Health & Safety Policy

Our commitment

The health and safety of our people, contractors, visitors and neighbours comes before production. Our goal is zero harm: no fatalities, no serious injuries and no occupational illness. Every leader is accountable for safety, and every person has the right and the duty to stop work they believe is unsafe, without fear of reprisal.

Scope

This policy applies to all Kursi Group operations — exploration, mines, beneficiation and processing plants, refineries, laboratories, warehouses, construction projects, vehicles and offices — and to all employees, contractors and visitors.

Legal and other requirements

We comply, as a minimum, with:

• the Nigerian Minerals and Mining Act 2007 and the Nigerian Minerals and Mining Regulations 2011, including the requirements of the Mines Inspectorate;
• the Factories Act (Cap F1, LFN 2004) and the Labour Act;
• the Employee's Compensation Act 2010;
• the Explosives Act (Cap E18, LFN 2004) and its Regulations for the storage, transport and use of explosives;
• the Nigerian Nuclear Safety and Radiation Protection Act 1995 and the requirements of the Nigerian Nuclear Regulatory Authority for minerals containing naturally occurring radioactive material, such as monazite;
• applicable environmental health regulations; and
• the conditions of our mining titles and permits.

Where Nigerian law is silent, we apply recognised international good practice, such as ISO 45001 and the IFC Environmental, Health and Safety Guidelines for Mining.

How we manage health and safety

1. Leadership and accountability. Site managers are responsible for safety performance on their sites; safety objectives form part of every manager's performance review.
2. Hazard identification and risk assessment. We identify hazards and assess risks before work starts, applying the hierarchy of controls — elimination, substitution, engineering controls, administrative controls, then personal protective equipment.
3. Critical controls. We set and verify critical controls for our highest risks: ground and slope stability, mobile equipment and haul roads, working at height, confined spaces, energy isolation, hazardous chemicals (including cyanide and acids used in processing), molten metal and furnaces, explosives, and electrical work.
4. Competence. Everyone receives induction and task-specific training, and only authorised, trained people operate equipment or handle explosives and hazardous substances.
5. Personal protective equipment. Appropriate PPE is provided free of charge and must be worn.
6. Contractors. Contractors are selected partly on safety performance and must meet our standards on our sites.
7. Occupational health. We monitor dust, noise, chemical and radiation exposure, provide health surveillance where needed, and maintain first aid and medical response capability.
8. Emergency preparedness. Each site has a tested emergency response plan, including medical evacuation, fire, chemical release and slope failure.
9. Incident reporting and learning. All incidents and near misses are reported, investigated to find root causes, and the lessons shared across the Group. Reportable incidents are notified to the Mines Inspectorate and other authorities as the law requires.
10. Community safety. We control access to hazardous areas, manage traffic on public roads, secure explosives and chemicals, and communicate with communities about risks.

Artisanal and small-scale mining

Where we buy from artisanal and small-scale producers, we promote safer practices — including eliminating mercury use — and will not buy from sites with unacceptable safety conditions or child labour.

Measuring performance

We track leading and lagging indicators, including lost-time injury frequency, high-potential incidents, critical control verifications and training completion, report them to the Board, and set annual improvement targets.

Responsibilities

• The Board sets this policy and reviews safety performance at every meeting.
• Management provides resources, leads by example and ensures compliance.
• Every employee and contractor works safely, follows procedures, reports hazards and incidents, and stops unsafe work.

This policy is reviewed at least every two years and is displayed at all Kursi sites.