Code of Business Conduct & Ethics

Why we have a Code

Our reputation, our licence to operate and our relationships with communities, governments, customers and partners depend on how each of us behaves. This Code sets out the standards expected of directors, officers, employees, contractors and anyone acting on behalf of Kursi Group Limited or its subsidiaries. Suppliers and business partners are expected to meet equivalent standards.

The Code reflects our values — people, partnership, technology and innovation, integrity and sustainability — and the principles of the Nigerian Code of Corporate Governance 2018 and the Companies and Allied Matters Act 2020.

Obeying the law

We comply with all laws that apply to our business, including the Nigerian Minerals and Mining Act 2007 and its Regulations, environmental, labour, tax, anti-corruption, anti-money-laundering, competition and data protection laws. Where the law and this Code differ, we follow the stricter standard.

Integrity in business

• Bribery and corruption. We never offer, give, request or accept bribes, kickbacks or facilitation payments. See our Anti-Bribery & Corruption Policy.
• Gifts and hospitality. Only modest, infrequent and transparent gifts or hospitality may be given or accepted, never to influence a decision, and always recorded as our procedures require.
• Conflicts of interest. You must avoid situations where personal, family or financial interests conflict, or appear to conflict, with Kursi's interests, and declare any potential conflict in writing so it can be managed.
• Fair competition. We compete on merit and comply with the Federal Competition and Consumer Protection Act 2018. We do not agree prices, divide markets or share competitively sensitive information with competitors.
• Accurate records. Books, records, assays, weights and reports must be complete, accurate and honest. Falsifying records — including the origin, grade or quantity of minerals — is strictly prohibited.
• Money laundering and sanctions. We know our customers and suppliers and do not deal with sanctioned persons or proceeds of crime. See our AML, Sanctions & KYC Policy.

Respect for people

• We provide safe and healthy workplaces and expect everyone to follow safety rules and stop unsafe work. See our Health & Safety Policy.
• We treat everyone with dignity and do not tolerate discrimination, harassment, bullying or abuse. See our Equal Opportunity & Anti-Harassment Policy.
• We respect human rights and never use child labour or forced labour. See our Human Rights & Modern Slavery Policy.
• We respect freedom of association and the right to collective bargaining in accordance with Nigerian law.

Communities and the environment

We engage honestly with host communities, honour our Community Development Agreements, and work to minimise our environmental impact and rehabilitate the land we use. See our Environmental & Rehabilitation Policy and Community Development & Engagement Policy.

Protecting company assets and information

• Use company property, funds, equipment and minerals only for legitimate business purposes, and protect them from theft and misuse.
• Keep confidential information confidential, including after you leave Kursi.
• Protect personal data in line with the Nigeria Data Protection Act 2023 and our Data Protection Compliance Statement.
• Use IT systems securely and in line with our IT and Cybersecurity Policy.

Political activity

Kursi Group does not make contributions to political parties or candidates on behalf of the company. Employees may take part in political activity in a personal capacity, in their own time and without using company resources or implying company endorsement.

Dealing with government

Interactions with regulators and public officials must be honest, transparent and documented. Information provided to authorities — including production, royalty and export data reported to the Ministry of Solid Minerals Development, the Nigerian Extractive Industries Transparency Initiative (NEITI) and tax authorities — must be accurate and timely.

Speaking up

If you see or suspect a breach of this Code or the law, you must report it. You can speak to your manager, Legal & Compliance, or use our confidential speak-up channel. Retaliation against anyone who raises a concern in good faith is itself a serious breach of this Code.

Consequences

Breaches of this Code may lead to disciplinary action up to and including dismissal, termination of contracts, and referral to the authorities.

Responsibility

The Board approves this Code and oversees its implementation. Legal & Compliance maintains it, provides training and advice, and reviews it at least every two years.