Human Rights & Modern Slavery Policy

Our commitment

Kursi Group respects internationally recognised human rights, including those set out in the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the African Charter on Human and Peoples' Rights, and the fundamental rights guaranteed by the Constitution of the Federal Republic of Nigeria 1999. We follow the UN Guiding Principles on Business and Human Rights: we avoid causing or contributing to adverse human-rights impacts, address impacts when they occur, and seek to prevent impacts linked to our business relationships.

Legal framework

Alongside the Constitution, we comply with the Labour Act, the Child's Rights Act 2003 and state child-rights laws, the Trafficking in Persons (Prohibition) Enforcement and Administration Act 2015, the Discrimination Against Persons with Disabilities (Prohibition) Act 2018, and other applicable law.

Our standards

• No child labour. We do not employ anyone under 18 in mining, processing or other hazardous work, and we do not tolerate child labour anywhere in our supply chain.
• No forced labour or trafficking. All work is voluntary. We do not retain identity documents, charge recruitment fees, use debt bondage, or restrict workers' freedom of movement.
• Fair wages and hours. We pay at least the national minimum wage, pay on time, and respect legal limits on working hours, rest days and overtime.
• Freedom of association. We respect workers' rights to join trade unions and bargain collectively in accordance with Nigerian law.
• Non-discrimination and dignity. See our Equal Opportunity & Anti-Harassment Policy.
• Safe and healthy work. See our Health & Safety Policy.
• Communities and land. We respect the rights of host communities, consult them meaningfully, and provide fair compensation for land access. See our Community Development & Engagement Policy.
• Security and human rights. Our security arrangements follow the Voluntary Principles on Security and Human Rights. Private security providers are vetted and trained, force is used only when strictly necessary and proportionate, and any allegation of abuse is investigated and reported to the authorities.
• Privacy. We protect personal data in line with the Nigeria Data Protection Act 2023.

Due diligence

We assess human-rights risks in our operations and supply chain — including through our supplier onboarding and responsible-sourcing due diligence — act on what we find, track the effectiveness of our actions, and communicate how we address impacts. Higher-risk areas include artisanal and small-scale mineral supply, contractor labour, recruitment agencies and security provision.

Suppliers and contractors

We expect suppliers, contractors and business partners to meet these standards, include them in our contracts, and may audit compliance. We will work with partners to remedy problems where possible, and will end relationships where serious abuses are not addressed.

Remedy and grievances

Anyone affected by our operations can raise concerns through our community grievance mechanism or our confidential speak-up channel. Where we have caused or contributed to harm, we will provide for or cooperate in remediation.

Responsibility and review

The Board oversees this policy. Legal & Compliance coordinates its implementation with HR, Community Relations, Security and Procurement. It is reviewed at least every two years.