Our Commitment

Sustainability is not incidental to what we do; it is central to it. The systems we engineer directly enable our clients to reduce their environmental footprint, and we hold ourselves to the same standard internally. This Sustainability and ESG Policy formalizes Divcon’s commitments across three pillars: Environmental, Social, and Governance. It establishes the accountability structures through which we measure and record progress.

This policy applies to all Divcon employees, officers, and subcontractors engaged on company business, across all office locations and project sites. Subcontractors performing work on behalf of Divcon are required to comply with the applicable provisions of this policy and our Subcontractor Code of Conduct as a condition of their agreement. This policy is reviewed annually by the Executive Leadership Team and updated as our business, regulatory landscape, and stakeholder expectations evolve.

ESG At a Glance

Environmental

• Assess and track our operational carbon footprint across offices, fleet, and supply chain

• Embed sustainable design principles into client engagements where applicable

• Manage waste responsibly, track and record recycling efforts, and source from environmentally conscious suppliers

• Maintain internal records of our emissions and energy data to support continuous improvement

Social

• Build and sustain a diverse, equitable, and inclusive workforce

• Invest in employee development, safety, and well-being

• Uphold fair labor standards for our people and throughout our supply chain

• Contribute positively to the communities where our employees live and work

Governance

• Operate with integrity, transparency, and accountability at every level

• Maintain robust data privacy and cybersecurity practices

• Enforce zero tolerance for bribery, corruption, and conflicts of interest

• Track and record ESG performance internally and use findings to drive continuous improvement

1. Environmental Stewardship

Divcon’s core business places us in a unique position within the sustainability ecosystem. The solutions we engineer routinely generate measurable reductions in energy consumption, peak demand, and carbon output for our clients. We are committed to applying those same principles to our own operations.

1.1 Greenhouse Gas Emissions

Divcon assesses and tracks its greenhouse gas (GHG) emissions through an annual third-party carbon footprint assessment. We are committed to ongoing internal accountability for our emissions profile and to continuously seeking reductions in our operational footprint.

• Conduct an annual GHG assessment through our third-party carbon accounting platform and retain results for internal review.

• Continuously seek opportunities to reduce Scope 1 and Scope 2 emissions across operations, fleet, and facilities.

• Reduce fleet emissions over time through vehicle electrification or hybridization where operationally feasible, prioritizing replacements as existing fleet ages out.

• Encourage remote and hybrid work arrangements for roles where in-person presence is not operationally required.

• Work toward expanding our emissions tracking to include material Scope 3 sources such as employee commuting, business travel, and supply chain impacts.

1.2 Energy Use in Our Facilities

Divcon offices and facilities are managed in a manner consistent with the efficiency standards we advocate for our clients.

• Periodically assess energy use in company-occupied facilities and implement cost-effective efficiency measures.

• Prioritize ENERGY STAR-certified or equivalent equipment in major procurement decisions for office technology and facilities.

• Track and record energy consumption for company-operated facilities on an ongoing basis.

1.3 Waste Reduction and Recycling

Divcon is continuously focused on reducing waste across our operations. We track and record our recycling efforts on an ongoing basis to ensure we are improving and remaining vigilant over time.

• Operate as a primarily paperless office through digital project management, e-signatures, and cloud document storage.

• Recycle decommissioned electronics and equipment through certified e-waste handlers; maintain records of all such disposals.

• Encourage the elimination of single-use plastics from company-stocked supplies across all office locations.

• Manage project site waste in compliance with applicable regulations and, where possible, divert materials from landfill through reuse or certified recycling.

• Track and internally record recycling and waste diversion data to identify trends and opportunities for improvement.

1.4 Sustainable Client Engagements

Our work on behalf of clients creates an opportunity to multiply our environmental impact beyond our own operations. Divcon raises sustainability-oriented design options in client engagements.

• Where within project scope, explore sustainable design options that support client energy efficiency objectives.

• Stay current with evolving building decarbonization standards and incorporate them into project guidance.

1.5 Sustainability Education and Engagement

Divcon participates in external sustainability engagements and is actively focused on building internal sustainability literacy across our team. We believe that an informed workforce is better positioned to identify opportunities and deliver value for environmentally conscious clients.

• Participate in industry forums, working groups, and external sustainability initiatives relevant to our sector.

• Pursue internal programs and resources that expand employee understanding of sustainability topics, energy efficiency, and our clients’ decarbonization goals.

• Encourage employees to engage with and share developments in the sustainability and clean energy space.

1.6 Supply Chain and Procurement

Environmental responsibility is a meaningful factor in how Divcon evaluates vendors, suppliers, subcontractors, and procurement decisions.

• Consider environmental certifications (such as ISO 14001) and documented environmental management practices as part of supplier evaluation.

• Incorporate sustainability considerations into vendor qualification and renewal reviews as part of standard due diligence.

• Request environmental data and certifications from major materials and equipment suppliers during onboarding where applicable.

2. Social Responsibility

Divcon’s ability to deliver for clients depends on attracting, retaining, and developing talented people, and on maintaining the trust of the communities we operate in. We take seriously our responsibility to our employees, our supply chain partners, and the public.

2.1 Diversity, Equity, and Inclusion

Divcon is committed to building and maintaining a diverse, equitable, and inclusive workplace. We believe that diversity of background, experience, and perspective makes us a stronger organization and better serves our clients. All employment decisions are made on the basis of merit, qualifications, and business need, free from bias or discrimination on any protected basis.

• Actively work to mitigate bias in hiring, promotion, and compensation decisions.

• Maintain a zero-tolerance policy for discrimination, harassment, or retaliation on any protected basis, as set out in our Employee Handbook.

• We are committed to fair and equitable compensation for all employees.

• Foster an inclusive workplace culture where all employees feel respected, valued, and able to contribute.

2.2 Workplace Health and Safety

Divcon takes workplace health and safety seriously. We comply with all applicable OSHA standards and regulations across our office and field operations, and we expect equivalent commitment from our subcontractors working on Divcon projects.

• Conduct safety briefings for all personnel working on active construction or industrial sites.

• Investigate workplace incidents to identify and address root causes; track and report recordable incidents internally.

• Maintain and communicate appropriate safety protocols for field operations to all personnel, including subcontractors.

2.3 Employee Development

In a specialized technical field, continuous learning is both a competitive imperative and an obligation to our people. Divcon supports employee growth through access to training and professional development resources.

• Support employees in pursuing industry certifications and continuing education relevant to their roles.

• Conduct regular performance conversations on a rolling basis, with ongoing goal-setting and constructive feedback.

2.4 Labor and Human Rights

Divcon is committed to fair labor practices and respect for human rights across our operations and supply chain.

• Comply with all applicable wage, hour, and labor laws in every jurisdiction where Divcon operates.

• Require subcontractors and suppliers to certify compliance with applicable labor laws, including prohibitions on forced labor and child labor, as a condition of contract.

• Address labor standards compliance requirements in subcontractor agreements through our Subcontractor Code of Conduct.

• Maintain reporting channels through which employees and supply chain workers can raise concerns without fear of retaliation, as described in our Employee Handbook.

2.5 Community Engagement

Divcon encourages and supports volunteerism and community involvement among our employees. We believe that engaged employees who give back to their communities reflect the values at the core of our organization.

• Encourage participation in community initiatives, particularly those related to STEM education, workforce development in skilled trades, and energy access programs.

• Participate in local industry and professional organizations to support the development of a skilled regional workforce.

3. Governance and Ethics

Strong governance is the framework within which Divcon’s environmental and social commitments are made credible. We operate in sectors where integrity, reliability, and regulatory compliance are foundational expectations. We hold our leadership, employees, and contractors to high standards of ethical conduct and accountability.

3.1 Ethical Conduct

Divcon’s conduct standards, as reflected in our Employee Handbook and Subcontractor Code of Conduct, govern the behavior of all personnel and subcontractors acting on the company’s behalf.

• All employees are required to read and act in accordance with applicable conduct standards as set out in the Employee Handbook.

• Conduct standards address conflicts of interest, gifts and entertainment, fair dealing, confidentiality, and data privacy.

• Employees may raise concerns about potential violations through the reporting channels described in the Employee Handbook; retaliation against good-faith reporting is prohibited.

• Subcontractors performing work on behalf of Divcon are required to comply with the Subcontractor Code of Conduct as a condition of their agreement.

• Periodic ethics and compliance reminders are communicated to employees and subcontractors as warranted.

3.2 Anti-Corruption and Anti-Bribery

Divcon operates across a range of industries and client types. Our commitment to clean business is unequivocal.

• Zero tolerance for bribery, kickbacks, facilitation payments, or any other corrupt practice.

• Maintain a gifts and entertainment policy with appropriate approval processes; log gifts and hospitality offered or received above de minimis levels.

• Divcon complies with all applicable sanctions laws and regulations governing its third-party relationships.

• Include anti-corruption expectations in subcontractor agreements where appropriate.

3.3 Data Privacy and Cybersecurity

Divcon handles sensitive client facility data and employee personal information. The security of that data is both a professional and legal obligation.

• Comply with applicable federal and state data privacy laws in the collection, use, storage, and disposal of personal data.

• Maintain information security practices governing access controls, encryption, and acceptable use.

• Maintain a Business Continuity Plan that addresses cybersecurity disruption scenarios; review and update the plan regularly.

• Conduct regular security awareness training for all employees.

3.4 Financial Controls and Legal Compliance

• Maintain internal financial controls commensurate with company size and complexity, reviewed by management regularly.

• Ensure all material contracts and client agreements receive review by qualified legal counsel.

• Maintain insurance coverage appropriate for the scope and risk profile of Divcon’s operations, including general liability, professional liability (errors and omissions), cyber liability, and workers’ compensation.

• Comply with all applicable federal, state, and local regulations governing our industry, including contractor licensing, permitting, and certification requirements.

3.5 ESG Tracking and Accountability

Divcon’s ESG commitments are supported by internal tracking and recordkeeping that allow us to assess progress and drive continuous improvement over time.

• Assess and track ESG performance metrics internally on an annual basis across each pillar.

• ESG program ownership sits with the General Counsel & Chief Administrative Officer, who is responsible for coordinating data collection, recordkeeping, and internal reporting.

• This policy is reviewed annually by the Executive Leadership Team and updated in response to material changes in business scope, applicable regulations, or stakeholder expectations.

• Align our tracking and recordkeeping framework over time with recognized ESG standards as our data maturity grows.

4. Implementation and Oversight

Responsibility for implementing this policy sits with Divcon’s Executive Leadership Team, with day-to-day ESG program ownership designated to the General Counsel & Chief Administrative Officer. Each functional area is accountable for ESG-relevant practices within its domain. Progress is reviewed by the Executive Leadership Team on an annual basis, with material gaps escalated as appropriate.

All employees are required to comply with this policy and to raise concerns through available reporting channels as described in the Employee Handbook. Subcontractors engaged on Divcon projects are required to comply with applicable provisions as a condition of their agreement, consistent with the Subcontractor Code of Conduct.

This policy does not create contractual rights or obligations beyond those set forth in applicable employment agreements and governing contracts. Divcon reserves the right to amend this policy at any time. Questions or concerns regarding this policy should be directed to Divcon’s legal department at notices@divconcontrols.com.