< Previous9 ESG- Related Policies Analyst Corner Health, Safety and Environment Policy + Compliance with Anti-Corruption Laws + Human Rights Policy + Corporate Security Policy + + Code of Business Conduct and Ethics Whistleblower Policy + PolicyDescription Code of Business Conduct and Ethics•Outlines Gran Tierra’s commitment to the highest standard of ethical business conduct •Applies to all our directors, officers, employees and every other person or entity representing Gran Tierra Compliance with Anti-Corruption Laws•Intended to ensure that Gran Tierra does not seek or receive any improper advantage in the course of its business dealings and to ensure that all payments and expenses are properly recorded in our books and records •Applies to all Gran Tierra entities and all employees of each Gran Tierra entity conducting business in any location •Applies to all agents, suppliers, consultants and other providers of goods and/or services Corporate Security Policy•Outlines Gran Tierra’s commitment to the protection of our personnel, assets, and reputation •Signed by the President and CEO Health, Safety and Environment Policy•Outlines Gran Tierra’s commitment to the efficient and responsible development of hydrocarbon resources to the mutual benefit of the people of the countries where we operate and the employees and investors of Gran Tierra •Commits to ensuring that operations and activities are protective of human health and the environment and to set annual goals for Health, Safety and Environment performance which will be overseen by Gran Tierra’s senior management and the Board •Signed by the President and CEO Human Rights Policy•Outlines Gran Tierra’s commitment to the respect and promotion of all human rights internationally recognized •Developed with the full commitment to respect the internationally recognized human rights incorporated in the International Bill of Human Rights and the International Labor Organization Conventions (ILO), including the fundamental rights principles established in the ILO Declaration on Fundamental Principles and Rights at Work •Developed with the commitment to apply relevant international standards including: the United Nations (UN) Guiding Principles on Business and Human Rights, the UN Voluntary Principles for Security and Human Rights, the OECD Guidelines for Multinational Companies, the OECD Due Diligence Guidance for Responsible Business Conduct, the UN 2030 Agenda for Sustainable Development and Gran Tierra’s Code of Business Conduct and Ethics •Signed by the President and CEO Whistleblower Policy•Outlines the company’s commitment to providing a workplace conducive to open discussion of our business practices and to complying with the laws and regulations to which we are subject •Includes a hotline to anonymously report complaints and a policy of non-retaliation Gran Tierra is committed to conducting its business honestly, fairly and safely and has outlined these principles in a comprehensive, binding set of corporate policies. The Company carries out regular training to inform employees and contractors about all relevant policies and ensure compliance. All Policies are approved by the Board of Directors, with the exception of the Human Rights Policy which is approved at the CEO level. Table 2: ESG-Related PoliciesBoard Diversity 10 Gran Tierra Energy believes in the importance of diversity at all levels throughout the company. In addition to the traditional concepts of diversity (e.g., gender, culture, and geographic region), we believe it is important for the Board to achieve a diversity of knowledge, experience and capabilities that support Gran Tierra’s strategic direction. Currently, Gran Tierra does not have a formal policy concerning the diversity of director nominees. However, when considering director candidates, the Board seeks individuals with backgrounds and qualities that, when combined with those of incumbent directors, provide a blend of skills and experience to further enhance the Board’s effectiveness. As part of the annual self-evaluation, the Board assesses whether the directors, both individually and collectively, provide the integrity, experience, judgment, commitment, skills, and expertise appropriate for our company. Gran Tierra recognizes the benefits of increasing the diversity of our Board of Directors. In February 2021, the Board updated its Corporate Governance Guidelines to state that as part of the search process for each new director, the Nominating and Corporate Governance Committee will actively seek out women and minority candidates to include in the pool from which Board nominees are chosen. Female directors now represent 22% of our Board of Directors, and 25% of independent directors. It is important for Gran Tierra to maintain positive relationships with the governments of the countries in which we operate, while maintaining the highest levels of transparency and business ethics. Failure to comply with existing anti-corruption, anti-bribery and payments transparency laws and initiatives could lead to fines, increased compliance costs, and damage our reputation. We do not have any proved or probable reserves in countries that fall within the 20 lowest rankings in Transparency International’s Corruption Perception Index. Gran Tierra is committed to conducting business honestly, fairly, and safely, and has outlined these principles in a comprehensive set of Corporate Policies which are binding for all employees. Gran Tierra’s approach to upholding the highest standards of ethical business conduct is guided by our Code of Business Conduct and Ethics, our Compliance with Anti-Corruption Laws Policy, and our Whistleblower Policy. Refer to the ESG-related Policies section for an overview of the key commitments and scope of these three policies. The Vice President, Corporate Services has ultimate accountability for business ethics, anti-corruption and transparency. Business Ethics & Transparency Importance to Gran Tierra and Approach Corporate Governance Guidelines + Analyst Corner Compliance with Anti-Corruption Laws + SASB EM-EP-510a.2 + SASB EM-EP-510a.1 + + Code of Business Conduct and Ethics Whistleblower Policy +Gran Tierra Energy is committed to providing a workplace conducive to open discussion of our business practices and is committed to complying with the laws and regulations to which we are subject. All company personnel have a role in ensuring that any violations, imminent violations, or suspected violations are brought to our attention immediately so that they can be appropriately addressed. Personnel are encouraged to speak to their supervisor or manager about any conduct that may constitute a violation of Corporate Policies. Employees can also report suspected violations to the company’s Compliance Officer who is responsible for receiving, reviewing, and investigating (under the direction and oversight of the Audit Committee) complaints. We prohibit retaliation against any personnel who report or participate in an investigation of a possible violation of the Code of Business Conduct and Ethics, other Corporate Policies, or the law. Gran Tierra also carries out regular training to inform employees and contractors about all relevant policies and ensure compliance. We have obtained certification of the Code of Business Conduct and Ethics by 100% of our employees. New Board directors attend an orientation session where they review the company’s compliance programs and the Code of Business Conduct and Ethics. Gran Tierra Energy has publicly disclosed payments to governments since 2016 as required by the Canadian Federal Government’s Extractive Sector Transparency Measures Act (ESTMA). Our annual ESTMA filings can be found on our website. For more details on Corporate Governance at Gran Tierra, see the Notice of 2022 Annual Meeting of Stockholders and Proxy Statement 11 Highest Standards of Ethical Business Conduct Transparency on Payments to Governments Analyst Corner Extractive Sector Transparency Measures Act 2020 Report + SASB EM-EP-510a.2 + Notice of 2021 Annual Meeting of Stockholders and Proxy Statement + Business Ethics & Transparency + Code of Business Conduct and EthicsEnvironment 12 Gran Tierra Energy’s material environmental factors include: •Climate Change and Greenhouse Gas Emissions •Air Quality •Water Management •Biodiversity Impacts Protecting the environment is a key component of our development plans and operations. We attach great importance to minimizing our impact on the environment and voluntarily support environmental education, conservation, and prevention programs. 2021 further established Gran Tierra as an industry standard bearer for its net positive effect on Colombia’s environment. The Vice President, HSE & CSR has the highest level of accountability for environmental factors at Gran Tierra, including climate change and GHG emissions, air quality, water management and biodiversity. This position reports directly to the CEO. Gran Tierra has two key environmental objectives: leverage our resources to meaningfully address some of the most pressing environmental challenges facing South America, while also minimizing the environmental impacts of our own operations. Gran Tierra’s Health, Safety and Environment (HSE) Policy guides all of our environmental efforts, including with respect to climate change and GHG emissions, air quality, water management and biodiversity. Gran Tierra strategically aligns regulatory commitments and voluntary initiatives with the Colombian government’s environmental protection and climate adaptation strategy to help mitigate our environmental impacts and maximize our contribution to protecting the country’s air, land, and water. Gran Tierra has implemented environmental management policies and procedures that are managed through an Environmental Management System (EMS) that is ISO 14001:2015 certified. Our EMS was recertified in 2021 after successfully completing a virtual audit and a physical recertification. We have defined seven environmental objectives through our EMS which relate to our material environmental factors. We also conduct environmental impact assessments prior to entering any new areas. For more detail on the EMS, Gran Tierra’s significant environmental aspects and our approach to conducting environmental impact assessments, see the Biodiversity Impacts section. Analyst Corner Health, Safety and Environment (HSE) Policy + Figure 1: Gran Tierra Energy’s 6 Environmental Objectives Gran Tierra’s Environmental Objectives The company has defined six environmental objectives aligned with its commitment to the Environmental Management System (EMS), the applicable legal requirements and the significant environmental aspects. Contribute to the conservation and efficient use of water. Reduce the amount of solid waste at GTE facilities and ensure it´s proper disposal. Monitor and reduce greenhouse gas emissions in all of GTE’s operations. 123 Prevent, reduce and immediately attend any environmental incident and spills resulting from GTE´s activities. Achieve environmental compliance and guarantee continuity within all GTE projects. Develop projects that will benefit the region with a focus on ecosystem restoration, and conservation. 456 TCFD Governance b +13 Analyst Corner Health, Safety and Environment (HSE) Policy + Climate Change and Greenhouse Gas Emissions Importance to Gran Tierra and Approach For detail on our governance of climate change factors, see the ESG Oversight section. Our Approach to ESG includes consideration of climate change factors. The ESG Materiality Assessment that we conducted (see theESG Materiality Assessment section for more detail) included the consideration of GHG emissions, climate change transition and climate change physical risks. We assessed the potential impact and likelihood of these risks over the short (0 to 1 years), medium (1 to 3 years) and long term (greater than 3 years). We identified GHG emissions and the climate change transition as important factors for Gran Tierra over the short, medium and long term. The transition to a lower carbon economy has the potential to reduce demand for hydrocarbons and impact our regulatory environment. GHG emissions regulations are being implemented or considered globally, which could increase operating costs and require additional capital expenditures. Companies that are not focused on reducing GHG emissions could face increased costs and reputational risk. Further, in recent years the investment community has increased their consideration of climate change factors when making investment decisions. To the extent financial markets view climate change and GHG emissions as a financial risk, this could negatively impact our cost of or access to capital. Currently, none of our Scope 1 GHG emissions are covered under emissions-limiting regulations and existing GHG emissions legislation has not resulted in material compliance costs for our business. We are actively and regularly monitoring evolving regulatory frameworks and proposed regulations in the jurisdictions where we operate to ensure compliance and ability to protect value. We are committed to tracking GHG emissions and to take steps to reduce them where we can do so in a cost- effective manner. We identified climate change physical risks as an important factor for Gran Tierra over the medium and long term. Over the medium or long term, the physical impacts of climate change could impact the markets we serve or the areas where our assets reside, resulting in increased expenses and impacts to operations. As a responsible energy producer, our goal is to create the most value with the least environmental impact possible. We do this by maintaining operational integrity across all our infrastructure, designing our processes to maximize efficiency and meet rigorous international standards. Finding ways to reduce our GHG emissions remains a priority for the company. Gran Tierra’s emissions reduction strategy focuses on three key areas: 1.Consistent, transparent and expanded reporting 2.Gas-to-power projects 3.Nature-based solutions SASB EM-EP-110a.1 + SASB EM-EP-530a.1 + TCFD Strategy b + TCFD Strategy a +14 Gas-to-Power Projects FieldGas-to-Power (kWh) Gas Used (SCF) Savings (USD) Costayaco 2 68,781,969468,745,820$1,272,466 Moqueta 3 148,8271,479,600$18,864 Acordionero469,731,909932,986,000$17,467,843 Mono Araña 5 978,5598,505,848$50,885 Vonu4,142,46530,743,300$405,474 Los Angeles218,3964,293,200$393,550 Cohembi1,594,92418,225,670- Analyst Corner SASB EM-EP-110a.3 + Consistent, Transparent and Expanded Reporting As part of our commitment to drive down GHG emissions where feasible, we have contracted external experts to begin in-person measurements of potential fugitive emission sources at our three main producing facilities. An additional understanding of fugitive emissions will allow us to focus reduction efforts where they will have the biggest impact. We are also undertaking real-time tracking and internal reporting approaches to integrate GHG emissions data into ongoing Environmental Information Management systems. Finally, we are aligning our corporate GHG emissions reduction activities with the Government of Colombia’s plan to meet its emissions reduction targets and participate in meetings with Colombia’s Ministry of Mines and Energy on an ongoing basis. We are building an inventory of GHG emissions reduction opportunities in order to assess potential mitigation actions and to prioritize measures to be considered in the coming years. Gran Tierra has taken actions to lower GHG emissions by reducing the flaring of natural gas through major capital investments in voluntary “Gas-to-Power projects”. Instead of flaring excess gas, we convert gas into power at our fields. This reduces our reliance on diesel, reduces flare volumes and the associated GHG emissions, reduces GHG emissions associated with the transportation of diesel and reduces demand on National power grids. Technological advances in compact compressors allow the generation of power from gas at almost any scale, enhancing the applicability of these projects and further allowing us to reduce our GHG emissions. Gran Tierra’s ongoing effort to reduce direct emissions by converting excess gas produced from our wells into an energy source for its operations continues to generate results. The Gas-to-Power projects have significantly reduced gas flaring and the company’s use of electricity from the grid and diesel consumption, as well as resulted in cost savings. Demand on municipal utilities has decreased, fiscal resilience has increased by lowering unit production costs, and we have access to a more stable energy supply, all while reducing flaring and GHG emissions. For example, at the Acordionero field, diesel consumption has decreased by 85%. A priority for 2021 was to implement Gas-to-Power projects at additional fields. All major fields have been fully converted and we are now turning our attention towards generating gas power at our smaller locations, with service now in place at Cohembi and Los Angeles. In 2022, we expected to be able to sell excess power from our Costayaco facilities to supply the local grid. The table below highlights the amount of power generated, gas used for power instead of being flared and the cost savings from Gran Tierra’s Gas-to-Power projects. Climate Change and Greenhouse Gas Emissions Table 3: Gas-to-Power chart TCFD Strategy b +Air EmissionsMetric Tons NOx576.74 SOx14.98 Volatile Organic Compounds (VOCs)31.16 Particulate Matter (PM10)23.11 15 Analyst Corner SASB EM-EP-110a.3 + SASB EM-EP-110a.1 + Nature-Based Solutions Gran Tierra’s efforts to lower emissions through nature-based projects is a top priority and we will continue to work Beyond Compliance, supporting environmental projects focused on reforestation, conservation and carbon sequestration. Examples of such environmental projects include the Costayaco Forestry Centre and the NaturAmazonas program described in the Biodiversity Impacts section. Carbon sequestration describes the processes of capturing and storing atmospheric CO2. Through photosynthesis, forests and vegetation sequester carbon by capturing carbon dioxide from the atmosphere and converting it into organic matter as a fuel source. The NaturAmazonas program will sequester approximately 8.7 million tonnes of CO2 through reforestation and conservation over its lifetime. Understanding Our Air Emissions Performance Exploration and production activities can produce non- GHG air emissions (including hazardous air pollutants, criteria air pollutants and volatile organic compounds) that can impact the environment and communities. Gran Tierra Energy has comprehensive air pollutant measurements in place as outlined by regulatory requirements in Colombia with which we comply. We are in the process of refining our approach to aggregate air pollutant measurements, analyzing the data and identifying opportunities for air emission reductions beyond regulatory requirements. We are pleased to be able to report our air emissions data for the first time in 2021. From 2019 to 2021, we have achieved a 55% reduction in absolute Scope 1 and 2 GHG emissions and a 46% reduction in Scope 1 and 2 GHG emissions intensity in large part due to our Gas-to- Power projects. 11% of our absolute Scope 1 GHG emissions are methane emissions. Gran Tierra continues to focus on GHG emissions reductions, including methane emissions, where possible. 353,227 72,098 75,060 72,942 82,081 103,942 9,854 6,085 6,589 14,801 9,331 11,459 - 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000 201920202021 Metric tons CO ₂ e Scope 1 GHG Emissions Flared HydrocarbonsOther CombustionVented EmissionsFugitive Emissions Climate Change and Greenhouse Gas Emissions Table 4: Air Emissions chart TCFD Strategy b + SASB EM-EP-120a.1 + SASB EM-EP-110a.2 + Figure 2: Scope 1 GHG Emissions Metrics and Targets a + Metrics and Targets b +Biodiversity Impacts 16 Analyst Corner Importance to Gran Tierra and Approach Exploration and production activities can have impacts on biodiversity. Gran Tierra operates in a region with highly biodiverse areas. The Andes - Amazonia corridor is a strategic zone in the Putumayo Department that hosts the greatest diversity of ecosystems in the Colombian Amazon. Significant negative impacts to biodiversity could result in fines, delays in obtaining permits, reputational risk, and opposition from stakeholders to operations. Approximately 7% of Gran Tierra’s proved reserves are in or near sites with protected consideration status of endangered species habitats. Approximately 7.2% of Gran Tierra’s probable reserves are in or near sites with protected consideration status of endangered species habitats. The Putumayo has been significantly impacted by deforestation and biodiversity loss due to coca cultivation. As the largest oil and gas operator in the Putumayo, Gran Tierra is committed to protecting the area’s biodiversity and has adopted a strategy to coordinate our efforts with other organizations to maximize regional impact. We bring a total-life-cycle perspective to our operations, with the goal of leaving a legacy of environmental protection. Our voluntary environmental efforts are often linked with economic development because sustainably protecting sensitive natural resources is also in the interest of local residents and communities. Gran Tierra Energy’s HSE Policy includes commitments to conduct environmental impact assessments, develop and implement environmental management plans, and implement an effective spill prevention program (while quickly and thoroughly cleaning up any spills that do occur). Our environmental management policies and procedures are designed based on the International Finance Corporation (IFC)’s Environmental, Health, and Safety Guidelines for Onshore Oil and Gas Developments. These policies and procedures are managed through an EMS that is ISO 14001:2015 certified. Certification has been granted to all of our operations and activities in Colombia (where all of our operations were in 2021). The Vice President, HSE & CSR is the ISO management system lead. The scope determined by Gran Tierra for the EMS under the ISO 14001: 2015 standard includes hydrocarbon exploration, production, treatment, transportation, distribution, sales and marketing activities. The EMS identifies nine significant environmental aspects that form the basis of Gran Tierra’s commitment to environmental protection. Use and consumption of water for industrial and domestic activities Fuel consumption Solid and liquid waste generation Electric power consumption Thermal radiation generation GHG emissions generation Use and consumption of chemicals Spill generation Removal of vegetation cover Figure 3: Environmental Management System Environmental Aspects SASB EM-EP-160a.1 + SASB EM-EP-160a.3 + HSE Policy +Biodiversity Impacts Prior to entering any new areas, and in accordance with Colombian and Ecuadorian environmental regulations, we perform rigorous Environmental Impact Assessments of our proposed projects. These assessments enable project planners to understand the environmental conditions of the area, determine the interactions between a project and the ecosystem, identify potential impacts, and propose appropriate environmental strategies and any needed mitigation, correction, or compensation measures. In addition, during the environmental impact assessment process, Gran Tierra encourages the participation of the local communities and authorities. NaturAmazonas, Gran Tierra’s flagship, voluntary conservation program has successfully completed its initial five-year run. This large-scale project combats deforestation at strategic locations that connect the Amazon rainforest with the foothills of the Andes mountain range; one of the most biodiverse ecosystems in the world. The initiative, now entering its second phase, has reforested over 1,000 hectares of land and secured 2,400 hectares for conservation. The original five-year commitment has been extended by an additional two years and has invested a total of USD $13 million. NaturAmazonas, originally conceived as a voluntary reforestation project to meet the needs of communities, regional ecosystems and contribute to Colombia’s national reforestation goals, has developed a large alliance and built a new model for institutional coordination, creating conditions for transformative change in Colombia’s Amazonia region. NaturAmazonas also makes a significant contribution towards the 2030 emissions reduction and carbon sequestration targets established by the national government and the Ministry of Mines and Energy in Colombia. The project will sequester approximately 8.7 million tonnes of CO2 through reforestation and conservation over its lifetime. The 2021 Sustainability Report includes additional highlights from the NaturAmazonas program. For more detail, see NaturAmazonas By the Numbers on p.21 2021 Sustainability Report. Environmental Impact Assessments NaturAmazonas Conservation Program 17 Analyst Corner Leveraging Technology to Protect the Environment The Chawar Project, completed in 2019 in partnership with Colombia’s Alexander von Humboldt Biological Resources Research Institute, is a powerful tool that helps Gran Tierra make decisions that reduce the social and environmental impacts of well exploration and development projects. Chawar incorporates a wide range of data sets into a powerful technology platform that allows Gran Tierra to minimize our footprint, design smarter environmental mitigation and compensation strategies, reduce forest fragmentation and protect environmentally significant areas. Chawar was immediately applied to the Environmental Impact Assessment for the Cumplidor North development project, which requires a licence to operate in an environmentally important and biodiverse region connecting the Andes Mountain range to the Amazon rainforest. SASB EM-EP-160a.1 + 2021 Sustainability Report +Biodiversity Impacts An Alliance with ANDI 18 Analyst Corner ANDI (the National Business Association of Colombia), Gran Tierra, the National Natural Parks of Colombia and the Humboldt Biological Research Institute, have partnered together in an alliance that is focused on ecosystem protection, restoration and connectivity, sustainable development of biodiversity and promoting sustainable development in the region. The alliance’s accomplishments thus far include: •National Parks of Colombia and Gran Tierra are currently working together to create a framework for conservation agreements in protected areas. •Gran Tierra’s Costayaco Forestry Centre has supported the Andean-Amazon ecosystem connectivity strategy by restoring and protecting 314.5 hectares. •Ongoing coordination of environmental investments. The Costayaco Forestry Centre (CFC): A Plant & Animal Sanctuary Gran Tierra established the Costayaco Forestry Centre (CFC) in coordination with the regional environmental regulator in the Putumayo Department. Through the Costayaco Forestry Centre, Gran Tierra has planted over 200,300 trees across the Putumayo and Cauca Departments and donated trees to local communities and educational centres. Gran Tierra’s investments over the last ten years have increased the size and impact of the facility, which has become a model for public and private institutions interested in strategies for conservation investments. Based on the CFC’s success, plans to expand the facility and open similar forestry centres near Gran Tierra’s operations in the Middle Magdalena Valley and Putumayo South are underway. The new centres will follow the CFC model, implementing medium and long-term projects, working closely with environmental institutions and local communities. The 2021 Sustainability Report includes additional information on the CFC. For more detail, see p.22-24 2021 Sustainability Report. Case Study: Amazon Butterfly Species Guidebook Gran Tierra partnered with Corpoamazonia, the Corporation for the Sustainable Development of the Southern Amazon, to produce the first guidebook of the approximately 145 species of butterflies that exist in the Amazon piedmont. This study and cataloguing are a significant step in developing management and conservation practices for these species with high potential for scientific research and tourism. SASB EM-EP-160a.1 + 2021 Sustainability Report +Next >