A Distinguished Board

Each board committee member brings distinguished skills and capabilities enabling oversight of the strategies driving our long-term growth, economic performance, and sustainability and ESG goals.

Business Ethics and Transparency

TPL maintains an Employee Handbook and a Code of Business Conduct and Ethics (Code of Conduct) that reflect up-to-date ethics and compliance expectations. The Employee Handbook includes a Policy for Reporting Concerns, Insider Trading Policy, and Related Person Transaction Policy. The Policy for Reporting Concerns outlines how employees are enabled and empowered to anonymously report ethics and compliance concerns through our Whistleblower Program. All employees are provided with these policies upon hire and can access them through the TPL intranet site. These policies are reviewed periodically by the Audit Committee and changes are approved by the Board of Directors.

TPL provides good-faith reporters with numerous confidential communication channels to report concerns, including our anonymous ethics hotline (844-639-9563) and reporting website (https://texaspacific.ethicspoint.com). Employees can also communicate concerns to their manager, Compliance, Human Resource, the General Counsel, or the Audit Committee. As outlined in TPL’s Code of Business Conduct and Ethics, TPL prohibits retaliation against employees for reporting concerns in good faith and for participating in an investigation.

Our Ethics and Compliance team will be informed of any grievance reports – this team is responsible for reviewing reports within a reasonable timeframe. Reports that are submitted to the ethics hotline or reporting website will be investigated by a third-party contractor. The third-party investigator will prepare a plan of investigation which includes expected timing, persons to be interviewed, documents to be reviewed, reports to be prepared, and roles to be assigned to Company personnel and outside advisors. The TPL Compliance team will meet with the investigator on a regular basis to provide oversight and receive updates on the progress of the investigation.

At the conclusion of the investigation, corrective actions may be recommended by the investigation and/or Compliance. Corrective actions will be consistent with applicable law and regulation and guidelines for disciplinary action included in the Employee Handbook. Types of disciplinary action include, but are not limited to, reprimand (verbal or written), suspension, and termination.

Compliance shall maintain a log of all concerns and the status of any investigations and corrective actions. Compliance is responsible for providing the Audit Committee with an update on all matters within the log at least quarterly.

Employee Training

Additionally, to ensure continued compliance and employee awareness, TPL mandates employee training for anti-bribery & antitrust and workplace ethics. On an annual basis, employees must read and acknowledge TPL’s Code of Conduct. Additionally, third-party contractors are required to read and acknowledge the Code of Conduct as part of their employment standards. Our Code of Conduct confirms:

• The prohibition of certain activities which could result in actual or potential conflicts of interest, including insider trading.
• The prohibition of bribery.
• The prohibition of facilitation payments.
• Texas Pacific’s Gifts and Entertainment Policy.
• Texas Pacific’s Political Contributions Policy.
• All employees are required to undertake training annually or whenever there are changes to key provisions or updates.
• Any ethics or compliance concerns can be initiated through our Whistleblower link / hotline, which directs these concerns to the proper HR resources. The Company prohibits any retaliation against any employee who in good faith reports a violation of this Code or any of the Company’s policies.

Policy on Human Rights

Our Code of Business Conduct and Ethics emphasizes our commitment to adhering to all applicable laws and best practices within the United States (U.S.). We also adhere to human rights principles, including those concerning freedom of association and collective bargaining, non-discrimination, and prohibiting forced labor and underage workers in the workplace. TPL’s commitment to protecting human rights extends to our employees, suppliers, and to the communities in which we operate. Although TPL does not employ security providers, our Code of Business Conduct and Ethics would cover their behavior and ethical conduct expectations. All employees and affiliates of the company are required to comply with this Code. Failure to follow it subjects them to disciplinary action, up to and including termination and possible legal prosecution.

The entirety of TPL’s operations is located within the U.S. and subject to U.S. human rights and labor laws to protect the rights of our employees. The Company adheres to all laws, including the prohibition of child labor and forced labor, and we integrate human rights best practices into our operations, guided by internationally recognized Human Rights principles such as the UN Guiding Principles’ pillars of ‘Protect’ ‘Respect’ and ‘Remedy’. As such, we provide our employees with fair living wages and appropriate working hours. None of the Company’s operations have been subject to human rights impact assessments and there have been no human rights grievances.

TPL does not lease to oil and gas operators in areas of conflict and the Company does not operate our water business in areas of conflict. Our Business Code of Conduct and Ethics stipulates the expectations our workforce must abide by to ensure workforce, community, and third-party welfare. Our Business Code of Conduct and Ethics and our Employee Ethics Policy, condemn any form of violence or harassment in the workplace. All employees, community members and third-party agents of TPL are entitled to work in an environment that is free of any violation of their human rights, including discrimination and harassment. All people at TPL are treated with respect and as equals. Employees can report instances of workplace violence or suspicious activity by contacting the Department of Public Safety (DPS) through the iWatchTexas Community Reporting System at www.iwatchtx.org, or by calling 844- 643-2251. Employees have the right to make a report to DPS anonymously.

Human rights violations—both in the workplace and externally through our community and supplier engagements—are monitored 24/7 through our hotline and through the annual trainings hosted via web-based learning. Internally, these trainings cover inappropriate conduct, workplace harassment, and workplace violence. Disciplinary measures are also stipulated in our Business Code of Conduct and Ethics. Externally, TPL is committed to conducting our business in accordance with the highest standards of human rights, as outlined in our Human Rights Policy. To ensure our Human Rights Policy remains relevant, it is reviewed annually by key personnel at TPL, as well as our Board of Directors, and the Company commits to providing regular, objective monitoring and reporting on our human rights progress as well as monitoring the effectiveness and performance of the Human Rights Policy. TPL’s Human Resources department is accountable for ensuring our Human Rights Policy is effectively implemented and all members engaged in activities under the Company’s control are responsible for the application of the Human Rights Policy. We remain committed to treating all people, including minority groups, women, and indigenous peoples, as equals and following the guidelines stipulated by the UN Guiding Principles and outlined in our Human Rights Policy. This includes identifying our potential human rights impacts through active risk management, prevention, and structured mitigation strategies. While TPL has had no actual human rights incidents that require remediation, the Company is prepared to act quickly should that scenario ever arise.

Data Protection and Information Security

TPL is committed to proactively managing our data protection and information security policies and practices. While cyber threats continue to evolve, the Company remains steadfast in our cyber and IT security policies and trainings, as well as oversight and management of these issues. All TPL employees adhere to holistic and stringent cyber security practices through their day-to-day responsibilities and by keeping updated on relevant trainings. Governance of IT and cyber security is overseen by the Audit Committee of the Board of Directors and implemented by Executive Leadership. Throughout the year, the Audit Committee receives periodic IT and cyber security updates, unless there is a notable event that requires immediate communication. TPL continues to track and implement relevant technology, talent and practices to enhance our data protection and information security program. Our cyber security and IT policies and procedures are outlined in our Information Technology and Cyber Security policy.