Sustainability Policy

Sustainability Is Integral To Our Activities In Kazakhstan And North Macedonia

Our Sustainability Director, Nick Shirley, coordinates all site-based health and safety, environment and social activities with regular reporting to London. The Sustainability Committee meets on a quarterly basis to review sustainability related statistics and issues.

Whilst the focus of sustainability activity within the CAML Group is clearly at its operational sites at Kounrad and Sasa, the management team endeavours to ensure that the Group as a whole also adheres to high sustainability standards.

Mission Statement

Central Asia Metals (CAML) believes sustainability to be essential and integral to our business strategy, our stakeholders and our shareholders.

We will operate our projects in line with leading standards of health, safety and environmental management and engage with our stakeholders in a fair, open, informed and transparent manner. We will operate in full compliance with the laws and regulations of the countries in which we are located, and work towards compliance with best practice international standards.

We will regularly review and report on progress and ensure that this Policy remains relevant to the needs of our stakeholders. We will also conduct regular audits of our operations to ensure compliance with these principles, policies and standards.

Further, we will strive for continual improvement by having executive and non-executive review of our sustainability performance. This performance will be communicated in a transparent manner to all relevant internal and external stakeholders.

Health, Safety and Wellbeing

Aiming to provide a safe and healthy working environment for our employees,
contractors, consultants, visitors, and aiming for zero harm in the workplace by committing to:

Identifying the potential for accidents / incidents and conducting investigations to identify root causes and take remedial action to prevent them;
Identifying, assessing and eliminating, as far as commercially reasonable, potential risks associated with our operation to employees, contractors, the environment and communities;
Providing appropriate health and safety induction and training for all new employees and contractors. Ensuring that all employees, contractors and partners receive the appropriate ongoing training and fully and clearly understand our health and safety standards and
requirements;
Ensuring the health and safety of communities affected by our operations;
Preparing for, and responding quickly to, any incidents or emergencies, and improving and upgrading our health and safety management system in response to such incidents to prevent recurrences;
Regularly setting and reviewing objectives and targets for improved Health and Safety performance; complying with applicable and relevant legal and regulatory requirements, whilst seeking to achieve standards of international best practice;
Developing our employees in all areas, giving them the knowledge and skills to enable them to perform their jobs in a safe manner;
Developing effective Occupational and Community Health and Safety policies, procedures and guidelines.

Our People

Providing a healthy and safe workplace in accordance with labour legislation of the country within which we operate and in accordance with best international standards by:

Ensuring all employees are provided with comprehensive task oriented safe work practice training;
Not tolerating any discrimination, harassment or physical assault in the workplace;
Basing employment on the principle of equal opportunity and fair treatment with no discrimination;
Providing a complaint and grievance mechanism for internal and external use;
Supporting equal opportunities through our operations;
Treating all employees and contractors fairly;
Selecting employees for employment based on their qualifications, experience and past performance in a transparent manner;
Operating a strict zero drug and alcohol policy in the workplace;
Providing appropriate employee training, and opportunities for continuing development;
Not employing forced or child labour and using commercially reasonable means to ensure contractors and suppliers address these issues;
Allowing employees freedom of association to join legal and non-prohibited organisations of their own choosing;
Ensuring that working conditions and terms of employment are clearly documented and communicated to all employees;
Foster technical links with local educational centres and, where possible, offer practical development training at our operations for local students.

Environment

Minimising the impact to the natural environment within which the Company operates. To achieve this we will:

Operate as responsible stewards in compliance with local legislative requirements and strive to achieve international standards of best practice;
Eliminate, negate, mitigate or remediate the environmental impacts of our activities in accordance with local legislative requirements;
Improve efficiency where possible in the use of raw materials, energy and natural resources;
Identify, monitor and where possible minimise emissions;
Ensure any discharges to the natural environment attain the relevant environmental standards;
Minimise impacts on biodiversity and ecosystems;
Maximise operational efficiency and enhance waste management through the promotion of recycling and reuse;
Ensure diligence in responding to environmental incidents;
Develop and maintain an Emergency Response Plan for the protection of our operating environment and the prevention of pollution;
Decommission, reclaim and rehabilitate our sites in a timely manner in line with local legislative requirements;
Provide environmental awareness training for all employees and contractors so that they can conduct their tasks and duties with a full comprehension of the environmental issues on site;
Regularly set and review objectives and targets for improved environmental performance;
Operate a formal Environment Management System (‘EMS’).

Our Communities

Assisting the social and economic development of communities associated with our operations. We will achieve this by:

Identifying all stakeholders;
Respecting local cultures and community rights, and aiming to preserve or develop these, where possible, through our operations;
Engaging regularly with identified stakeholders throughout the life of our project, to build trust and foster proactive community engagement;
Liaising with national and local state authorities, community leaders, Non-Governmental Organisations, and any other interested parties to identify and implement projects to benefit local communities;
Minimising adverse effects on local communities;
Setting aside funds for social development initiatives to benefit communities associated with our projects;
Developing a social management system and mechanism through which community issues can be raised and addressed.

Governance & Stewardship

The Company will adhere to the highest levels of corporate governance by:

Conducting business ethically and in accordance with Company policies
Reporting transparently our sustainability performance and impacts
Ensuring compliance with all appropriate guidance and legislation on corporate governance
Ensuring that the company obtains and maintains all of the necessary permits and licences for its overseas operations
Compliance with the applicable mining, environmental and other relevant laws in its countries of operation
Maintaining a comprehensive risk management process in line with best practice that identifies and mitigates where possible all material group risks
Upholding the human rights of all individuals impacted by our operations including employees, contractors and external stakeholders
Ensuring an ethical supply chain

Application and Accountability

The above policy applies to Central Asia Metals plc and its subsidiary companies. CAML’s Sustainability Director has overall responsibility for the implementation and enforcement of this policy.

Senior executives and senior management within CAML and its overseas subsidiaries are accountable for the implementation and adherence of the policy. This policy will be communicated to our employees, contractors and relevant stakeholders. All employees and contractors are responsible for conducting their work in conformance with the above policy