In compliance with the provisions of the Federal Law on the Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on July 5, 2010 (the "Law"), its Regulations, and the Guidelines of the Privacy Notice published in the Official Gazette of the Federation on January 17, 2013, the following Privacy Notice is provided.

I. Controller of Personal Data

Carbon Tierra Prieta, S.A. de C.V. ("Tierra Prieta"), hereby informs you that your personal data will be strictly processed for the purposes stated below.

II. Personal Data

The personal data processed by "Tierra Prieta" consists of the holder's personal information, which may include full name, email address, home address, telephone numbers, Federal Taxpayer Registry (RFC), among other strictly necessary data for the purposes mentioned below.

If "Tierra Prieta" does not have your personal data, it will not be able to use it, and thus "Tierra Prieta" will not bear any liability resulting from handling these data.

III. Purposes of Personal Data Processing

"Tierra Prieta" may collect your personal data without commercial or disclosure intentions, solely for the following purposes:

• Conducting transactions and actions potentially engaged with "Tierra Prieta."

• Conducting various types of surveys.

• Addressing any matters related to the relationship with "Tierra Prieta."

• Promotion of products, discounts, promotions, bonuses, contests, and general advertising offered by "Tierra Prieta" or its affiliates.

• Reviews and corrections required for updating personal data and this website for better legal and security awareness.

• Communication with customers, suppliers, employees, or any individuals regarding matters related to personal data or this Privacy Notice.

• Addressing any issues related to this website’s information.

• Dissemination of information deemed relevant by "Tierra Prieta."

• Any other activity necessary to achieve the aforementioned purposes.

Personal data will be maintained under strict confidentiality and will not be used for purposes other than those mentioned, unless a change in this Privacy Notice occurs, as outlined in Section XI of this document.

Once the purpose of data processing is completed, personal data will be blocked solely to determine potential liabilities regarding their treatment until the applicable statutory or contractual limitations period expires. During this period, data will not be processed, and afterward, they will be deleted from databases or destroyed physically, as applicable.

IV. Collection of Personal Data

In collecting personal data, "Tierra Prieta" observes principles of legality, quality, consent, information, purpose, loyalty, proportionality, and responsibility.

Personal data will be collected directly from the holder, either in person or through legally permitted optical, audio, visual, graphical, or other technological means.

Information received and stored from internet pages when interacting with "Tierra Prieta" websites mainly includes technical details such as internet protocol addresses, computer operating system, browser type, reference website address, and website navigation path.

"Tierra Prieta" uses "cookies" to recognize users during interactions or future visits. Cookies can be disabled, though this might restrict website functionality.

V. Options and Means to Limit the Use or Disclosure of Personal Data

"Tierra Prieta" implements necessary administrative, technical, and physical security measures to protect personal data against unauthorized damage, loss, alteration, destruction, use, access, or processing.

Personal data is stored securely in databases and computers protected by physical and logical access controls, intrusion protection systems (IPS, Firewall), antivirus protection, and web filtering.

You may limit the use or disclosure of your data by emailing alejandro@tierraprieta.org.

VI. Person Responsible for Personal Data Processing

The person responsible is available Monday to Friday from 9:00 AM to 6:00 PM at alejandro@tierraprieta.org.

VII. Means to Exercise Access, Rectification, Cancellation, or Opposition Rights ("ARCO")

You may exercise ARCO rights by contacting the responsible individual via alejandro@tierraprieta.org. Your request must comply with Article 29 of the Law, including clear identification and description of the requested action.

"Tierra Prieta" is not obligated to delete personal data under certain conditions specified by Law, such as contractual obligations, legal requirements, or protection of legally recognized interests.

VIII. Personal Data Transfers

Transfers of sensitive data to third parties will occur only under specific legal or contractual circumstances. If third-party use differs from original agreements, consent will be presumed unless opposition is explicitly expressed within ten days of notification.

IX. Revocation

Consent for data processing may be revoked via written request to the designated individual at alejandro@tierraprieta.org. "Tierra Prieta" has thirty business days to respond and twenty business days thereafter to act upon accepted revocations.

X. Links to Other Websites

"Tierra Prieta" is not responsible for external websites linked on its pages, their privacy practices, or data management.

XI. Other User Websites

All "Tierra Prieta" operated websites adhere to this Privacy Policy, with adjustments possible based on local practices or regulations.

XII. Jurisdiction

This Privacy Notice and related legal handling will be governed by Mexican law, with disputes resolved by the competent courts in San Pedro Garza García, Nuevo León, Mexico.

XIII. Holder’s Consent

Consent for data processing is presumed unless explicit opposition is provided according to Section VII of this Privacy Notice.

XIV. Changes to Privacy Notice

"Tierra Prieta" reserves the right to modify this Notice at any time. Changes will be posted on this website.

 

Grievance Policy of Biochar de Nogal S.A. de C.V. “Tierra Prieta”

Version 1.0

Approved by Biochar de Nogal S.A. de C.V.

Approval Date: May 14, 2025

Review Frequency: Every five years

Policy Responsible: Andres Chapa de la Garza

Next Review: April 2030

1. Introduction

1.1 Biochar de Nogal S.A. de C.V. operates a biochar plant using walnut shells. Its primary functions are: a) Transforming walnut shells into biochar through pyrolysis. b) Certifying its operations for obtaining carbon removal credits.

1.2 Biochar de Nogal strives to offer high-quality services and maintain maximum integrity, establishing a mechanism for stakeholders (customers, suppliers, contractors, and the general community) to file complaints about its operations.

1.3 This policy aims for transparency in the complaint and decision-making process to ensure community trust. Complaints must be handled promptly according to a predefined schedule.

1. Scope

2.1 "Complaint" refers to dissatisfaction with Biochar de Nogal's processes or operations.

2.2 Complaints cover:

• Biochar manufacturing (raw material transport, pyrolysis processing, packaging, product export, employee, and plant visit matters).

• External community relations (clients, suppliers, contractors, local community, municipal, state, and federal authorities).

2.3 Labor disputes are excluded and handled separately under applicable law.

1. Escalation and Decision Making

3.1 Complaints must follow the procedure outlined in section 5.

1. Eligibility

4.1 Any stakeholder can file a complaint. 4.2 Anonymity requests are allowed without justification. 4.3 Biochar de Nogal may reject complaints lacking justification or new evidence.

1. Procedure

5.1 Complaints must be written and include identification or anonymity requests, issue details, dates, perceived impacts, and evidence. 5.2 Send complaints to contacto@tierraprieta.org, subject “Complaint.” 5.3 A response is provided within 20 calendar days if complete. 5.4 Accepted complaints are investigated within an additional 30 calendar days. 5.5 Extensions may be communicated. 5.6 Results and decisions are communicated in writing. 5.7 Appeals are accepted within 30 calendar days of the initial decision.

1. Records and Transparency

6.1 Notification upon complaint acceptance. 6.2 Updated case status and relevant documentation provided. 6.3 Decisions recorded in the "Active and Historical Complaints Registry." 6.4 Corrective actions documented and communicated. 6.5 Conflicts of interest disclosed.

1. Confidentiality and Privacy

7.1 Complainant information used for investigations, possibly shared for legal or technical advice. 7.2 Information is non-confidential unless explicitly requested. 7.3 Compliance with Mexican data protection laws and Biochar de Nogal's Privacy Notice.