Code of Conduct and Ethics

At Hyperion Renewables Corporate Group (“Hyperion”, “Group” or collectively referred to as“Company”), all employees and members of the management bodies (collectively referred to asEmployees”) must comply with the law and act ethically and diligently in all due respects.

This Code of Conduct and Ethics, (the “Code of Conduct”), prepared as set forth under article 7.º ofDecree-Law no. 109-E/2021, of 9 December – General Regime For The Prevention Of Corruption(“Regime Geral de Prevenção da Corrupção – RGPC”), reflects the Group’s commitment to theprinciples of business ethics and transparency in all areas of activity, especially in what regards therenewable energy sector, and establishes a set of principles and guidelines of conduct designed toensure ethical and responsible behavior of all Employees.

Compliance with the provisions established in this Code of Conduct is a key element to working forthe Company and the principles and guidelines contained in this Code of Conduct apply to allEmployees.

The Code of Conduct shall be reviewed every 3 (three) years, or whenever there is a change in theorganization’s duties or organizational or corporate structure that justifies a review or wheneverconsidered relevant by the Group.

The Company shall ensure that all Employees have access to the Code of Conduct and confirmadherence to it, initially and upon every revision made.

All Employees must

• Comply with all applicable Portuguese laws and regulations, including any applicable EU directive or regulation or any other applicable Internation rules;
• Follow all internal policies and procedures as approved by the Group;
• Ensure adherence to international standards and best practices in the renewable energy sector.

The Company must take the necessary steps and adopt all measures required to eliminate all kinds orforms of forced or compulsory labor. All employment is voluntary, and its Employees are free to ceasetheir employment contract or to leave their job, subject to reasonable notice, as stipulated in eachemployment contract.

The Company shall expressly reject the use of child labor within its organization, shall respect theminimum hiring age limits in accordance with applicable law, and shall have adequate and reliablemechanisms in place to verify the age of its Employees.

The Company shall respect the freedom of union association and the workers’ right to collectivebargaining, subject to the law applicable in each case.

The Company must reject all discriminatory practices in employment and occupational matters andtreat its Employees fairly and with dignity and respect. The Company will not make any distinction byreason of race, color, religion, gender, age, physical fitness, national origin, sexual orientation, politicalopinion, union membership, medical testing, or marital status.

The Company shall pay its Employees in accordance with the provisions of applicable wage laws, aswell as guarantee the right of its Employees to rest and shall comply with the applicable law in forcefor each of the sectors in which it operates regarding working hours.

The Company shall engage in commercial relationships according to principles of business ethics and transparent management, acting with due diligence to prevent and detect corruption.

The Company (and its Employees) shall comply in all material respects with Anti-Money Laundering and Anti-Bribery and Corruption laws, in particular with regard to Law no. 83/2017 of 18 August (and any legislation that may replace or complement it). The Company (and its Employees) shall also comply with the Hyperion ABC Policy attached to this Code of Conduct as Schedule I.

The Company (and its Employees) shall not accept, offer, or deliver to public officials, or any individual or legal person of government administrations, entity, public or private, political party or candidate for public office, commissions, gifts, or remuneration to obtain or maintain, illegally, business or other advantages.

The Company (and its Employees) shall compete and do business based only on the quality and competence of its products and services. The exchange of business entertainment must not be used to gain an unfair competitive advantage.

The Company (and its Employees) must avoid any activity that creates a potential conflict of interest where of the objectivity or loyalty of Hyperion can be questioned. Any person affected by a conflict of interest must refuse to participate in any applicable negotiation and report it to its Manager.

The Company shall ensure that all relevant suppliers who enter a business relationship of significant size, as defined in the 3rd Party DD Procedure, with the Group review and accept this Code of Conduct by signing the Code of Conduct and Ethics for Suppliers attached to this Code as Schedule II.

The information owned by Hyperion and disclosed to Employees shall, as a general rule, be deemed to be private and confidential.

Any essential or disclosed information obtained during the business relationship with Hyperion shall not be used as a basis for any personal business.

The Company will take appropriate measures to safeguard and maintain the confidential and private information of its business partners and will only use such information if duly authorized by a contractual agreement. In the event of subcontracting, confidential information may only be shared upon consent.

The Group shall ensure the protection of their Employees, avoiding their overexposure to chemical,bio-logical or physical hazards or to tasks demanding excessive physical effort at the workplace.

The Group shall identify and evaluate potential emergency situations at the workplace and shall minimize the possible impact thereof by implementing emergency response plans and procedures.

The Group shall provide its staff with the appropriate training and resources in order to carry out the work.

The Group shall identify dangerous substances, and chemicals products in order to ensure their safe handling, movement, storage, recycling, use and destruction. All applicable laws and regulations related to dangerous substances, chemicals and materials will be strictly followed. The Group shall comply with material restrictions and product safety requirements.

The Group must strictly comply with all environmental obligations applicable thereto and have an effective environmental policy or sufficient equivalent measures based on the products and services supplied.

The Group shall commit to reducing the environmental footprint and promoting sustainability,implementing best practices for environmental protection and conservation.

The Group shall identify and manage those substances and other materials that present a hazard when released into the environment in order to ensure that they are handled, transported, stored, recycled or reused, and disposed of safely and in compliance with applicable regulations. All waste materials,wastewater or emissions having the potential to adversely affect the environment shall be appropriately managed, controlled and treated.

The Group shall ensure that it obtains, keeps updated and follows the reporting guidelines of all necessary environmental records and licenses, so that these are legally valid at any time.

Furthermore, the Group shall strive to engage with local communities and stakeholders in a respectful and constructive manner, contributing positively to the socio-economic development of the regions where the Group operates and ensuring that the operations do not negatively impact local communities.

The Group has reviewed and adopted requirements imposed on Controllers and Processors by the General Data Protection Regulation 2016/679 (“GDPR”), if and to the extent applicable to Personal Data of Customer/Controllers that is processed under business activity.

The Company shall ensure that all measures are taken to secure and protect data from unauthorized access or breaches and destroy any confidential information and documentation in paper form as soon as it is not relevant.