All employees and contractors of ECHO Seismic LTD. and its affiliates (the “Corporation”) are expected to abide by all Policies & Procedures of the Corporation, and to act in a manner that will uphold and enhance the Corporation’s reputation for honesty, integrity, and reliability. Further, the principles of appropriate business conduct adopted in the Code are consistent with the core values and management philosophy of the Corporation and are to be pursued by all employees.

The professional integrity and actions displayed by individual employees and contractors play an important role in reflecting the Corporation’s values. The fundamental principles of the Code are designed to deter unlawful activity and misconduct and to promote the following:

We respect the human rights of all individuals impacted by our operations, including employees, contractors and external stakeholders. Wherever we operate, we seek to avoid causing or contributing to human rights violations and to facilitate access to remedy. While governments have the primary responsibility to protect against human rights violations, we understand and accept our responsibility to respect human rights. We consider “human rights” to be all internationally recognized human rights in the International Bill of Human Rights and the International Labour Organization (ILO) Declaration of Fundamental Principles and Rights at Work.

In fulfilling our mission, we are guided by several principles that help define our approach:

• We are committed to and always strive to act in accordance with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, and the Voluntary Principles on Security and Human Rights.

• We are committed to comply with the UN Declaration on the Rights of Indigenous Peoples (UNDRIP)

• We do not tolerate violations of human rights committed by our employees, affiliates, or any third parties acting on our behalf or related to any aspect of one of our operations.

• We do not tolerate the use of child labour, prison labour, or any form of forced labour, slavery or servitude.

• We believe in fair employment practices and in a workplace in which all individuals are treated with dignity and respect. We do not tolerate discrimination against individuals on the basis of race, colour, gender, religion, political opinion, ethnicity, age, nationality or social origin, sexual orientation, or union membership.

• We aim to pay all employees and contractors fairly. We will enforce working hours to the best of our ability aligned with ILO standards, and provide fairly compensated overtime and pay for periodic holidays and time off.

• We respect the freedom of expression and right to associate of our employees and contractors, including their right to establish and to join organizations of their own choosing to bargain collectively and advance their occupational interests without our previous authorization or unreasonable interference.

• We do not tolerate threats, intimidation, or attacks against human rights defenders.

• In our relationships with host governments, contractors and third-party service providers, we do our utmost to avoid being complicit in adverse human rights impacts, including benefitting from the human rights violations caused by others.

• We monitor and try to continuously improve our human rights performance.

To try and meet those commitments, we will aim to take several steps:

• Develop and implement supporting policies, procedures, training and internal reporting structures to embed this Policy throughout our company.

• Provide training on our human rights expectations to all new employees and all relevant existing employees.

• Provide a safe and healthy workplace for all staff, contractors and subcontractors.

• Follow the Voluntary Principles on Security and Human Rights in our dealings with public and private security providers, local communities and potential victims of human rights violations.

• Comply, and demand that all suppliers and contractors comply, with all national laws, the International Bill of Human Rights, and the ILO Core conventions.

• Conduct human rights due diligence for all new projects and significant modifications to existing operations where there is the potential for negative human rights impacts, and seek to employ reasonable measures to mitigate those impacts.

• For relevant suppliers and third-party service providers, perform reasonable due diligence, insist that human rights terms and conditions be included in contracts (including compliance with this Policy), and require periodic human rights reporting, certifications and/or training.

• Promote human rights by contributing to public debate, supporting international agreements and commitments, and identifying opportunities to constructively engage on human rights issues relevant to the countries in which we operate.

• Only employ people above the minimum employment age set by national law or by ILO Convention 138, whichever is the higher. We will avoid employing individuals below 18 years of age in work that is likely to harm their health, safety or morals.

• Promote fair competition, including respect for property rights.

• Respect the history, culture and traditional ways of indigenous peoples, their standing as distinct, self-determining peoples with collective rights, and their interests in land, waters and the environment.

• Meaningfully engage with the local communities and other stakeholders affected by our operations to create and maintain transparent relationships built on mutual respect and trust.

• Prohibition on hiring or using private or public security forces that may cause interference due to lack of instruction or control.

• Compliance with the Minamata Convention on Mercury use, production and disposal.

• Compliance with the Stockholm Convention for production and utilization persistent organic pollutants.

• Compliance with the Basel Convention for the handling, exporting, and importing of hazardous waste to safeguard human health and the environment from hazardous waste’s adverse effects.

• Establish and maintain a grievance mechanism for human rights complaints to be reported and addressed without any prejudice to the aggrieved person(s). We will report publicly on how complaints have been managed.

• Prevent, mitigate, and, where appropriate, remedy negative human rights impacts that are caused, or contributed to, by our company. In situations where we are directly linked to negative human rights impacts because of activities in our value chain, we will seek to use our leverage to prevent or mitigate those impacts.

• Take appropriate action where we identify violations of this Policy by employees or contractors.

This policy and any standards developed in support of the overall Policy objective are subject to ongoing review and evaluation by the President and Chief Executive Officer.

Modifications to this policy statement shall be made as deemed necessary to respond to current circumstances and/or evolving needs of ECHO Seismic LTD. and its subsidiaries.

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Richard Habiak, President, and CEO

ECHO Seismic Ltd