Responsible Sourcing & Supply Chain Due Diligence Policy

Purpose

Kursi Group mines, buys, processes and sells minerals including gold, tin, tantalum (tantalite and columbite) and other metals. We are committed to ensuring that the minerals we handle are produced and traded lawfully and responsibly, do not finance conflict or contribute to serious human-rights abuses, and can be traced to their source.

This policy is consistent with the model supply chain policy in Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the Responsible Jewellery Council (RJC) Code of Practices, the requirements of the EU Conflict Minerals Regulation (EU) 2017/821 and Section 1502 of the US Dodd-Frank Act as they affect our customers, and Nigerian law.

Scope

This policy applies to all minerals mined by Kursi Group companies and all minerals bought by Kursi Trades & Services, Kursi Ore and other Group companies from third parties, including licensed artisanal and small-scale miners, cooperatives and aggregators.

Our commitments

We will not tolerate, profit from, contribute to, assist with or facilitate:

• any form of torture or cruel, inhuman or degrading treatment;
• any form of forced or compulsory labour;
• the worst forms of child labour;
• other gross human-rights violations, such as widespread sexual violence;
• war crimes or other serious violations of international humanitarian law.

We will not provide direct or indirect support to non-state armed groups, and we will not tolerate illegal control of mine sites, transport routes or trading points by public or private security forces, or illegal taxation or extortion by them.

We will not tolerate bribery, fraudulent misrepresentation of the origin of minerals, money laundering, or non-payment of taxes, fees and royalties due to the government.

We also will not buy minerals from illegal mining, from protected areas, or from sites using mercury in processing where alternatives are available.

Due diligence — the OECD five steps

1. Strong management systems. This policy is approved by senior management; a responsible-sourcing function in Kursi Trades & Services implements it; suppliers are bound by it contractually; and we keep records for at least five years.
2. Identify and assess risk. We collect and verify information on every supplier — company and beneficial ownership, valid mineral titles or buying licences from the Mining Cadastre Office, mine of origin, transport routes and payment of royalties — and assess red flags by location, supplier and transaction.
3. Respond to risk. We have a risk-management plan. Depending on the risk, we continue trading while risks are mitigated, suspend trade temporarily, or disengage. We disengage immediately where we identify a risk of the most serious abuses listed above or of support to non-state armed groups.
4. Independent audit. Where applicable, our refining and trading activities are subject to independent third-party audit against recognised standards, including RJC certification requirements.
5. Report. We report annually on our supply chain due diligence.

Supporting artisanal and small-scale miners

Formalising artisanal and small-scale mining is one of the most effective ways to reduce illegal mining and improve conditions. Our buying centres offer licensed small-scale producers fair weighing, transparent assay and prompt payment, and we support improvements in safety, environmental practice and the elimination of child labour and mercury.

Raising concerns

Anyone may raise a concern about our supply chain through our speak-up channel or by emailing info@kursigroup.com. Concerns are assessed and, where appropriate, investigated.

Review

This policy is reviewed at least annually.