Whistleblower Protection Policy

1. Purpose

Bridgehampton encourages good-faith reporting of suspected misconduct and provides confidential, impartial, and non-retaliatory channels for concerns. This Policy supplements rights under the Delaware Whistleblowers' Protection Act and other applicable laws.

2. Who may report

Current or former directors, officers, employees, contractors, consultants, suppliers, agents, joint-venture personnel, and other persons with relevant information may report. Reports may be anonymous where legally permitted and operationally available.

3. Reportable matters

• Accounting, internal controls, auditing, fraud, theft, false records, tax misconduct, or misuse of assets.
• Bribery, corruption, sanctions, money laundering, conflicts, competition violations, or procurement misconduct.
• HSE violations, unsafe work, well-control risk, environmental harm, concealment of an incident, or danger to the public.
• Harassment, discrimination, violence, human-rights abuse, community or cultural-heritage misconduct.
• Cybersecurity, privacy, confidentiality, retaliation, obstruction, or destruction of evidence.
• A violation of law, permit, contract, Code, policy, or material Company control.

Personal employment grievances may be handled through Human Resources unless they also involve legal violation, retaliation, systemic misconduct, or senior leadership.

4. Reporting channels

Reports may be made to a supervisor, Human Resources, Legal, Internal Audit, the Audit and Risk Committee Chair, or another director. Accounting complaints and allegations involving senior executives should be directed to the Audit and Risk Committee Chair. Emergencies involving immediate danger should be reported to local emergency services and site emergency leadership first.

The Company's general office number is 312-416-8586. Persons seeking confidential or anonymous reporting should use any separate reporting channel designated by the Company for that purpose.

5. External reporting rights

Nothing in this Policy, any confidentiality agreement, nondisclosure provision, separation agreement, or Company instruction prohibits or requires prior authorization for lawful communication with the SEC, Department of Justice, Department of Labor, OSHA, EPA, OFAC, law enforcement, or another government body. No person is required to notify the Company of such a report where law protects that choice.

6. Non-retaliation

The Company prohibits discharge, threat, discrimination, reduced compensation, demotion, harassment, blacklisting, immigration-related threats, adverse assignment, or other retaliation because a person in good faith reported or was about to report a concern, participated in an inquiry, sought advice, or refused to participate in a violation. Knowingly false allegations may lead to discipline, but an unsubstantiated good-faith report is not a violation.

7. Intake and triage

Reports will be logged, risk-rated, acknowledged when possible, and directed to a person free from conflict. Immediate measures may protect people, environment, evidence, assets, and reporter confidentiality. Allegations involving the CEO, CFO, Chief Legal Officer, a director, or auditor will be overseen by disinterested directors or independent counsel.

8. Investigation

Investigations will be prompt, impartial, proportionate, documented, and conducted by qualified personnel. The Company will preserve evidence, respect privilege and privacy, provide a fair opportunity to respond, and avoid unnecessary disclosure of reporter identity. Personnel must cooperate and must not conduct unauthorized inquiries.

9. Outcome and remediation

Where appropriate, the Company will communicate closure to the reporter without disclosing protected personnel or privileged information. Substantiated matters may result in discipline, restitution, control remediation, training, contract action, self-reporting, or referral to authorities. Retaliation allegations will be investigated separately and urgently.

10. Records and Delaware notice

Records will be retained under applicable law and legal holds. For Delaware employees, the Company will post and otherwise provide notices required by 19 Del. C. Section 1707 and administer this Policy consistently with Sections 1701-1708.