Modern Slavery Report

Introduction

This report (the “Report”) describes the actions taken by Steel Reef Infrastructure Corp. and our subsidiaries (hereafter collectively referred to as “Steel Reef” or “Company”)[1] pursuant to Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act  (the “Act”).  We have prepared this Report in compliance with the Act for the year 2024.

Steel Reef is a widely held, private company incorporated pursuant to the laws of Alberta and is headquartered in Calgary, Alberta with an office in Denver, Colorado. We own and operate integrated gathering, processing, transportation and storage facilities within both the Province of Saskatchewan and the State of North Dakota. The focus of our operations is to capture, process and transport associated natural gas to prevent it from being flared or vented to the atmosphere. The resulting valuable products, that include natural gas, propane, butane, and condensate, are then sold into both local and cross border markets.

Steel Reef employs approximately 200 full and part time employees to which our corporate culture is of the utmost importance. We value discipline, respect and excellence and we partner with stakeholders that share in these values.

[1] Steel Reef Burke, LLC, a Delaware corporation; Steel Reef Pipelines US, LLC, a Delaware corporation; Steel Reef US Corp., a Delaware corporation; Steel Reef Pipelines Canada Corp., a Canadian corporation; Lignite Pipeline Canada Corp., a Canadian corporation; and Gateway Energy Terminal, a Saskatchewan corporation.

Identifying Modern Slavery Risks in 2024

During the 2024 calendar year, Steel Reef provided training to employees on forced labour and child labour. Since 2023, Steel Reef has also sought external guidance to further educate and support those involved in our supply chain, on forced labour and child labour (also referred to herein as “Modern Slavery”). Based on the guidance received from our external counsel regarding the legislative framework and associated risks, Steel Reef has developed and made available an optional Modern Slavery Due Diligence Questionnaire as part of our evolving approach to supplier engagement and risk awareness. This questionnaire is offered to all new and existing suppliers, seeking to gather insights into sourcing practices, historical labour compliance, and internal policies addressing forced or child labour. While participation remains voluntary at this stage, we are evaluating how this questionnaire, as a tool, could strengthen its role within our supplier engagement process, including potential steps to formalize risk categorization and enhance supply chain oversight.

Throughout 2024, Steel Reef continued to build internal capacity in this area. Our working group, established in 2023, consisting of management representatives from our supply chain, risk, compliance as well as governance and legal, met throughout the year to discuss the Act, evaluate internal practices, and explore enhancements to Steel Reef’s policies and procedures. Among other initiatives, the working group is actively considering the implementation of a structured supplier risk matrix to support informed prioritization and potential future supplier oversight measures. As part of these discussions, we are also exploring the feasibility of tailoring audit strategies to focus more specifically on suppliers that may present elevated risk profiles.

In addition, Steel Reef’s enterprise risk management program continues to play a foundational role in identifying and monitoring risks across the business. The program reports on a quarterly basis to the Audit and Enterprise Risk Management Committee (“AERM Committee”) comprised of three directors from the Board of Directors (“Board”). Each business unit within Steel Reef conducts, on an annual basis, a fulsome review of the risks specific to their unit, the controls in place to mitigate the risks and the effectiveness thereof. This annual risk report is also presented to the AERM Committee. In each instance of reporting, our risks are prioritized based on their likelihood, severity and level of impact to our business.

Our Supply Chain

Steel Reef utilizes reputable suppliers, both local and global, who supply different categories of goods and services used in our infrastructure. Such goods and services include, but are not limited to, electrical, welding and mechanical services and the equipment related thereto. All of our material suppliers are screened through a Request For Proposal (“RFP”) process that is crafted to ensure quality and safety, compliance with Steel Reef’s operational integrity requirements and to reduce potential legal and reputational risks. Further, as Steel Reef seeks to partner with suppliers who align with our values, suppliers that are onboarded must commit in writing to conduct themselves in accordance with Steel Reef’s Code of Business Conduct and Ethics Policy.

Our supply chain mapping activities in 2024 contributed to a broader understanding of the goods and services procured, including (i) the jurisdictions purchased from; and (ii) the break down of our spend by industry sector. While the majority of our suppliers are domiciled in North America, we appreciate that many of the products they supply may originate from other jurisdictions. This review also helps inform our ongoing consideration of potential areas of supply chain risk, including labour-related concerns in the earlier tiers of our suppliers’ sourcing practices.

The chart below represents our approximate global supply chain spend by industry sector for Operations as at December 31, 2024:

The chart below represents our approximate global supply chain spend by industry sector for Projects as at December 31, 2024:

Policies With Global Application

Steel Reef actively seeks to ensure both our staff and suppliers operate in an ethical, legal and responsible manner.  As part of this commitment, our Board annually reviews and approves the policies and procedures put in place by management to make clear that they capture our values and expectations for all levels of employment and for all decisions made at Steel Reef.  The policies are reviewed annually to identify ways for continuous improvement and ensure compliance with all applicable laws.  Following the Board’s annual review and approval, all staff are required to also review and agree to remain compliant. For suppliers of Steel Reef, an external website is provided where they can their review applicable policies of Steel Reef and the expectation of compliance is built into our written commercial arrangements.

The following policies are notable in our commitment to upholding ethical, legal and responsible behaviours:

Steel Reef is committed to ongoing policy review and improvement and is continually seeking ways to advance our practices in conjunction with addressing unethical behaviours.

Assessment of Risks & Looking Forward

In 2024, Steel Reef continued to assess potential risks of Modern Slavery across our operations and supply chain. As part of this work, we continue to assess and identify areas where we could refine our Code of Conduct and Ethics and our Respectful Workplace policies to ensure the clear articulation that Modern Slavery is prohibited. Further, we have incorporated language into our commercial agreements that reflects expectations for suppliers to avoid engaging in forced or child labour.

Upon assessing our workforce, we determined that, because the employees of Steel Reef are largely office staff and oil and gas field workers in Alberta, Saskatchewan, Colorado and North Dakota, our staff is at low risk for Modern Slavery. Nevertheless, we remain committed to monitoring potential areas of vulnerability and promoting awareness among employees and suppliers.

During 2024, our internal teams continued to apply a risk-based lens when reviewing key suppliers. This included credit worthiness, safety statistics and regulatory compliance, which collectively inform our supplier engagement and selection practices.  While we have not identified any forced labour or child labour in our activities and supply chains to date, and therefore have not taken any measures to remediate or eliminate any forced labour or child labour in our activities and supply chains (including any measures that would involve the potential loss of income to vulnerable families), we remain alert to the evolving global risk landscape.

We acknowledge and recognize a gap in not having full transparency into where our North American suppliers source their materials from. As a result, Steel Reef has been considering methods in which we can collect further and better particulars from our material suppliers to better understand where they source their materials from and what human rights practices are in place in those jurisdictions. Accordingly, as previously noted, we have initiated efforts to improve our understanding of upstream sourcing through the introduction of an optional Modern Slavery Due Diligence Questionnaire. While completion is currently voluntary, we are exploring ways to enhance its use as a tool to support supplier risk awareness and prioritization. We continue to evaluate the feasibility of developing a supplier risk matrix and exploring how tailored oversight measures, including potential audits, may be structured in the future.

Looking forward, Steel Reef will continue exploring ways to improve internal awareness and education on Modern Slavery, including targeted presentations to relevant teams and the potential integration of human rights content into annual Code of Conduct training. While we do not yet have formal metrics in place to evaluate the effectiveness of our efforts in ensuring that forced labour and child labour are not being used in our business and supply chains, we continue to explore practical ways to support future monitoring and continuous improvement through internal collaboration and awareness-building.

Approval and Attestation

This Report was approved pursuant to subparagraph 11(4)(b)(ii) of the Act by the Board of Directors of Steel Reef Infrastructure Corp.

In accordance with the requirements of the Act, I attest that I have reviewed the information contained in the Report and based on my knowledge, having exercised reasonable diligence, I attest that the information contained in the Report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year of 2024.

I am providing this attestation in my capacity as officer of Steel Reef Infrastructure Corp and not in my personal capacity. I have the authority to bind Steel Reef.

Greg Pollard
Chair of the Board of Directors

Dated: May 15, 2025

[1] Steel Reef Burke, LLC, a Delaware corporation; Steel Reef Pipelines US, LLC, a Delaware corporation; Steel Reef US Corp., a Delaware corporation; Steel Reef Pipelines Canada Corp., a Canadian corporation; Lignite Pipeline Canada Corp., a Canadian corporation; and Gateway Energy Terminal, a Saskatchewan corporation.