Whistleblowing Hotline

Metergy maintains a reporting hotline (“Hotline”) for employees, vendors, partners and otherinterested parties to anonymously report, among other things, any matters relating to suspectedunethical, illegal, unsafe or other unwanted behaviors. Modern slavery, as well as human traffickingissues are reportable on the Hotline. The Hotline is managed by an independent third party and isaccessible 24/7 by telephone (toll free) or by submitting an anonymous report online. The Hotline is available in multiple languages to mitigate any language barriers and to provide information to those intending to report.

5. Measure of Effectiveness

Metergy acknowledges that modern slavery and human trafficking are possible risks within ouroperations and supply chain. We undertake various steps to address these risks, including reviewing our policies and business practices to ensure they reflect our commitment to:

• implementing and enforcing effective systems and controls designed to reduce the risk of modern slavery in our business and supply chains; and
• transparency through our disclosure obligations.

We monitor and assess the effectiveness of our modern slavery policy framework through:

• regular engagement and feedback from key stakeholders, including through active promotion of our reporting Hotline; and
• operational risk and mitigation plan reporting to the board of directors and senior executives.

Approval

This Report has been approved by Metergy’s board of directors on the 22nd day of May, 2025, in accordance with Section 11(4)(a) of the Act.

Metergy Solutions Inc.

Mark Murski
Director
Date: May 22, 2025
I have the authority to bind Metergy Solutions Inc.