North West Co Inc/The

#### ESG Governance

**NORTH WEST IS committed to strong**
governance, including ESG oversight. We
manage ESG topics in the context of our
business strategy and take into consideration
the interests of our many partners. Starting
in 2023, North West began including ESG as
part of the criteria for the Company's shortterm incentive program, linking sustainability
performance to compensation, starting with
the executive and senior leadership.

###### North West ESG Governance Structure

**The Board: Comprised of the Board of**
Directors and Board subcommittees, the
Board oversees and monitors North West's
ESG strategy, policies and practices. The
Board sub-committees are responsible for risk
and compliance, ensuring adequacy of ESG
controls, ESG disclosure, alignment on policies/
regulations and overseeing progress against
ESG goals. In addition, the subcommittee
oversees the achievement of ESG incentive
plan goals in the organization.

**ESG Steering Committee: The Steering**
committee is comprised of company executives
and is responsible for ensuring the adoption
of leading ESG practices and programs. It
provides guidance to North West on ESG
programs, as well as strategic direction on
ESG activities, priorities, internal tracking and
external disclosure frameworks. The committee
ensures that ESG action plans are effectively
implemented, and that progress is made
towards established targets and milestones.

**Objective Lead Committee: This committee**
is comprised of ESG objective leads who
are responsible for the development,
ESG KPIs and targets that align to their
objective. Each objective lead is responsible
for coordinating and executing action plans,
tracking and reporting of KPIs, determining
resources and organizing with internal North
West groups as needed

|GOALS|ACTIONS TAKEN IN 2021| |---|---| |Build strong relationships with communities based on the recognition of rights, respect, cooperation and partnership.|• Engaged in ongoing consultation with political leadership at the national, regional and community level as the COVID-19 pandemic continued. • Produced monthly update letters to each community leader including Chiefs and their Councils, mayors and Pandemic Committees and other stakeholders, sharing the current state of our stores' operations, including safety protocols, pricing, staffing, product supply and strategies for circumstances impacting the community.|