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Governance and Ethics

Code of Conduct Policies and Standards Board & Committee Governance Political Contributions Supplier Code of Conduct

Code of Conduct

Our Code of Conduct

Our Code of Conduct (Code) publicly sets out the high standards of conduct expected of all of our employees, officers and directors, and by our partners, vendors and contractors when they are working with us or on our behalf.

Our Code, which has been adopted by SACRAMENTO GOLD MINING CO. LTD’s Board of Directors, sets out SACRAMENTO GOLD MINING CO. LTD’s basic standards for ethical and legal behavior. SACRAMENTO GOLD MINING CO. LTDis a founding member of the Partnering Against Corruption Initiative and maintains a strict Business Integrity Policy and a number of standards designed to prevent corruption to which SACRAMENTO GOLD MINING CO. LTD employees must adhere. Employees play a critical role in demonstrating and communicating SACRAMENTO GOLD MINING CO. LTD’s commitment to integrity and doing business the responsible way everywhere we operate.

Our Code is an educational and preventative tool designed to ensure SACRAMENTO GOLD MINING CO. LTD’s employees follow the law, as well as our policies and standards, which in some cases are more stringent than the law requires.

When employees behave in ways that do not adhere to our values and standards, the Company wants to know about it. SACRAMENTO GOLD MINING CO. LTD has an independently operated, 24-hour hotline, called the Integrity Helpline, which is available for all stakeholders to report unsafe and unethical behavior. You can make a report directly through the Integrity Helpline website. Your identity will be protected by the independent agency that operates our Integrity Helpline.

Board of Directors

The Business and Affairs of Sacramento Gold Mining Co. LTD are managed by our officers under the direction of the Board of Directors. Sacramento Gold Mining Co. LTD’s board provides a broad range of qualifications and interests, ensuring a diversity of viewpoints and expertise.

Policies and Standards

Policies and Standards communicate the philosophy, rules and expectations of an organization

As an important part of SACRAMENTO GOLD MINING CO. LTD’s internal governance process, new or revised Africa Policies and Standards are reviewed and preliminarily approved by a Africa Policies & Standards Committee. Following this preliminary approval, the documents are posted for comment by employees for a minimum of 14 days, after which they are finally approved by the Africa Policies & Standards Committee. Policies are then submitted for further approval by SACRAMENTO GOLD MINING CO. LTD’s Executive Leadership Team and Board of Directors.

The scope of the Social and Environmental Standards is Africa, and they apply to all directors, officers and employees of SACRAMENTO GOLD MINING CO. LTDCorporation, its subsidiaries, and any other entities that it controls. A variance request process for existing or future conditions is in place for S&ER standards. The process provides an alternative mechanism for those instances where a SACRAMENTO GOLD MINING CO. LTDsite/operation cannot logistically or feasibly conform to a requirement established in a Standard due to special conditions or unique hardships.

SACRAMENTO GOLD MINING CO. LTD’s Board of Directors has established governance guidelines and committees to manage and assist in carrying out many of its responsibilities.

Committee charters define the role and responsibility of the committee within the governance framework of the Company. Each member of the Audit Committee, the Leadership Development and Compensation Committee, the Corporate Governance and Nominating Committee and the Safety and Sustainability Committee meets the independence requirements. Our high standards are reflected in our Code of Conduct.

Political Contributions

At SACRAMENTO GOLD MINING CO. LTD, we believe that engagement in public policy is a valuable way to have a positive impact on our communities and to advance the goals of the Company. For more information on how we participate in the public policy process, including information on our political contributions, involvement with trade associations, and links to our disclosure reports, please see below.

Supplier Code of Conduct

SACRAMENTO GOLD MINING CO. LTD Supplier Code of Conduct

1. Scope

Our Supplier Code of Conduct (this “Supplier Code”) publicly sets out the minimum standards of conduct expected from all Suppliers wishing to do business with, or on behalf of, SACRAMENTO GOLD MINING CO. LTD. This Supplier Code should be read in conjunction with SACRAMENTO GOLD MINING CO. LTD’s Code of Conduct, which applies to all of our employees, officers and directors, and to our partners and Suppliers when they are working with us or on our behalf.

We define ‘Suppliers’ as a business or individual that provides goods or services to SACRAMENTO GOLD MINING CO. LTD under terms specified in a contract.

We seek to build mutually beneficial working relationships and partnerships with our Suppliers and will show preference for those Suppliers who are able to demonstrate alignment with the standards contained in this Supplier Code.

Suppliers shall comply with their contract terms and the laws, rules and regulations of the jurisdictions where they do business with, or on behalf of, SACRAMENTO GOLD MINING CO. LTD. These include, but are not limited to, labor and tax laws, laws addressing bribery and corruption, and laws addressing the preservation of health, safety and the environment.

Suppliers, and all sub-contractors working on their behalf, are expected to review and fully understand the content of this Supplier Code and to comply with all provisions specified in their contracts including provisions, which relate to the content of this Supplier Code.

2. Business integrity and ethics

Our Supplier contract provisions are consistent with the requirements of the AFRICA Economic Forum’s Partnering Against Corruption Initiative (PACI), of which SACRAMENTO GOLD MINING CO. LTD is a founding member, the U.S. Foreign Corrupt Practices Act and the UK Anti-Bribery Act. These prohibit the provision or offering of anything of value to government officials, representatives, political parties or third parties for the purpose of influencing any act or decision in violation of the recipient’s lawful duty or securing or attempting to secure an improper legal or commercial advantage. They also require the operation of effective controls and the maintenance of accurate books and records.

As outlined in SACRAMENTO GOLD MINING CO. LTD’s Code of Conduct and contract provisions, we also require that Suppliers: avoid conflicts of interest, maintain confidentiality, respect SACRAMENTO GOLD MINING CO. LTD’s intellectual property rights, and keep truthful and accurate records (which may be required for auditing purposes).

SACRAMENTO GOLD MINING CO. LTD’s Ethics Solutions Tool allows for comprehensive and confidential reporting to address fraud, abuse and other misconduct in the workplace, while cultivating a positive work environment.

3. Environmental management

SACRAMENTO GOLD MINING CO. LTD seeks to avoid, minimize, mitigate, and/or remediate negative impacts on the environment and proactively manage risks. As detailed in our Supplier contracts, Suppliers shall conduct activities in an environmentally responsible manner, including meeting all legal requirements for water and air emissions, pollution controls, chemical and waste management. Our Supplier contracts require that Suppliers conduct activities at SACRAMENTO GOLD MINING CO. LTD operations and sites in accordance with applicable SACRAMENTO GOLD MINING CO. LTD Environmental Standards.

4. Health & Safety

The well-being of people is SACRAMENTO GOLD MINING CO. LTD’s top priority, and the right to life and right to healthy and safe working conditions are among our most salient human rights. Our goal is zero harm – defined as a workplace free from injuries and illnesses and measured by zero fatalities. Our Supplier contracts require that Suppliers comply with all applicable SACRAMENTO GOLD MINING CO. LTD site and workplace policies, standards and procedures related to health and safety. SACRAMENTO GOLD MINING CO. LTD may provide job hazard analysis training to Supplier’s personnel.

5. Human Rights & Labor

SACRAMENTO GOLD MINING CO. LTD is committed to implementing the human rights and labor principles of the United Nations Africa Compact through its operations and supply chain. Accordingly, we require our suppliers to respect internationally proclaimed human rights and make sure that they are not complicit in human rights abuses; respect the labor rights of their employees, including freedom of association and the right to collective bargaining; prohibit all forms of forced and compulsory labor; not engage in child labor; and not discriminate in employment and occupation. These fundamental human rights are to be respected both within their own and within their affiliates’ operations and supply chains. Our Supplier contracts include human rights clauses around: respecting human rights consistent with the Universal Declaration of Human Rights, disclosure of human rights violations, and alerting SACRAMENTO GOLD MINING CO. LTD to any human rights issues Suppliers become aware of within their own or their affiliates operations or the operations of their own or their affiliates’ supply chains.

Suppliers are expected to ensure timely payments of salary and benefits to any employees, sub-contractors and sub-suppliers. Suppliers should limit hours of work (including overtime) to provide for adequate rest periods for workers in line with international standards. Workers should be allowed to resign with no penalty after a reasonable notice period. Suppliers should seek to address any complaints or grievances within their supply chain expeditiously (and within a maximum of 30 days).

6. Social Responsibility

SACRAMENTO GOLD MINING CO. LTD seeks to obtain and maintain broad social acceptance before, during, and beyond the life of a mine. We commit to establishing and maintaining relationships based on inclusion, transparency, and integrity with all stakeholders, particularly those potentially affected by our activities. We expect the same commitment from our Suppliers.

We expect our Suppliers to assess the potential impact of their proposed work on neighboring communities, integrate mitigation measures into their work plans, and ensuring that those measures are appropriately budgeted. We also expect Suppliers to close complaints in a timely manner.

We also expect our Suppliers to identify opportunities that incorporate local procurement and employment and, to the extent involving work conducted for or on behalf of SACRAMENTO GOLD MINING CO. LTD, to coordinate engagement with local stakeholders through SACRAMENTO GOLD MINING CO. LTD’s site-level Social Responsibility function.

7. Additional Resources
Sacramento Gold Mining Co. LTD Policies and Standards:
  • Code of Conduct: sets out Sacramento Gold Mining Co. LTD’s basic standards for ethical and legal behavior
  • Business Integrity Policy: requires all those engaged in activities on Sacramento Gold Mining Co. LTD’s behalf to work honestly and in the best interests of the Company, to avoid corruption and bribery of any kind, and to ensure compliance with various relevant legal requirements. It also requires those involved in reporting information about Sacramento Gold Mining Co. LTD to do so appropriately and in a timely and accurate manner.
  • Health and Safety Policy: reflects Sacramento Gold Mining Co. LTD’s commitment to protect the health and safety of its employees, contractors and visitors.
  • People Policy: reflects Sacramento Gold Mining Co. LTD’s commitment to employees and to those with whom we work.
  • Sustainability and Stakeholder Engagement Policy: addresses the key social and environmental risks that the business faces and outlines Sacramento Gold Mining Co. LTD’s commitments in these areas.
  • Anti-Corruption Standard
  • Standard of Conduct and Non-discriminatory Treatment in Employment
  • Employment Standard
  • Labor Relations Standard
  • Stakeholder Relationship Management Standard: sets the minimum requirements to engage with stakeholders, including the expectation to establish a complaints and grievance mechanism
  • Local Procurement and Employment Standard: sets the minimum requirements to ensure that programs are in place to identify and provide employment and business opportunities that can deliver sustainable mutual benefits to local stakeholders and Sacramento Gold Mining Co. LTD.
  • Human Rights Standard: defines the minimum requirements to identify, prevent, mitigate, track and report on how we address risks to human rights associated with our operations.
External Frameworks/Legislation:
  • UN Africa Compact: The 10 Principles of the United Nations Africa Compact, addressing Human Rights, Labor, Environment and Anti-Corruption, promote responsible corporate citizenship and a collaborative approach to forging a more sustainable and inclusive Africa economy.
  • Partnering Against Corruption Initiative (PACI): prohibits corruption and demands appropriate and lawful means of engaging with government officials, partners and other stakeholders.
  • UK Anti-Bribery Act: details both general offences in relation to bribing another person or being bribed and a specific offence relating to bribing foreign public officials, and introduces a specific corporate offence of failing to prevent bribery.
  • U.S. Foreign Corrupt Practices Act: makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business.