Statement of Commitment

ALLSTREAM Energy Solutions Limited ("ALLSTREAM", "the Company", "we") is committed to conducting its business fairly, honestly, transparently and with integrity. The Company maintains zero tolerance for bribery and corruption in all forms, whether involving public officials, private individuals, employees, business associates or third parties.

The Board of Directors and Top Management are committed to establishing, implementing, maintaining and continually improving an effective Anti-Bribery Management System (ABMS) in accordance with ISO 37001:2025 – Anti-bribery management systems – Requirements with guidance for use.

Prohibition of Bribery

ALLSTREAM prohibits:

• Offering, promising, giving, requesting or accepting bribes, directly or indirectly.
• Facilitation payments, kickbacks and improper commissions.
• Gifts, hospitality, donations or other benefits intended to improperly influence a business decision.
• Any form of retaliation against a person who reports suspected bribery in good faith.

The Company will not obtain or retain any business advantage through bribery. We would rather lose a business opportunity than compromise our integrity.

Compliance and Responsibilities

All employees, management, directors, contractors, consultants, agents, suppliers and business associates acting on behalf of ALLSTREAM are required to comply with this Policy and all applicable anti-bribery laws and regulations.

Employees and relevant business associates shall:

• Act professionally, ethically and transparently.
• Avoid conflicts of interest and disclose them promptly.
• Maintain accurate and complete business and financial records.
• Exercise appropriate due diligence when engaging third parties.
• Report suspected or actual bribery through approved reporting channels.

Reporting and Protection

ALLSTREAM encourages the prompt reporting of suspected bribery, attempted bribery or violations of this Policy. Reports will be handled confidentially and investigated appropriately.

No employee or business associate will suffer retaliation, discrimination or disciplinary action for making a genuine report in good faith.

Compliance Function and Continual Improvement

The Anti-Bribery Compliance Function shall have appropriate authority, independence and access to Top Management to oversee the effectiveness of the ABMS.

ALLSTREAM is committed to providing adequate resources, training and awareness to support implementation of this Policy and to continually improve the effectiveness of the ABMS.

Disciplinary Action

Any employee or business associate found to have engaged in bribery or violated this Policy may be subject to appropriate disciplinary, contractual, legal or other corrective action.

Management Commitment

Top Management shall demonstrate leadership by promoting an ethical culture, ensuring compliance with this Policy and establishing measurable anti-bribery objectives.

This Policy shall be communicated to all relevant personnel and interested parties, made available as appropriate, and reviewed periodically to ensure its continuing suitability and effectiveness.