Accessibility Plan

Accessibility Plan 2026-2028

Heavy Crude Hauling LP

1. Intent

Heavy Crude Hauling L.P. (the "Company") is committed to providing a barrier-free environment for all stakeholders, including customers, employees, job applicants, suppliers, and any visitors who enter the premises, access information provided by the Company, or use the Company's services.

The Company will work to identify and remove barriers, and prevent new barriers, for persons with disabilities as they relate to employment, communication, the built environment, and transportation at the Company. This plan outlines the Company's Accessibility Plan and strategy for identifying, removing, and preventing these barriers.

The Company is part of a network of wholly-owned companies and limited partnerships that are subsidiaries of Mullen Group Ltd. ("Mullen Group"). Mullen Group's corporate office ("Corporate Office") provides the Company certain services and will assist with the development and implementation of the Accessibility Plan on an ongoing basis.

2. Definitions

Barrier: Anything physical, architectural, technological, or attitudinal, anything that is based on information or communications, or anything that is the result of a policy or a practice that hinders the full and equal participation in society of a person with an impairment, including a physical, mental, intellectual, cognitive, learning, communication, or sensory impairment, or a functional limitation.

Disability: Any impairment, including a physical, mental, intellectual, cognitive, learning, communication, and sensory impairment, or functional limitation that is either permanent, temporary, or episodic in nature. It can be evident or not in interaction with a barrier to hinder a person's full and equal participation in society.

Accessibility Plan: This Accessibility Plan includes an overview of our policies, programs, practices, and services in relation to the identification and removal of barriers and the prevention of new barriers. The Accessibility Plan was prepared and published by June 1, 2023, and will be updated every three years following that, or sooner if necessary.

3. Statement of Commitment

Heavy Crude Hauling LP is committed to providing an accessible and inclusive workplace and service environment. As a transportation and logistics company we recognize that accessibility directly supports safety, operational efficiency, and employee wellbeing.

The Company adheres to all requirements made by regulation in the development and ongoing maintenance of the Accessibility Plan.

4. Feedback Process and Contact Information

The Company welcomes feedback regarding the manner in which it is implementing its Accessibility Plan and any barriers encountered by persons with disabilities. Persons who provide formal feedback will receive acknowledgement of their feedback in the same manner in which it was received, unless feedback is submitted anonymously. The Company is committed to reviewing the feedback received in good faith and taking steps to address barriers identified in this feedback.

Feedback can be submitted in person, by mail, by telephone and by email to:

Human Resources Administrator
780-870-4020
6601-62 Street
Lloydminster, AB T9V 3T6
info@heavycrudehauling.com

Feedback can be provided anonymously, if desired, and will remain confidential unless the person consents to the disclosure of their personal information. Feedback is received in whatever format the individual providing the feedback is most comfortable with. Any feedback received will be reviewed with the Company's Business Unit Leader, and provided to Corporate Office. Consideration will be given to the feedback upon review by the representative collecting feedback, the Company's Business Unit Leader and Corporate Office and a response or summary will be included in the next progress report.

Any changes to the Accessibility Plan or the feedback process are published as soon as reasonably possible and notice of any changes are reported to the Accessibility Commissioner. The personal information of anyone who provides feedback remains confidential in accordance with all applicable privacy laws.

5. Alternative Formats

The Accessibility Plan is offered in any of the following formats upon request:

• Print;
• Large print;
• Braille;
• Audio; and
• Electronic.

You can request alternative formats of the Accessibility Plan by contacting:

Human Resources Administrator
780-870-4020
6601-62 Street
Lloydminster, AB T9V 3T6
info@heavycrudehauling.com

The Accessibility Plan will be made available as soon as feasible. In the instance of a request for the plan in a Braille or audio format, it will be provided 45 days after the day the request was received. Requests for other formats will be provided within 15 days after the day the request was received.

6. Priority Areas Under Section 5 of the ACA

i. Employment

The Company understands that improving workplace accessibility and ensuring an accessible recruitment and selection process for applicants with disabilities can contribute to a more diverse and welcoming workplace culture. The Company reviews its practices and procedures to identify, remove, and prevent barriers by developing inclusive employment procedures that support persons with disabilities. Where necessary, accommodations are made during the recruitment and selection stages, and throughout the employment lifecycle. Technological and systemic barriers may exist for employee orientation and training, as such, training and development programs provided by the Company should be reviewed to consider an employee's barriers and abilities. Systemic barriers can be identified with respect to conventions associated with the hiring process.

• The Company will review current job application processes for persons with disabilities who experience barriers and evaluate potential alternatives.
• Review corporate policies, with the support of Corporate Office, that pertain to accommodations for employees and candidates with disabilities and make plans to remove any barriers that are discovered.
• Train those responsible for hiring on the barriers that may exist in the hiring, selection and accommodation process, with support from Corporate Office.
• Review human resource policies for improvements with respect to inclusion and accessibility, with support from Corporate Office.
• Provide online learning on accessibility and inclusiveness to employees.
• Offer training on unconscious bias to human resources employees to improve awareness of accessibility issues.
• Review potential opportunities, where suitable, for establishing mentorship for employees of the Company that are persons with disabilities.

We are committed to accessible recruitment, onboarding, accommodation and employment practices. To support this commitment, we will review our hiring processes to identify and remove accessibility barriers, provide accessibility and unconscious bias training for employees and leaders and continue to improve our accommodation processes and policies. We will also explore mentorship opportunities to better support employees with disabilities and promote an inclusive workplace culture.

ii. The Built Environment

We are committed to improve accessibility in offices and yards by continually assessing our locations for physical barriers and identifying opportunities for improvement. We will continue to review our emergency systems to ensure accessibility through both visual and auditory alerts, while enhancing the accessibility of workspaces and customer facing areas to create a safer and more inclusive environment for everyone.

iii. Information and Communication Technologies (ICT)

Software with accessibility functionality is already utilized by the Company; however, the Company recognizes that systemic barriers exist within technology and presumptions made about its use. The Company wishes to remove barriers and improve accessibility for employees with disabilities, by making such technology more accessible.

iv. Communication other than ICT

The Company acknowledges that content and medium are both important in providing accessible communication to its customers, employees, job applicants, suppliers, and any visitors that access the premises. Communication barriers exist in the content and format of online information, in-person interactions and meetings and presentations. One of the Company's goals is to work towards providing more accessible communications.

v. Procurement of Goods, Services and Facilities

Procurement practices have the potential to be subject to unconscious bias and systemic barriers. It is the Company's goal to consider accessibility in its procurement processes, where possible.

• Review procurement practices and improve, where reasonable and applicable, to consider accessibility in the purchase of goods, services and the use or purchase of facilities.

vi. Design and Delivery of Programs and Services

The Company's primary customers are other businesses, and as such, evaluating the design and delivery of programs and services to the public is not applicable. The Company considers the design and delivery of programs and services as it might apply to its employees and customers.

• Review the accessibility of design and delivery of programs and services with respect to employees and customers with disabilities.

vii. Transportation

The Company's business may provide transportation, logistics services, and/or specialized and industrial services, it does not provide passenger transportation services. As such, barriers to the public and passenger-based services are not considered. The Company's focus is on continually evaluating potential barriers that exist for employees and candidates. Such barriers might include, physical barriers, like ramps, curbs, vehicle and equipment design or lack of vehicle and equipment adaptability. The Company will work towards reducing barriers for employees with disabilities to the extent reasonable, pursuant to applicable occupational health and safety legislation, and other relevant legislation.

• Assess the accommodations available for vehicles and equipment that would be compliant with the Company's occupational health and safety, and other relevant legislative, contractual and other obligations for opportunities for safe implementation.

7. Consultation

• Heavy Crude Hauling has consulted with Bea Fisher Enterprises regarding barriers faced by persons with disabilities.
• Heavy Crude Hauling would focus on what the person could do - different tasks, such as folding and sorting coveralls.
• Create positions that would be available, such as simple data entry or typing, filing, or shredding of documents.
• Provide custodial work, such as cleaning bays or the exterior of trucks.
• Organize recycling materials.

8. Training

Training will be provided across all departments and to contractor drivers and will cover the Accessible Canada Act requirements, disability awareness, the duty to accommodate, and inclusive communication practices. This training is intended to build awareness, strengthen understanding, and support consistent application of accessibility principles across the organization.

9. Reporting and Monitoring

Annual monitoring will be conducted to assess progress on accessibility initiatives, including the tracking of training completion rates, reviewing facility improvements, and analyzing feedback trends. This ongoing monitoring will help identify areas of success and opportunities for continued improvement.

10. Progress Reports and Review Cycle

The Company prepares and submits annual progress reports in years where a full update of the Accessibility Plan is not required. These progress reports include information on feedback received and the actions taken in response, updates on consultation activities, and an overview of progress made in addressing identified barriers. This Accessibility Plan is reviewed every three years, or earlier if required, due to regulatory changes or operational changes.

11. Document Retention

The Company keeps detailed records of the creation, implementation, and updating of the Accessibility Plan and progress reports. The Accessibility Plan and feedback process are retained at www.heavycrudehauling.com for seven years from the publication date. Any feedback provided to the company is retained for seven years from the date it is received. Where necessary, names and personal information of individuals and employees who participated in the feedback process are redacted to ensure confidentiality and privacy. The Company will not retain contact information for any anonymously provided feedback.