BUILDING A SUSTAINABLE BUSINESS-ESG

GOVERNANCE AND INTEGRITY

At ERG Africa, sound governance and unwavering integrity are fundamental to the sustainability of our business and the trust we build with stakeholders. We are committed to acting as a responsible partner, upholding ethical conduct, respecting human rights and engaging transparently with governments, communities, customers and downstream value chain actors.

We embed these commitments through robust compliance systems, a culture of accountability and proactive engagement across our operations and supply chains.

Eurasian Resources Group S.à r.l., a limited liability company governed by the laws of the Grand Duchy of Luxembourg, is the parent company of the organisation.

ERG is 40% owned by the Republic of Kazakhstan, such representation ensures its continued support to the Group. The heirs of Mr Alijan Ibragimov, one of the founder shareholders, own 20.7% of the company’s shares, and Mr Shakhmurat Mutalip owns 39.3% of the company’s shares.

Ethical conduct, compliance and human rights

Our ethical standards go beyond legal compliance and are central to how we operate. This includes rigorous respect for human rights, zero tolerance for corruption and full alignment with global expectations for responsible mineral sourcing.

We implement a risk-based Group Compliance Management System covering compliance risks, including:

  • bribery-icon

    Anti-bribery
    & corruption

  • laundering-icon

    Anti-money
    laundering

  • sanctions-icon

    Sanctions
    compliance

  • data-icon

    Data
    protection

  • rights-icon

    Human
    rights

Through this system, we identify and manage compliance risks, conduct stringent due diligence on counterparties, deliver targeted training and monitor compliance through regular audits. Our Compliance team provides assurance across high-risk jurisdictions and business areas, ensuring that controls are effectively designed, implemented and continuously improved.

ERG Code of Conduct and Compliance Policies

We are dedicated to upholding the highest standards of labour rights, human right and ethical governance.

Our policies reinforce our values and provide clear guidelines for our operations.

ERG Code of Conduct

ERG Supplier Code of Conduct

ERG Human Rights Policy

Anti-Bribery and Anti-Corruption Policy

ERG Human Rights Statements of Commitment

Hotline

The ERG Whistleblowing Hotline is external, 100% confidential and is manned 24 hours a day, seven days a week by an independent company. It provides the opportunity for an employee, either anonymously or by voluntary disclosing his/her identity, to report any concerns or suspicions that another employee, superior or business partner has breached the Code of Conduct.

How to report your concerns

You can raise your concerns:

Hotline
Website

hotline-web-icon

via ERG Hotline website
erg.integrityline.org

Hotline
Phone

Hotline-phone-icon

by phone - all the phone numbers are provided on erg.integrityline.org

Hotline
Email

hotline-web-icon

sending an email to
co********@*rg.net

Training and awareness

Our Compliance Training and Awareness Programme ensures that employees, governance body members, suppliers and business partners understand and apply our ethical standards.

It includes:

- Regular communications from senior leadership

- Mandatory e-learning modules covering:

  • ERG Code of Conduct
  • Anti-bribery and corruption
  • Respect for human rights
  • Conflict of interest
  • Data privacy

- In-person training on:

  • Counterparty Due Diligence (CPDD)
  • Sanctions and AML
  • Human Rights

E-learning for suppliers and subcontractors of the ERG Supplier Code of Conduct

Outlook for cobalt and copper markets for 2017 and beyond
ERGs outlook on global commodity markets

Human Rights

We are committed to upholding human rights in accordance with the ERG Code of Conduct, Human Rights Policy, and Supplier Code of Conduct. Our approach is guided by international best practices, including the UN Guiding Principles on Business and Human Rights and the Voluntary Principles on Security and Human Rights.

We focus on:

  • Identifying, preventing and mitigating adverse human rights impacts
  • Maintaining legitimate and accessible grievance mechanisms
  • Providing targeted training to high-risk roles
  • Ensuring third-party alignment with ERG’s Code of Conduct and Human Rights policy which expresses our zero tolerance to child and forced labour, as well as any form of discrimination

In the DRC, we conduct regular operational-level human rights risk assessments, overseen by Human Rights Working Groups that include regional and Group experts. These inform our risk registers, mitigation strategies, and drive continuous improvement.

Grievance mechanisms for human rights concerns include:

  • A confidential, independently managed ERG Hotline (erg.integrityline.org)
  • Human Resources channels
  • Community engagement structures
  • Site-based grievance platforms

All reported incidents are investigated and addressed in accordance with our policies and legal obligations.

Supplier due diligence

We apply stringent due diligence to suppliers across our value chain. All suppliers must adhere to our Supplier Code of Conduct, which prohibits forced and child labour and requires compliance with ERG’s Human Rights Policy.

We implement additional procedures such as:

  • Detailed audits of labour practices
  • Independent assurance of supplier systems, including ones related to ESG topics
  • Annual audits of labour brokers
  • Targeted action plans and follow-ups on any third-party allegations

Where gaps or incidents are identified, we work with suppliers to address issues through mitigation measures, remediation, or disengagement where necessary.

Government relations and policy engagement

Governments and public institutions are key stakeholders in our operating environment. We engage openly and transparently to support national development priorities and align our operations with public policy goals.

In the DRC, where the Government is a shareholder in some of our assets, our engagements focus on:

  • Future development of selected mining licences
  • Enhancing local economic impact, including through Local Procurement Programmes
  • Supporting energy security through collaborative investments in infrastructure

We uphold the highest ethical standards in all government interactions and remain committed to contributing positively to local, regional and national development across our jurisdictions. In line with the Group Tax Policy, we also follow OECD Transfer Pricing Guidelines and submit Extractive Industries Transparency Initiative (EITI) reports in the DRC, and Zambia as required.

Key highlights

In the DRC, we seek full alignment with the Voluntary Principles on Security and Human Rights at all our operations.

This includes:

  • Awareness campaigns, toolbox talks, and training for employees and contractors
  • Contractual obligations for private security providers to implement the Voluntary Principles
  • Pre-engagement assessments and ongoing audits of providers

These measures ensure that our security arrangements respect human rights and support a safe environment for all stakeholders.

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