Rockland Capital, LP (“Rockland”) recognizes that Environmental, Social and Governance (“ESG”) issues impact our business, including our development and investment related activities. This policy sets out Rockland’s approach to integrating the consideration of ESG issues throughout the development, ownership and/or investment cycle. Rockland focuses on investments in power generation projects where we can improve functionality, reliability, resiliency and efficiency of the projects in a cost-effective manner.

ENVIRONMENTAL POLICY

Rockland is committed to protecting the quality of the environment as it creates value for its investors. Rockland demonstrates this commitment through our business-operations, which include:

• Developing, constructing, acquiring and operating facilities in a manner that meets all applicable federal, state and local environmental regulatory standards
• Carefully monitoring our power generation operations and promptly taking appropriate steps to correct any non-compliance and mitigate any resulting adverse environmental impacts
• Making sure that our operations and maintenance contractors (“O&M Contractors”) are properly training and educating employees and plant staff on the potential environmental impacts associated with plant operations and the procedures for mitigating negative impacts in accordance with all applicable federal, state and local environmental regulatory standards
• Evaluating and monitoring performance by periodically conducting self-assessments and third party audits of our power plant operations
• Continually seeking to optimize projects and operations
• Modifying and customizing our projects to reflect local and regional issues

HEALTH AND SAFETY POLICY

Rockland is committed to the health and safety of its employees, contractors and neighbors. We strive to operate industry-leading facilities with respect to the protection of human health and safety, minimize risks to human health and maintain a safe environment in and around our facilities and workplaces. This is a core competency supported by Rockland’s leadership at all levels, and is the collective responsibility of all Rockland employees. This commitment is critical in the selection of our contractors and other service providers, all of whom must share these principles and values Rockland advocates for the health and safety of our employees and onsite service providers by: 

• Requiring contractors and employees to be accountable for understanding and incorporating  industry accepted health and safety practices in their daily work
• Requiring O&M Contractors to implement health and safety procedures at each facility
• Meeting or exceeding all applicable regulatory agency health, safety and reporting requirements,  including Occupational Safety and Health Administration (“OSHA”) and other applicable agency  requirements 
• Fostering an open dialog on health and safety issues with employees and encouraging their  ongoing involvement in a process of continuous improvement of health and safety practices 
• Ensuring that our O&M Contractors prioritizing health and safety in the operating practices and  procedures of our facilities 
• Interacting with our facilities’ host communities and local emergency services providers • Evaluating O&M Contractors’ safety performance track records  
• Engaging third-party environmental, health and safety experts to audit and assist in improving site  health and safety matters

SOCIAL RESPONSIBILITY & COMMUNITY INVOLVEMENT POLICY 

Rockland strives to be a good neighbor and partner in the communities where it operates by minimizing  environmental impact, stimulating local economies through tax revenue, creating job and training  opportunities, and hiring local talent. Our efforts include: 

• Ensuring that our O&M Contractors are implementing project-level physical security of our power  generation projects 
• Implementing cybersecurity protections to ensure the integrity and reliability of our power  generation projects 
• Creating and providing jobs, along with supporting revenues for schools and local governments • Coordinating with local stakeholders for beneficial support of the host community 

HUMAN RIGHTS POLICY

Rockland is committed to being a responsible corporate citizen. We conduct our business operations in ways that seek to respect, protect and promote human rights.  

GOVERNANCE POLICY 

Rockland clearly defines our commitment to corporate governance and a culture of compliance in our policies and procedures, and we require employees to conduct business with honesty, integrity and fairness. Rockland’s governance is primarily established through the policies contained in our Compliance  Manual, investment policies and procedures, NERC and FERC standards, Employee Handbook, and related initiatives. Our legal, compliance and human resources professionals will not only enforce internal policies and procedures to ensure compliance with applicable laws and regulations, but also identify and mitigate potential conflicts of interest and other reputational risks. Additional governance principles include: 

• Providing managers with the authority, expertise and resources required to make strategic and  operational decisions with respect to the employees, contractors and other third-party service  providers they oversee 
• Working closely with O&M Contractors, to ensure awareness of potential risks and to promptly  address such risks 
• Encouraging and supporting open and regular communications from asset managers to ensure  senior management is aware of plant operational issues 
• Recognizing and appreciating that our success over time is a testament to the quality of our  employees 
• Maintaining an open door policy within our Management, HR, and compliance professionals,  welcoming all employees to openly raise any concerns or issues 
• Diligently reviewing and considering ESG issues with respect to potential asset acquisitions to  ensure acquisition and operations plans address any gaps identified (see Investment and  Development Activities below) 
• In general, Rockland seeks control investments and, in so doing, ensures its portfolio companies are governed in a manner consistent with Rockland’s standards. 

INVESTMENT AND DEVELOPMENT ACTIVITIES   

We are committed to ensuring that our business activities are conducted in a manner that reflects intentional and responsible ESG management.   To accomplish our goal, we examine ESG factors when analyzing, selecting and managing assets where we believe our experience will enable us to operate consistent with industry best practices, reduce risks and impacts to the environment and local communities, and improve the safety and efficiency of operations.  ESG factors are among many factors considered throughout a fund’s investment and operational decision making processes. Our investment professionals and subject matter experts conduct extensive diligence on project sites and target assets, including diligence of ESG factors.   

ESG POLICY REVIEW   

The Chief Compliance Officer will conduct or cause to be conducted periodic reviews of this ESG Policy to ensure the policies set forth herein address then-applicable risks, environmental, legal and regulatory developments, and other relevant factors.  Please contact [email protected] with any questions or concerns regarding this ESG  Policy.