ASC 606: Principal vs. Agent

Company response: , describe how you assessed the indicators outlined in ASC 606‑10‑55‑36 through 55‑40. Response: We acknowledge the Staff’s comment and have evaluated whether we act as principal or agent in our carbon credit transactions under ASC 606‑10‑55‑36 through 55‑40. In most of our carbon credit sales, we conclude that we are the principal because we control the credits before they are transferred to the customer. Our assessment is based on the following indicators: · Control of the asset before transfer (ASC 606‑10‑55‑37): We obtain control of the credits either by (i) originating them through our project arrangements, or (ii) purchasing them from third parties and holding them in our registry… response letter →

Company response: We acknowledge the Staff’s comment. We recognize that ASC 606‑10‑50‑8 through 50‑10 requires disclosure of the opening and closing balances of contract liabilities (deferred revenue), significant changes in those balances, and information about the timing of revenue recognition for remaining performance obligations. Below is a roll forward as requested. FY2025 (Year Ended May 31, 2025) Q2 FY2026 (Six Months Ended Nov 30, 2025) Opening balance $ - $ 3,864,080 Heidelberg deferred revenue $ 928,042 $ (928,042 ) DevvStream deferred revenue $ 2,936,038 $ - Other deferred revenue $ - $ 26,764 Currency translation $ - $ (47,901 ) Closing balance $ 3,864,080 $ 2,914,901 Current portion $ 3,864,080… response letter →

Company response: addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40. Response: We have expanded our disclosures in the Summary of Significant Accounting Policies - Revenue Recognition in footnote 2 to Notes to Unaudited Condensed Consolidated Financial Statements and in Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Critical Accounting Policies End estimates in our Form 10-Q for the first fiscal quarter ended November 30, 2025 filed on January 14, 2026, and will continue disclosing them plus the new language in brackets below in our future filings. We added the following disclosures: Gross Versus Net Revenue ASC 606… response letter →

Company response: The Company respectfully clarifies that the previously disclosed “gross amount of revenue” was intended as an operational metric. In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with deletions shown in strikethrough showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. “ NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS … 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES … (s) Revenue recognition … 5 CPaaS revenues The Company accounts for revenue from… response letter →