Policies and Standards

  • Home
  • Policies and Standards

1. Introduction

Meghman Canada Mining Group Inc. is committed to operating with honesty, fairness, and transparency in all aspects of its business. As a trusted provider of advanced mining machinery and equipment solutions, our reputation is built on integrity. This policy sets out our principles and expectations for ethical behavior in all dealings—internal and external—covering excavation, ore transport, drilling, blasting, and site preparation.

This Business Integrity Policy (the “Policy”) reinforces our dedication to ethical conduct, ensuring that all actions align with our core values and contribute to sustainable development in the mining industry. By adhering to this Policy, we protect our stakeholders, including employees, contractors, suppliers, customers, communities, and shareholders, while complying with applicable laws and regulations.

2. Purpose

The purpose of this Policy is to:

  1. Define standards for honest, fair, and transparent business practices.
  2. Prevent corruption, bribery, and other unethical behaviors that could harm our operations or reputation.
  3. Provide guidance on identifying and managing integrity risks in mining-related activities, such as procurement of equipment for drilling and blasting, supplier contracts for ore transport, and regulatory approvals for site preparation.
  4. Promote a culture of accountability where ethical decision-making is prioritized.
  5. Ensure compliance with Canadian anti-corruption laws, including the Corruption of Foreign Public Officials Act (CFPOA) and relevant sections of the Criminal Code (e.g., Sections 119-125 on bribery and influence peddling), as well as international standards.

This Policy supports our broader Code of Conduct and is aligned with global initiatives like the Extractive Industries Transparency Initiative (EITI) and principles from organizations such as Transparency International.

3. Scope and Applicability

This Policy applies to:

  1. All employees, officers, directors, and temporary workers of Meghman Canada Mining Group Inc. and its subsidiaries.
  2. Third parties acting on our behalf, including contractors, suppliers, joint venture partners, agents, and consultants involved in our mining operations.
  3. All business activities, both domestic and international, with heightened vigilance in high-risk areas such as interactions with government officials for mining permits or dealings in regions prone to corruption.

Joint ventures and associates are expected to adopt equivalent standards. Where local laws conflict with this Policy, the stricter requirement prevails. Exceptions must be approved in writing by the Chief Compliance Officer.

4. Definitions

  1. Bribery: Offering, promising, giving, requesting, or accepting anything of value to improperly influence an action or decision.
  2. Corruption: Abuse of entrusted power for private gain, encompassing bribery, fraud, extortion, conflicts of interest, and misuse of company assets.
  3. Facilitation Payment: Small, unofficial payments to expedite routine government actions (e.g., processing permits for site preparation).
  4. Conflict of Interest: A situation where personal interests (financial, familial, or otherwise) could interfere with or appear to interfere with company duties.
  5. Government Official: Any person acting in an official capacity for a government, agency, or public enterprise, including regulators overseeing mining safety or environmental compliance.
  6. Third Party: Any external entity or individual engaged in business with the company, such as equipment suppliers or transport contractors.

5. Key Principles and Guidelines

Meghman Canada Mining Group Inc. expects all personnel to uphold the following principles in daily operations.

5.1 Anti-Bribery and Anti-Corruption

We maintain a zero-tolerance stance on bribery and corruption in all forms, whether direct or through intermediaries.

  1. Prohibit offering or accepting bribes to secure contracts, obtain regulatory approvals (e.g., for blasting operations), or gain unfair advantages in supplier negotiations.
  2. Avoid corrupt practices in mining activities, such as falsifying records for ore transport or manipulating bids for excavation equipment.
  3. Comply with the CFPOA, which prohibits bribing foreign public officials to obtain business advantages, and Criminal Code provisions against domestic bribery.
  4. Conduct risk assessments for high-risk scenarios, such as international equipment procurement or site preparation in foreign jurisdictions.

5.2 Conflicts of Interest

Employees must avoid situations where personal interests conflict with company interests.

  1. Disclose any potential conflicts, such as family members working for suppliers of drilling machinery or personal investments in competing mining firms.
  2. Refrain from hiring, supervising, or influencing decisions involving relatives or close associates without approval.
  3. Report conflicts to your line manager or the Compliance Department immediately via the Conflicts Register.

5.3 Gifts, Entertainment, and Hospitality

Gifts and hospitality must not influence business decisions or create obligations.

  1. Limit gifts to modest values (e.g., under CAD $100) and ensure they are appropriate and transparent.
  2. Prohibit gifts to government officials without pre-approval from Legal and Compliance, especially during permit applications for blasting or site preparation.
  3. Record all gifts over CAD $50 in the Gift Registry, including entertainment like meals with suppliers.
  4. Decline gifts that could appear to influence judgments, such as during tender processes for ore transport contracts.

5.4 Facilitation Payments

Facilitation payments are prohibited, except in cases of immediate threat to personal safety (e.g., extortion at a mining site checkpoint).

  1. Any such payment must be reported immediately to Compliance and recorded transparently.
  2. Train employees on alternatives, such as escalating to management or using official channels for routine approvals.

5.5 Political and Charitable Contributions

  1. Prohibit political donations to parties, candidates, or officials, directly or indirectly, to avoid perceptions of influence.
  2. Charitable contributions must support legitimate community development (e.g., in mining-affected areas) and not benefit specific officials or disguise bribes.
  3. Require pre-approval for all donations and sponsorships, ensuring alignment with sustainable development goals.

5.6 Fair Competition

Comply with antitrust laws to promote fair marketplace behavior.

  1. Avoid anti-competitive practices, such as price-fixing with equipment suppliers or sharing sensitive information with competitors at industry events.
  2. Limit interactions with competitors and seek Legal approval for joint ventures or information exchanges.

5.7 Confidentiality and Protection of Information

  1. Protect confidential information, including proprietary data on mining technologies or site preparation plans.
  2. Use personal information only for legitimate purposes (e.g., HR or safety compliance) and comply with privacy laws like PIPEDA.
  3. Prohibit insider trading based on non-public information about company operations.

5.8 Accurate Record-Keeping

  1. Maintain truthful, accurate, and complete records for all transactions, including financial reports, safety logs for drilling, and environmental compliance for blasting.
  2. Prohibit falsification or destruction of records, especially those relevant to audits or legal proceedings.

5.9 Interactions with Government Officials

  1. Engage transparently and ethically with officials, avoiding offers of value to expedite mining permits or inspections.
  2. Lobbying must be lawful, documented, and aligned with company interests.

5.10 Third-Party Due Diligence

  1. Screen third parties (e.g., contractors for ore transport) for integrity risks before engagement.
  2. Include anti-corruption clauses in contracts and monitor performance.
  3. Terminate relationships with third parties involved in unethical practices.

6. Compliance with Laws

Meghman Canada Mining Group Inc. complies with all applicable laws, including:

  1. The CFPOA for foreign bribery.
  2. Criminal Code provisions on corruption and influence peddling.
  3. International standards promoted by Global Affairs Canada for anti-bribery in trade. Personnel must report suspected violations of sanctions, export controls, or other regulations relevant to mining equipment trade.

7. Reporting Concerns

We encourage reporting of integrity concerns without fear of retaliation.

  1. Use the confidential whistleblower hotline (Speak Up Line: 1-800-XXX-XXXX or online portal) for anonymous reports.
  2. Protect whistleblowers from adverse actions; violations of this protection result in disciplinary measures.
  3. Investigate all reports promptly and fairly through the Compliance Department.

8. Training and Awareness

  1. Provide mandatory training on this Policy during onboarding and annually, with specialized sessions for high-risk roles (e.g., procurement for excavation equipment).
  2. Promote awareness through workshops, communications, and leadership examples.

9. Monitoring and Enforcement

  1. The Compliance Department oversees implementation, conducting audits and risk assessments.
  2. Use a “Three Lines of Defense” model: operational controls, oversight by Compliance, and independent audits.
  3. Review the Policy annually or as needed to address emerging risks in the mining sector.

10. Consequences of Violations

Violations may result in:

  1. Disciplinary action, up to termination.
  2. Legal consequences, including referral to authorities for criminal prosecution.
  3. Contract termination for third parties.

11. Approval and Review

This Policy is approved by the Board of Directors and effective as of [Insert Date]. It will be reviewed annually by the Chief Executive Officer and Chief Compliance Officer.

For questions, contact the Compliance Department at compliance@meghmancanada.com.

By adhering to this Policy, we ensure Meghman Canada Mining Group Inc. remains a leader in ethical mining practices, fostering trust and long-term success.

1. Purpose

Meghman Canada Mining Group Inc. recognizes that our success is deeply tied to fostering strong, respectful, and mutually beneficial relationships with the communities in the regions where we operate. This Community Policy outlines our commitment to responsible mining practices that prioritize local development, environmental stewardship, and sustainable benefits for communities impacted by our excavation, ore transport, drilling, blasting, and site preparation activities.

2. Scope

This policy applies to all employees, contractors, and partners involved in Meghman Canada Mining Group Inc.’s operations, including but not limited to exploration, development, and operational activities across all project sites in Canada. It extends to all communities within the vicinity of our operations, including Indigenous and non-Indigenous communities.

3. Core Principles

Our community engagement and operations are guided by the following principles:

  1. Respect: We honor the rights, cultures, traditions, and values of local communities, including Indigenous peoples, and strive to build trust through transparent and inclusive engagement.
  2. Sustainability: We aim to create long-term, positive impacts through economic opportunities, environmental protection, and community development initiatives.
  3. Accountability: We hold ourselves accountable for minimizing negative impacts and maximizing benefits to communities through responsible mining practices.
  4. Collaboration: We actively seek partnerships with local communities to co-create solutions that address their needs and aspirations.

4. Commitments

To uphold these principles, Meghman Canada Mining Group Inc. commits to the following:

4.1 Community Engagement

    1. Engage with communities early and throughout the project lifecycle, from exploration to closure, to understand their needs, concerns, and priorities.
    2. Establish formal communication channels, such as community liaison committees, to facilitate ongoing dialogue and feedback.
    3. Respect and incorporate Indigenous knowledge, rights, and traditional land use in our planning and operations, in alignment with applicable laws and agreements.
    4. Provide accessible, transparent, and timely information about our activities, including potential impacts and mitigation measures.

4.2 Environmental Stewardship

  1. Minimize environmental impacts from excavation, ore transport, drilling, blasting, and site preparation through adherence to best practices and regulatory standards.
  2. Implement robust environmental monitoring programs to track and address impacts on air, water, soil, and biodiversity.
  3. Engage communities in environmental monitoring efforts to promote transparency and shared responsibility.

4.3 Economic and Social Benefits

  1. Prioritize local hiring and procurement to provide economic opportunities for community members, with a focus on training and skill development.
  2. Invest in community development initiatives, such as education, healthcare, and infrastructure, based on community-identified needs.
  3. Support small businesses and entrepreneurship in local communities through partnerships and capacity-building programs.

4.4 Health and Safety

  1. Ensure that our operations, including drilling and blasting, are conducted in a manner that prioritizes the health and safety of both our workers and nearby communities.
  2. Develop and communicate emergency response plans in collaboration with local authorities and communities to address potential risks.

4.5 Cultural Respect and Inclusion

  1. Recognize and respect the cultural heritage and traditional practices of communities, particularly Indigenous groups, in the areas where we operate.
  2. Work to protect culturally significant sites and incorporate community input into cultural preservation efforts.

5. Implementation

  1. Community Engagement Plans: Each project site will develop a tailored Community Engagement Plan, created in consultation with local communities, to address specific needs and impacts.
  2. Training: All employees and contractors will receive training on this policy and cultural sensitivity to ensure respectful and effective community interactions.
  3. Monitoring and Reporting: We will regularly monitor and report on our community engagement and environmental performance, sharing results with communities and stakeholders.
  4. Grievance Mechanism: A transparent and accessible grievance process will be established to address community concerns promptly and fairly.

6. Accountability and Review

  1. This policy will be reviewed annually to ensure it remains relevant and effective in addressing community needs and evolving industry standards.
  2. We will conduct regular audits of our community engagement and environmental practices to ensure compliance with this policy.
  3. Feedback from communities will be actively sought and incorporated into policy updates and operational improvements.

7. Contact

For questions, concerns, or feedback regarding this Community Policy, please contact our Community Relations Office at:
Email: community@meghmancanada.com
Phone: 1-800-555-1234

Meghman Canada Mining Group Inc. is committed to being a responsible neighbor and partner, ensuring that our operations contribute to the well-being and prosperity of the communities we serve.

1. Purpose and Objectives

The purpose of this Health and Safety Policy is to establish a robust framework that prioritizes the protection of all employees, contractors, visitors, and surrounding communities involved in or impacted by our mining operations. Meghman Canada Mining Group Inc. is firmly committed to fostering a zero-harm environment, where health and safety are integrated into every aspect of our business decisions and activities. This includes:

  1. Providing a safe, healthy, and supportive workplace for all personnel, with a focus on physical, mental, and emotional well-being.
  2. Preventing accidents, injuries, occupational illnesses, and environmental incidents across all operations, such as excavation, ore transport, drilling, blasting, mineral processing, site preparation, and waste management.
  3. Complying with all applicable health and safety laws, regulations, standards, and industry best practices, including those from Canadian federal and provincial authorities, as well as local African jurisdictions.
  4. Promoting a culture of continuous improvement in health and safety performance through regular audits, feedback mechanisms, and the adoption of innovative technologies and practices.
  5. Integrating health and safety considerations into strategic planning, budgeting, and performance evaluations to ensure long-term sustainability.

Objectives:

  1. Eliminate or minimize workplace hazards through comprehensive risk assessments, engineering controls, administrative measures, and preventive strategies.
  2. Ensure all employees, contractors, and visitors receive appropriate, role-specific safety training and competency assessments.
  3. Encourage active participation and consultation of all staff in health and safety programs, including through safety committees and open reporting channels.
  4. Maintain a high level of emergency preparedness and response capabilities for potential incidents, ensuring minimal disruption and rapid recovery.
  5. Achieve measurable improvements in health and safety metrics, such as reducing lost-time injury rates by at least 10% annually, through data-driven initiatives.
  6. Promote health and wellness programs to address occupational hazards like dust exposure, noise-induced hearing loss, ergonomic strains, and mental health challenges associated with shift work and remote operations.

2. Scope

This policy applies universally to:

  1. All employees, management personnel, contractors, subcontractors, suppliers, and visitors associated with Meghman Canada Mining Group Inc.
  2. All phases of mining operations, including but not limited to exploration, excavation, ore extraction and transport, drilling, blasting, mineral processing, tailings management, site preparation, rehabilitation, and decommissioning.
  3. All project locations and facilities across African countries where the company operates, as well as any supporting offices or logistics hubs in Canada or elsewhere.
  4. Interactions with local communities, ensuring that operations do not adversely affect public health and safety, such as through controlled access zones and community engagement programs.

This policy extends to remote work, travel, and off-site activities related to company business, emphasizing a holistic approach to health and safety beyond the mine site.

3. Content

a) Health and Safety Principles

  1. Safety is a foundational core value embedded in every mining operation, guiding all decisions from planning to execution.
  2. Every individual, from senior management to frontline workers, is personally responsible for their own safety, the safety of colleagues, and the broader community.
  3. All accidents, incidents, and occupational illnesses are preventable through proactive planning, vigilant behavior, and a commitment to learning from past experiences.
  4. Health and safety performance is a key indicator of operational excellence and is linked to individual and organizational accountability, including performance reviews and incentives.
  5. We prioritize mental health by recognizing stressors unique to mining, such as isolation and high-risk environments, and provide access to counseling and support services.

b) Risk Management

  1. Conduct regular, systematic hazard identification and risk assessments (HIRAs) at all operational stages, involving multidisciplinary teams and external experts when necessary.
  2. Implement a hierarchy of controls to eliminate or reduce identified risks: prioritizing elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE) as a last resort.
  3. Utilize tools such as Job Safety Analyses (JSAs) and Safe Work Method Statements (SWMS) for high-risk activities like blasting and heavy machinery operation.
  4. Monitor emerging risks, including those from climate change (e.g., extreme weather), technological changes, and supply chain disruptions, with annual reviews and updates to risk registers.
  5. Engage in proactive health surveillance programs to detect early signs of occupational diseases, such as respiratory issues from silica dust or musculoskeletal disorders from repetitive tasks.

c) Safety Training and Awareness

  1. Provide mandatory safety induction training for all new employees, contractors, and visitors, covering site-specific hazards, emergency procedures, and company policies.
  2. Offer periodic refresher training, at least annually or following significant changes, on topics like safe work practices, hazard recognition, and the use of specialized equipment.
  3. Develop tailored training programs for high-risk roles, including certification in areas such as confined space entry, working at heights, electrical safety, and chemical handling.
  4. Promote ongoing awareness through toolbox talks, safety bulletins, posters, and digital platforms to reinforce a safety-first mindset.
  5. Ensure competency verification through practical assessments and maintain records of all training to comply with regulatory requirements.

d) Safe Work Practices

  1. Mandate the use of appropriate personal protective equipment (PPE) at all times in designated areas, with regular inspections to ensure fit, condition, and compliance.
  2. Enforce strict adherence to safety procedures for key activities, including lockout/tagout (LOTO) for machinery maintenance, traffic management plans for ore transport, and blast zone protocols.
  3. Maintain all equipment, vehicles, and infrastructure in safe operating condition through scheduled preventive maintenance, daily pre-use inspections, and prompt repairs.
  4. Implement fatigue management strategies, such as shift rotation limits and rest breaks, to mitigate risks associated with long hours in demanding environments.
  5. Prohibit unsafe behaviors through a fair disciplinary process while rewarding positive safety contributions via recognition programs.

e) Emergency Preparedness

  1. Develop and maintain detailed emergency response plans (ERPs) tailored to potential incidents, including fires, explosions, cave-ins, equipment failures, chemical spills, medical emergencies, and natural disasters like floods or earthquakes.
  2. Conduct regular emergency drills, simulations, and tabletop exercises at least quarterly, involving all personnel and external responders such as local fire services and medical teams.
  3. Equip sites with necessary resources, including first-aid stations, automated external defibrillators (AEDs), evacuation routes, and communication systems for remote areas.
  4. Establish crisis management teams with defined roles and ensure 24/7 availability of on-call support.
  5. Coordinate with local communities and authorities to align ERPs with regional disaster response frameworks.

f) Incident Reporting and Investigation

  1. Require immediate reporting of all incidents, near misses, unsafe conditions, and hazards via a user-friendly system, such as mobile apps or dedicated hotlines, to enable swift action.
  2. Conduct thorough investigations into incidents using methodologies like root cause analysis (RCA) and the “5 Whys” technique to identify underlying factors.
  3. Implement corrective and preventive actions (CAPAs) based on investigation findings, with timelines, responsible parties, and follow-up verification.
  4. Share lessons learned company-wide through incident bulletins and safety meetings to prevent recurrence.
  5. Track and analyze incident data using key performance indicators (KPIs) to inform policy updates and continuous improvement efforts.

g) Responsibilities and Accountability (New Section)

  1. Senior Management: Lead by example, allocate resources for health and safety initiatives, and review performance metrics quarterly.
  2. Supervisors and Line Managers: Oversee daily compliance, conduct safety inspections, and mentor teams on safe practices.
  3. Employees and Contractors: Actively participate in safety programs, report concerns, and adhere to all procedures.
  4. Health and Safety Committee: Comprising representatives from all levels, meet monthly to discuss issues, propose improvements, and monitor policy implementation.
  5. External Stakeholders: Ensure contractors undergo vetting for safety compliance and collaborate with regulators for audits.

h) Monitoring, Review, and Continuous Improvement (New Section)

  1. Perform regular internal audits and external certifications to verify policy effectiveness and compliance with standards like ISO 45001.
  2. Collect feedback through anonymous surveys and suggestion boxes to identify areas for enhancement.
  3. Review and update this policy annually or following major incidents, regulatory changes, or operational shifts.
  4. Benchmark performance against industry peers and report progress transparently to stakeholders.

4. References

This policy is guided by and aligns with:

  1. Local and National Occupational Health and Safety Regulations of African jurisdictions where the company operates, including those from countries such as South Africa, Ghana, and Tanzania.
  2. Canadian Occupational Health and Safety Regulations under the Canada Labour Code and provincial standards (e.g., Ontario’s Occupational Health and Safety Act).
  3. International Council on Mining and Metals (ICMM) Health and Safety Framework and Critical Control Management guidelines.
  4. International Labour Organization (ILO) Conventions, including Convention 176 on Safety and Health in Mines and Convention 155 on Occupational Safety and Health.
  5. ISO 45001:2018 – Occupational Health and Safety Management Systems.
  6. World Health Organization (WHO) guidelines on occupational health in mining sectors.
  7. Mining Association of Canada (MAC) Towards Sustainable Mining (TSM) protocols.

Approved by: Senior Management Team – Meghman Canada Mining Group Inc.
Effective Date: August 11, 2025
Review Date: August 11, 2026

1. Purpose

The purpose of this Incident Management Policy is to provide a comprehensive, structured framework for the identification, reporting, investigation, resolution, and follow-up of all incidents occurring within Meghman Canada Mining Group Inc.’s operations. This policy aims to safeguard the health and well-being of employees, contractors, visitors, local communities, and the environment, while mitigating risks to operational continuity in key activities such as excavation, ore transportation, drilling, blasting, and mining site preparation. By fostering a proactive approach to incident management, the policy supports the company’s overarching goals of zero harm, regulatory compliance, and sustainable mining practices.

2. Scope

This policy encompasses all aspects of incident management and applies universally to:
  1. All personnel, including full-time employees, part-time staff, contractors, subcontractors, and visitors present at any Meghman Canada Mining Group Inc. facilities or sites.
  2. All operational sites and activities conducted across Africa, including but not limited to mining exploration, extraction, processing, and support functions.
  3. A broad spectrum of incidents, which may include:
    1. Occupational health and safety events, such as workplace injuries, illnesses, or fatalities.
    2. Equipment-related failures, including machinery breakdowns, structural collapses, or vehicle accidents.
    3. Environmental incidents, encompassing spills of hazardous materials, unauthorized emissions, habitat disruptions, or water contamination.
    4. Security-related occurrences, such as breaches, theft, vandalism, or unauthorized access.
    5. Near-miss events, defined as any unplanned occurrence that could have resulted in injury, damage, or loss but did not due to chance or timely intervention.
    6. Any other disruptions that could impact operations, reputation, or compliance obligations.
    This policy does not cover routine maintenance issues or non-incident-related grievances, which are addressed under separate company policies.

3. Objectives

The primary objectives of this policy are to:

    1. Facilitate prompt and accurate reporting of incidents to enable swift response and minimize potential escalation.
    2. Conduct thorough investigations to uncover root causes, contributing factors, and systemic vulnerabilities, thereby preventing future occurrences.
    3. Cultivate a strong safety culture that encourages open reporting, accountability, and continuous learning among all stakeholders.
    4. Ensure full adherence to applicable local, national, and international laws, regulations, and industry standards, including mandatory reporting to regulatory bodies such as environmental agencies or occupational health authorities.
    5. Enhance operational resilience by integrating lessons learned into risk management strategies and performance metrics.

4. Incident Management Process

The incident management process is designed to be systematic, timely, and collaborative, following a standardized sequence of steps to ensure consistency across all sites.

a) Reporting

  1. All incidents, regardless of severity, must be reported without delay—ideally within one hour of occurrence—to the immediate supervisor, site manager, or designated safety officer via established channels (e.g., verbal notification, incident reporting forms, or digital apps).
  2. The initial report should capture essential details, including:
      1. Date, time, and precise location of the incident.
      2. Description of the incident type and sequence of events.
      3. Names and roles of individuals involved or affected, including witnesses.
      4. Any immediate hazards identified and initial mitigation actions taken (e.g., first aid administered, area secured).
      5. Supporting evidence, such as photographs, if safe to obtain.
  3. Anonymous reporting options are available through the company’s confidential hotline to encourage participation without fear of reprisal.

b) Investigation

    1. Upon receipt of a report, a formal investigation shall commence within 24 hours for minor incidents and immediately for serious or high-potential events.
    2. An investigation team, comprising the site safety coordinator, relevant department heads, and external experts if necessary (e.g., for environmental or technical assessments), will be assembled.
    3. The investigation process includes:
        1. Site inspections, evidence collection, and interviews with involved parties.
        2. Root cause analysis using methodologies such as the “5 Whys” technique, fishbone diagrams, or fault tree analysis.
        3. Identification of immediate causes (e.g., human error), contributing factors (e.g., inadequate training), and underlying systemic issues (e.g., policy gaps).
    4. Investigations must be impartial, documented at every stage, and completed within predefined timelines: 7 days for minor incidents and 30 days for major ones, unless extended with justification.

c) Corrective and Preventive Actions

  1. Immediate corrective actions will be implemented to address direct causes and restore safe operations, such as equipment repairs, temporary procedural changes, or enhanced supervision.
  2. Preventive measures will be developed based on investigation findings, including:
      1. Employee training programs or refresher courses on specific risks.
      2. Upgrades to equipment, tools, or infrastructure (e.g., installing safety guards on machinery).
      3. Revisions to operational procedures, risk assessments, or emergency response plans.
  3. All actions will be assigned to responsible parties with clear deadlines, tracked via a centralized action register, and verified for effectiveness through follow-up audits.

d) Communication

  1. Investigation outcomes, including root causes and recommended actions, will be disseminated promptly to all affected employees, contractors, and relevant departments through safety briefings, toolbox talks, or company-wide bulletins.
  2. For significant incidents (e.g., those involving injuries, environmental damage, or regulatory implications), reports will be escalated to senior management, external stakeholders (e.g., local communities, regulators), and insurers as required by law or contractual obligations.
  3. Communication will emphasize transparency, lessons learned, and positive reinforcement of safe behaviors to build trust and engagement.

e) Documentation and Recordkeeping

  1. All incident-related documentation, including reports, investigation notes, photographs, witness statements, and action plans, must be compiled into a secure, digital incident management system.
  2. Records will be retained for a minimum of 7 years or as mandated by applicable regulations, whichever is longer.
  3. Periodic reviews of records (at least quarterly) will be conducted to analyze trends, such as recurring incident types or high-risk areas, informing broader safety initiatives and performance indicators.

5. Responsibilities

Clear delineation of roles ensures accountability and effective policy implementation:

  1. Senior Management: Provide necessary resources (e.g., budget, personnel), oversee policy enforcement, and champion a safety-first culture through leadership example and regular reviews.
  2. Supervisors and Site Managers: Facilitate immediate reporting, lead or support investigations, ensure corrective actions are executed, and monitor compliance within their teams.
  3. Employees and Contractors: Vigilantly observe and report incidents or near-misses without delay, participate actively in investigations and training, and adhere to all safety protocols.
  4. Safety Officers/Committees: Coordinate incident management activities, conduct trend analyses, and recommend policy enhancements based on data insights.
  5. All Personnel: Foster a collaborative environment by sharing knowledge and supporting peers in maintaining safe operations.

6. Continuous Improvement

  1. This policy and associated procedures will undergo an annual review, or sooner following major incidents or regulatory changes, to incorporate emerging best practices, technological advancements, and feedback from audits or employee surveys.
  2. Lessons learned from incidents will be systematically integrated into training curricula, risk registers, and operational guidelines to drive ongoing enhancements in safety performance and efficiency.
  3. Key performance indicators (KPIs), such as incident frequency rates, investigation completion times, and action closure rates, will be monitored and reported to measure progress and identify improvement opportunities.

7. Statement of Commitment

Meghman Canada Mining Group Inc. pledges unwavering commitment to incident management characterized by urgency, integrity, and excellence. We prioritize the protection of human life, environmental stewardship, and asset integrity above all else, striving for incident-free operations that uphold our reputation as a responsible leader in African mining. Through rigorous application of this policy, we empower our workforce to achieve sustainable success and contribute positively to the communities we serve.

Approved by:
Senior Management – Meghman Canada Mining Group Inc.

Effective Date: August 11, 2025
Review Date: August 11, 2026

1. Scope and Applicability

This Supplier Code of Conduct (the “Code”) establishes the foundational expectations and requirements for all suppliers, vendors, contractors, subcontractors, agents, and service providers (collectively referred to as “Suppliers”) that engage in business with Meghman Canada Mining Group Inc. (“Meghman” or the “Company”). The Code applies universally to all aspects of Suppliers’ operations, activities, and supply chains that directly or indirectly support Meghman’s mining endeavors, including but not limited to excavation, ore extraction and transport, drilling, blasting, site preparation, infrastructure development, and the provision of mining machinery, equipment, tools, spare parts, consumables, and associated services.

Given Meghman’s primary operations in various African countries, this Code emphasizes compliance with local, national, and international standards relevant to the mining sector in Africa. Suppliers are required to ensure that their own subcontractors and downstream partners adhere to these principles, promoting a cascading commitment to ethical practices throughout the entire value chain.

All Suppliers must demonstrate unwavering commitment to the highest standards of business integrity, ethical conduct, environmental stewardship, occupational health and safety, human rights protection, and social responsibility. Failure to comply with this Code may result in corrective actions, including but not limited to suspension of contracts, termination of business relationships, or legal remedies as deemed appropriate by Meghman. Suppliers are encouraged to integrate these principles into their own policies and management systems to foster continuous improvement.

2. Business Integrity and Ethics

Meghman expects Suppliers to operate with absolute transparency, honesty, and accountability in all business interactions. This section outlines core principles to prevent misconduct and ensure fair dealings.

Suppliers must:

  1. Adhere to Legal Compliance: Conduct all business activities in full compliance with applicable local, national, and international laws, regulations, and treaties, including anti-corruption laws such as the Canadian Corruption of Foreign Public Officials Act (CFPOA), the U.S. Foreign Corrupt Practices Act (FCPA), and relevant African anti-bribery legislation. Suppliers should maintain robust internal controls to monitor and enforce compliance.
  2. Prohibit Corruption and Bribery: Strictly forbid all forms of bribery, kickbacks, extortion, embezzlement, fraud, money laundering, or any unethical influence peddling. This includes prohibiting facilitation payments, gifts, hospitality, or favors that could be perceived as influencing business decisions. Suppliers must implement anti-corruption training programs for employees and report any suspected violations immediately.
  3. Manage Conflicts of Interest: Identify, disclose, and mitigate any actual or potential conflicts of interest that could compromise impartiality in dealings with Meghman. Examples include personal relationships with Meghman employees, financial interests in competing entities, or dual roles that might affect objectivity. Disclosures should be made in writing to Meghman’s designated compliance officer without delay.
  4. Ensure Accurate Record-Keeping: Maintain complete, accurate, and verifiable records of all financial transactions, contracts, and communications related to Meghman. These records must be preserved in accordance with legal requirements and made available for audit or inspection upon request. Falsification or omission of records is strictly prohibited and may lead to severe consequences.

Suppliers are also expected to foster a culture of ethical behavior by establishing whistleblower mechanisms that allow anonymous reporting of unethical conduct without fear of retaliation.

3. Environmental Management

Environmental sustainability is a cornerstone of Meghman’s operations, particularly in sensitive African ecosystems affected by mining activities. Suppliers must prioritize the protection of natural resources and minimize ecological footprints.

Suppliers must:

  1. Comply with Environmental Regulations: Abide by all applicable environmental laws, permits, and standards in the countries of operation, including those governing air quality, water usage, biodiversity, and land use. This includes obtaining necessary environmental impact assessments (EIAs) and adhering to mitigation plans.
  2. Minimize Environmental Impacts: Implement measures to reduce emissions (e.g., greenhouse gases, dust, and pollutants), manage waste efficiently, and optimize resource consumption (e.g., water, energy, and raw materials). Suppliers should adopt best practices such as pollution prevention technologies, energy-efficient equipment, and low-emission transportation methods for ore and machinery.
  3. Promote Sustainable Practices: Actively support recycling programs, responsible waste disposal (including hazardous materials), and land rehabilitation efforts post-mining activities. Where applicable, Suppliers should engage in reforestation, soil restoration, and biodiversity conservation initiatives to restore disturbed sites to their natural or productive states.
  4. Align with Sustainability Goals: Provide products, services, and materials that contribute to Meghman’s broader sustainability objectives, such as using eco-friendly mining equipment, sourcing recycled components, or incorporating circular economy principles. Suppliers are encouraged to track and report environmental performance metrics, such as carbon footprints and water usage, to demonstrate progress.

Suppliers should integrate environmental management systems (e.g., certified under ISO 14001) and conduct regular audits to ensure ongoing compliance and improvement.

4. Health and Safety

The safety and well-being of workers are paramount in the high-risk mining industry. Suppliers must create and maintain environments that prevent accidents, injuries, and occupational illnesses.

Suppliers must:

  1. Establish Safe Workplaces: Provide and maintain safe, hygienic, and healthy working conditions for all employees, contractors, and visitors. This includes adequate ventilation, lighting, sanitation facilities, and emergency preparedness plans tailored to mining-specific hazards like underground operations or heavy machinery use.
  2. Comply with Safety Standards: Adhere to all relevant health and safety laws, mining regulations (e.g., those from African mining authorities), and industry best practices for activities such as excavation, drilling, blasting, ore transport, and site preparation. Suppliers must ensure equipment meets safety certifications and is regularly inspected and maintained.
  3. Train and Equip Workers: Deliver comprehensive training on health and safety protocols, hazard recognition, and emergency response. All workers must be provided with appropriate personal protective equipment (PPE), such as helmets, gloves, respirators, and safety harnesses, and trained in their proper use. Training should be ongoing, culturally sensitive, and accessible in local languages.
  4. Incident Management: Promptly report, investigate, and remediate any workplace incidents, near-misses, or hazards. Suppliers must maintain incident logs, implement corrective actions, and share lessons learned to prevent recurrence. In cases involving Meghman projects, incidents must be reported to the Company within 24 hours.

Suppliers are urged to pursue certifications like ISO 45001 and foster a safety-first culture through leadership commitment and employee involvement.

5. Human Rights and Labor Practices

Meghman is committed to upholding human dignity and fair labor standards across its supply chain, in alignment with international human rights frameworks.

Suppliers must:

  1. Respect Human Rights: Conduct operations in a manner that respects and protects human rights, as outlined in the Universal Declaration of Human Rights and the International Labour Organization (ILO) conventions. This includes avoiding complicity in abuses and conducting human rights due diligence in high-risk areas.
  2. Prohibit Exploitative Labor: Strictly ban child labor (under the legal working age), forced labor, bonded labor, human trafficking, and any form of modern slavery. Suppliers must verify worker ages, ensure voluntary employment, and prohibit practices like withholding wages or passports.
  3. Ensure Fair Employment Conditions: Provide fair and competitive wages that meet or exceed legal minimums, along with benefits such as overtime pay, rest periods, and paid leave. Working hours must comply with local laws and ILO standards, avoiding excessive overtime. Non-discriminatory practices must be enforced, prohibiting bias based on race, gender, age, religion, disability, or other protected characteristics.
  4. Support Worker Rights: Respect employees’ rights to freedom of association, collective bargaining, and peaceful assembly. Suppliers should not interfere with union activities and must provide mechanisms for grievance resolution.

Suppliers operating in Africa should be particularly vigilant about vulnerabilities in mining communities and implement monitoring systems to detect and address labor issues.

6. Social Responsibility and Community Engagement

Beyond compliance, Suppliers are encouraged to contribute positively to the social fabric of the communities where they operate, promoting inclusive and sustainable development.

Suppliers are encouraged to:

  1. Support Local Communities: Invest in local employment, skills training, apprenticeships, and economic development programs to build capacity and create opportunities for host communities in Africa. This may include prioritizing local hiring, supplier diversity initiatives, and partnerships with educational institutions.
  2. Responsible Sourcing: Ensure materials and services are sourced ethically, avoiding any association with conflict minerals, illegal mining, or environmentally destructive practices. Suppliers should trace supply chains (e.g., using blockchain or certification schemes) to verify origins and compliance with standards like the OECD Due Diligence Guidance for Responsible Mineral Supply Chains.
  3. Stakeholder Engagement: Interact transparently and respectfully with stakeholders, including local governments, indigenous groups, NGOs, and community leaders. This involves regular consultations, addressing concerns proactively, and reporting on social impacts to build trust and mitigate risks.

Suppliers should aim to measure and report on social performance, such as community investment metrics, to align with Meghman’s corporate social responsibility (CSR) goals.

7. Alignment with Additional Resources, Policies, and Standards

This Code is informed by and aligned with a range of authoritative frameworks to ensure comprehensive coverage of best practices:

  1. Local and National Laws: All relevant mining, environmental, labor, and anti-corruption laws in African countries where Meghman operates, including those from bodies like the African Mining Vision.
  2. International Council on Mining and Metals (ICMM) Sustainable Development Principles: Emphasizing responsible mining practices for environmental, social, and governance (ESG) excellence.
  3. United Nations Global Compact Principles: Covering human rights, labor standards, environmental protection, and anti-corruption.
  4. ISO Standards: Including ISO 14001 for Environmental Management Systems and ISO 45001 for Occupational Health and Safety Management Systems, as well as ISO 26000 for Social Responsibility guidance.

Suppliers are required to familiarize themselves with these resources, integrate them into their operations, and provide evidence of compliance upon request. Meghman may conduct audits, assessments, or third-party verifications to confirm adherence.

Approved by: Executive Management – Meghman Canada Mining Group Inc.
Effective Date: [Insert Date]
Review Date: [Insert Date]

1. Purpose

Meghman Canada Mining Group Inc. is committed to upholding the highest standards of safety, ethics, and professionalism across all mining operations, including excavation, ore transport, drilling, blasting, and site preparation. The Zero Tolerance Rule (ZTR) establishes clear non-negotiable standards for behavior, safety, and compliance. Violations of these rules will not be tolerated and will result in immediate disciplinary action, which may include termination of employment or contract, and legal consequences where applicable.

2. Scope

This policy applies to all employees, contractors, subcontractors, and visitors involved in Meghman Canada Mining Group Inc.’s operations, regardless of role or location. It covers all activities related to mining operations, including but not limited to excavation, ore transport, drilling, blasting, and site preparation.

3. Zero Tolerance Rules

The following behaviors and actions are strictly prohibited and will result in immediate disciplinary action:

3.1 Safety Violations

  1. Failure to wear required personal protective equipment (PPE) at all times in designated areas.
  2. Operating machinery or equipment without proper training, certification, or authorization.
  3. Bypassing or disabling safety devices, guards, or protocols on equipment or machinery.
  4. Engaging in reckless behavior that endangers oneself or others, such as horseplay or unauthorized access to restricted areas.
  5. Failure to report accidents, near-misses, or hazardous conditions immediately.

3.2 Ethical and Professional Conduct

  1. Engaging in harassment, discrimination, or bullying based on race, gender, religion, age, disability, or any other protected characteristic.
  2. Theft, vandalism, or willful damage to company property, equipment, or resources.
  3. Falsifying records, reports, or documentation, including safety logs, production reports, or timekeeping.
  4. Engaging in bribery, corruption, or any form of unethical business practices.

3.3 Substance Abuse

  1. Use, possession, or distribution of alcohol, illegal drugs, or unauthorized substances on company premises or during work hours.
  2. Reporting to work under the influence of alcohol, drugs, or any substance that impairs performance or judgment.

3.4 Environmental and Regulatory Compliance

  1. Unauthorized disposal of hazardous materials or waste in violation of environmental regulations.
  2. Failure to adhere to federal, provincial, or local mining regulations and standards.
  3. Negligent actions that result in environmental damage, such as spills or improper containment of materials.

4. Disciplinary Actions

Violations of the ZTR will result in immediate disciplinary action, which may include:

  1. Immediate Suspension: Removal from the worksite pending investigation.
  2. Termination: Termination of employment or contract for confirmed violations.
  3. Legal Action: Referral to law enforcement for violations involving illegal activities, such as theft, substance distribution, or environmental crimes.
  4. Fines or Penalties: Financial penalties where applicable, as determined by company policy or regulatory authorities.

5. Reporting and Investigation

  1. All employees and contractors are required to report ZTR violations immediately to their supervisor or the designated compliance officer.
  2. Reports will be investigated promptly, thoroughly, and impartially by the Meghman Canada Mining Group Inc. compliance team.
  3. Confidentiality will be maintained to the extent possible, and retaliation against whistleblowers is strictly prohibited.

6. Training and Awareness

  1. All employees and contractors must complete mandatory ZTR training upon hiring and annually thereafter.
  2. Regular safety briefings and updates on regulatory requirements will be conducted to ensure ongoing compliance.
  3. Signage and documentation outlining ZTR policies will be prominently displayed at all worksites.

7. Policy Enforcement

  1. Supervisors and managers are responsible for enforcing the ZTR and ensuring compliance within their teams.
  2. The compliance team will conduct regular audits and inspections to monitor adherence to ZTR standards.
  3. Failure to enforce the ZTR by supervisors may result in disciplinary action.

8. Review and Updates

This policy will be reviewed annually or as needed to ensure alignment with industry standards, regulatory changes, and operational requirements. Updates will be communicated to all relevant personnel.

9. Acknowledgment

All employees, contractors, and visitors must acknowledge receipt and understanding of the ZTR Policy. Failure to comply with this policy will be considered a violation of company standards.

Effective Date: August 11, 2025

Approved by:
[Your Name], [Your Title]
Meghman Canada Mining Group Inc.