This policy sets out the approach of Single Mine Origin Limited (SMO) to the prevention of bribery and other forms of corruption.

Corruption and bribery are illegal and unethical. They destabilise communities, undermine the rule of law, and pose serious threats to sustained economic progress and the healthy operation of markets. Failure to address the risk of corruption and bribery may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/ or individuals.

We do not engage in corruption, and we never pay bribes, regardless of local custom or practice. SMO’s position on corruption is clear: the offer, payment, authorisation, solicitation and acceptance of bribes and other improper advantages is unacceptable.

This policy applies to all employees, directors and officers, as well as contractors under SMO’s direct supervision.

OUR COMMITMENT

We do not tolerate bribery of any kind, whether to a public official or a private individual.

We never offer, provide or authorise bribes of any kind, including facilitation payments, either directly or indirectly, to a public official or a private individual.

We never request or accept bribes of any kind, either directly or indirectly.

A bribe may be monetary or non-monetary, tangible or intangible. A bribe may take the form of, or be facilitated through:

• payments of money
• gifts or entertainment
• discounts, loans and/or financing given on non-commercial terms
• rebates or kickbacks in relation to services provided
• overpayments to business partners
• use of assets at a discount or free of charge
• sponsorships, charitable contributions and community investments
• political contributions
• employment or internships
• information or assistance

To manage our bribery and corruption risk, we implement a range of procedures and controls relating to dealings with public officials, gifts and entertainment, our business partners, sponsorships and donations, political contributions and record keeping.

We remain alert to corruption and bribery red flags and report them to Senior Management.

PUBLIC OFFICIALS

Dealing with public officials brings a higher risk of corruption or the perception of corruption. We are especially careful when communicating with public officials, exchanging gifts and entertainment with public officials or providing assistance to public officials.

FACILITATION PAYMENTS

In certain jurisdictions, public officials may request small payments, known as facilitation payments to expedite or to secure the performance of a routine governmental action such as issuing permits, licenses, or other official documents; processing government papers such as visas; providing customs clearances; providing police protection; providing utility services; or handling cargo.

Facilitation payments are a form of bribery. We never pay, or authorise the payment of, facilitation payments. If we are asked to make a facilitation payment, we must not pay and we must inform Senior Management immediately.

PAYMENTS MADE UNDER DURESS AND EXTORTION

SMO prioritises the physical safety and well- being of all its employees and contractors. If our welfare or safety is at risk, we take reasonable steps to remove ourselves from danger. In exceptional circumstances, this may include making a payment to a public official to ensure our safety in the situation. We must report any such incident to Senior Management as soon as we are safely able to.

GIFTS AND ENTERTAINMENT

The proper management of the giving and acceptance of gifts and entertainment is key to avoiding the risk they present of actual or perceived bribery or corruption.
We only give or accept gifts and entertainment that are:

• in good faith, occasional, reasonable and appropriate
• a normal business courtesy, and transparent.

We don’t give or accept gifts and entertainment:

• with the intent or prospect of influencing decision-making or other conduct
• with the intent obtaining any improper or undue advantage
• which are reasonably capable of being regarded in any way as a bribe, or
• in the form of cash, which includes pre- paid cards or gift cards which can be redeemed for cash.

SPONSORSHIPS, CHARITABLE CONTRIBUTIONS AND COMMUNITY INVESTMENTS

We never make a sponsorship, charitable contribution or community investment in order to disguise a bribe, or to gain an improper business advantage.

We ensure that, before we enter into sponsorships, community investments or make charitable contributions we conduct risk-based due diligence. We monitor the appropriate use of our funds or resources when required.

POLITICAL CONTRIBUTIONS

We do not seek to influence the political process by improper or corrupt means. To mitigate this risk, we do not contribute any funds or resources towards any political campaign, political party, political candidate or any politically affiliated organisation.

BUSINESS PARTNERS

We expect our business partners to share our commitment to ethical and responsible business practices. We never authorise a business partner to engage in bribery or corruption on our behalf.

To manage our bribery and corruption exposure associated with our business partners, we implement a range of controls and processes including screening, due diligence and monitoring, using a risk-based approach.

We implement additional controls with regards to high-risk business partners, such as business developers, joint venture partners, lobbyists, consultants or advisers interacting with public officials on our behalf. We conduct a detailed risk-based assessment prior to entering into these types of relationships, to enable us to identify, assess and mitigate the corruption risk presented by the engagements. Where appropriate, we also conduct ongoing monitoring and regular review of our high-risk business partner relationships.

MERGERS AND ACQUISITIONS

When considering entering into a merger or acquisition, we conduct risk-based due diligence to understand any bribery and corruption risks associated with the transaction and take steps to address any identified issues. Where we acquire the right to control or operate a business, we promptly implement this policy, associated procedures and controls.

ACCURATE RECORD KEEPING

We ensure all transactions are accurately recorded in SMO’s books and records in accordance with our procedures and reflect the nature and substance of the transaction.

SPEAKING OPENLY

We are each responsible for ensuring that we meet our commitments. SMO expects its employees and contractors to speak openly and raise concerns about possible breaches with their manager, supervisor or via other available reporting channels. SMO takes concerns seriously and handles them promptly.
SMO has zero tolerance for retaliation against anyone who speaks openly about conduct they believe is unethical, illegal or not, even if the concern isn’t substantiated, as long as they have not knowingly made a false report.

CONSEQUENCES

Our policies support our Values and reflect what is important to us. We take breaches of our policies seriously. Depending on the severity of the breach, consequences may range from a warning to termination of employment.