Luck Grove DEI Policy

Diversity, Equity, and Inclusion (DEI) Commitment

At Luck Grove, we are dedicated to fostering an inclusive, equitable, and diverse environment. Our DEI policy reflects our core values of integrity, initiative, and innovation, and aligns with our mission to provide cutting-edge technology and innovative operational procedures in the telecommunications and utilities industries. We believe that a diverse and inclusive workforce is essential to our success and contributes positively to the communities we serve.

Diversity

Workforce Diversity:

1. - Inclusive Hiring Practices: We are committed to implementing fair and inclusive hiring practices that promote diversity in all roles and at all levels of our organization. We ensure that our hiring criteria are unbiased and relevant to the skills and competencies required for each position.
  - Diverse Sourcing: We actively seek out candidates from underrepresented groups through partnerships with diversity-focused organizations and platforms. This includes engaging with minorities, women, veterans, LGBTQ+, and individuals with disabilities.

Supplier Diversity:

- Supplier Engagement and Outreach: We actively identify and engage with diverse-owned businesses, including those owned by minorities, women, veterans, LGBTQ+, and individuals with disabilities. Our Supplier Diversity team networks, attends events, and partners with relevant organizations to identify potential suppliers.
- Vendor Eligibility Criteria: To be considered as a diverse supplier, a business must be at least 51% owned and controlled by individuals from underrepresented groups, independent, and provide valid certifications from recognized third-party organizations or agencies.
- Verification Process: We ensure the authenticity and accuracy of supplier diversity claims through a thorough verification process involving application review, documentation submission, validation, and, if applicable, site visits.

Equity

Equitable Opportunities:

1. - Career Development: We provide equitable opportunities for career development and advancement within the company. This includes offering mentorship programs, training, and resources to support the growth and competitiveness of our employees and suppliers.
  - Pay Equity: We are committed to ensuring pay equity across all roles and levels within the organization. Regular audits and adjustments are conducted to address any disparities.

Inclusive Workplace:

- Employee Resource Groups (ERGs): We support various ERGs, including those for veterans and other underrepresented groups, to provide a platform for diverse voices and perspectives. These groups foster a sense of community and belonging within the company.
- Inclusive Policies: Our policies reflect our commitment to creating an inclusive workplace. This includes accommodations for individuals with disabilities, gender identity and sexual orientation non-discrimination, and support for employees’ reproductive health decisions.

Inclusion

Creating an Inclusive Culture:

1. - Training and Awareness: We provide ongoing training and awareness programs to educate our employees about diversity, equity, and inclusion. This includes workshops on unconscious bias, cultural competency, and inclusive leadership.
  - Community Engagement: We engage with local communities through our charitable giving and community projects. Notable initiatives include donating a telecommunications lab to the local children’s museum to promote STEM education and supporting various charitable causes.

Transparency and Accountability:

- Reporting and Transparency: We maintain transparency in our DEI efforts through regular reporting. This includes updates to stakeholders on program achievements, supplier statistics, and the impact on the community.
- Governance Structure: Our DEI initiatives are overseen by the ESG Committee, which ensures alignment with our strategic objectives and stakeholder expectations. The Board of Directors has oversight of DEI matters, integrating these considerations into our overall governance framework.

Continuous Improvement

We recognize that our DEI journey is ongoing and commit to continuously improving our practices. We seek input from stakeholders to enhance our DEI efforts and adapt our strategies based on emerging best practices and new technologies.

Measurement and Reporting

We understand the importance of accountability and transparency in our DEI efforts. We will maintain records of audits, training participation, supplier engagement, and more. We will produce an annual DEI report reviewed by the executive team, outlining our achievements, goals, and challenges in each aspect of our DEI policy.

Our Resolve and Commitment

Luck Grove’s DEI policy emphasizes inclusivity, equity, and diversity. Through engaging diverse suppliers, promoting equitable opportunities, and fostering an inclusive culture, we aim to create a meaningful and lasting impact on our workforce and the communities we serve.

Purpose

Luck Grove is committed to integrating sustainable practices into our operations to reduce our environmental impact and enhance our role as responsible stewards within the telecommunications and utilities engineering and construction sectors. This policy outlines our commitments to improving energy efficiency, reducing waste, and lowering our carbon footprint, aiming for practical, achievable steps that align with industry norms and stakeholder expectations.

Scope

This policy applies to all Luck Grove operations, including procurement, project planning, and business development activities, with an intent to gradually extend these practices into everyday operations over time.

Commitments and Simplified KPIs

Energy Efficiency:
- Commitment: We aim to reduce energy consumption across our facilities and operations by implementing straightforward, cost-effective energy-saving measures.
- Specific Actions:
  - Use energy-efficient lighting (such as LEDs) in all new and existing facilities.
  - Encourage employees to adopt energy-saving habits, like turning off lights and equipment when not in use.
- KPI:
  - Monthly Energy Bill Tracking: Monitor monthly energy costs at primary facilities, aiming for a 5% reduction in energy expenses by the end of 2025.
- Tracking and Reporting: Track monthly utility bills for our main offices. Annual summaries will be included in our sustainability report, beginning at the end of 2025.
Waste Reduction:
- Commitment: We will work to reduce waste generated at our project sites and offices, with a focus on increasing recycling and minimizing unnecessary material use.
- Specific Actions:
  - Set up basic recycling bins in all facilities and job sites for paper, plastics, and metals.
  - Encourage digital documentation to reduce paper use.
- KPI:
  - Recycling Program Participation: Track the number of sites with active recycling programs, aiming for 100% participation across all major facilities and job sites by the end of 2025.
- Tracking and Reporting: Track participation through simple checklists completed by site managers, with a yearly review for the sustainability report.
Carbon Footprint Reduction:
- Commitment: We aim to reduce our carbon footprint by managing and minimizing CO2 emissions associated with business travel, particularly flights.
- Specific Actions:
  - Utilize our CO2 emissions tracking program to monitor the carbon footprint from all company flights.
  - Implement travel policies that prioritize virtual meetings and reduce non-essential travel.
- KPI:
  - CO2 Emissions Reduction per Employee: Reduce the overall carbon footprint ratio based on the number of employees and CO2 emissions by 5% by the end of 2025.
- Tracking and Reporting: CO2 emissions data will be collected from our flight tracking program. Quarterly reviews will be conducted to assess progress, with results included in the annual sustainability report.

Implementation and Accountability

Integration into Operations: Business Development and Operations teams are responsible for implementing these practices. Procurement and project planning will incorporate these guidelines, with a gradual extension to broader daily operations.
Employee Engagement: Luck Grove will promote awareness and participation in sustainability efforts through internal communications and training, fostering a company-wide culture of environmental responsibility.

Community and Industry Engagement

To support our commitment to environmental sustainability, Luck Grove will continue its involvement in community projects such as the revitalization of the Syracuse, NY Creekwalk.
We will explore additional opportunities to engage with industry partners and community organizations on sustainability initiatives.

Measurement, Reporting, and Review

Reporting Timeline: Formal reporting on sustainability efforts will begin at the end of the 2025 calendar year, providing a comprehensive overview of our progress and outlining next steps.
Annual Reporting: We will produce a simplified annual sustainability report, summarizing our KPIs and highlighting key achievements. This report will be shared with stakeholders to maintain transparency and demonstrate our commitment to continuous improvement.
Continuous Improvement: This policy will be reviewed annually to ensure its relevance and effectiveness. Adjustments will be made as needed to refine our approach and respond to new challenges and opportunities.

Conclusion By adopting this policy, Luck Grove commits to a pragmatic approach to sustainability, focusing on manageable steps that make a real difference. Through this commitment, we aim to contribute to a healthier environment and set an example of responsible industry practice.