Effective date: 01 January 2026
Waymark Metals Limited (“Waymark Metals”, “we”, “us” or “our”) is committed to conducting its business with integrity, professionalism and accountability. This Code of Conduct sets out the standards of behaviour and ethical principles expected of all directors, officers, employees, consultants, contractors and business partners acting on behalf of, or in connection with, the Waymark Group.
This Code applies to Waymark Metals Limited and all subsidiaries, affiliates and connected companies operating in the United Kingdom, Nevis, the Cayman Islands, the British Virgin Islands, Liberia, Sierra Leone, Guinea (Conakry) and the United Arab Emirates.
Compliance with this Code of Conduct is a condition of engagement with Waymark Metals.
1. Core Principles
All individuals and entities associated with Waymark Metals are expected to act in accordance with the following principles:
- Integrity and honesty in all dealings
- Compliance with applicable laws and regulations
- Respect for people, communities and the environment
- Zero tolerance for bribery, corruption or unethical conduct
- Accountability for actions and decisions
2. Compliance with Laws and Regulations
Waymark Metals operates across multiple jurisdictions. All covered persons must comply with applicable local, national and international laws, regulations and licensing requirements, including those relating to mining, commodities, trade, sanctions, data protection and financial crime.
Where laws differ between jurisdictions, the higher standard of conduct should be applied.
3. Anti-Bribery and Corruption
Waymark Metals maintains a zero-tolerance approach to bribery and corruption.
You must not:
- Offer, give, request or accept bribes or improper payments
- Provide improper gifts, hospitality or inducements
- Use intermediaries to engage in prohibited conduct
All activities must comply with applicable anti-corruption laws, including the UK Bribery Act and relevant local legislation.
4. Conflicts of Interest
All covered persons must avoid situations where personal interests conflict, or appear to conflict, with the interests of Waymark Metals.
Any actual or potential conflict of interest must be disclosed promptly to senior management. Failure to disclose conflicts may result in disciplinary action.
5. Ethical Business Practices and Fair Dealing
Waymark Metals is committed to fair, transparent and ethical business practices.
This includes:
- Honest communications with investors, partners and governments
- Accurate record keeping and reporting
- No misleading statements or omissions
- Respectful and professional conduct in negotiations
6. Human Rights and Labour Standards
Waymark Metals does not tolerate:
- Forced labour, child labour or modern slavery
- Abuse, exploitation or unsafe working conditions
We expect our partners and suppliers to uphold basic human rights standards and will not knowingly engage where serious violations exist and cannot be mitigated.
7. Health, Safety and Wellbeing
Safety is fundamental to responsible mining and operations.
Covered persons must:
- Act in a manner that protects their own safety and that of others
- Follow applicable health and safety rules and guidance
- Report unsafe conditions or incidents promptly
Waymark Metals seeks to promote a safety-first culture across all activities.
8. Environmental Responsibility
Waymark Metals is committed to responsible environmental practices.
All covered persons must:
- Comply with environmental laws and permits
- Avoid unnecessary environmental harm
- Support practical measures to reduce environmental impact
Environmental responsibilities are further detailed in the ESG and Responsible Mining Policy.
9. Confidentiality and Data Protection
Confidential information relating to Waymark Metals, its projects, partners or counterparties must be protected and used only for legitimate business purposes.
Personal data must be handled in accordance with applicable data protection laws, including UK GDPR, EU GDPR and UAE data protection requirements where relevant.
10. Use of Company Assets and Information
Company assets, information and systems must be used responsibly and only for authorised business purposes.
Unauthorised use, misuse or disclosure of company assets or information is prohibited.
11. Whistleblowing and Reporting Concerns
Waymark Metals encourages the reporting of concerns relating to unethical, unlawful or improper conduct.
Reports may be made confidentially and without fear of retaliation. Retaliation against anyone raising a concern in good faith will not be tolerated.
12. Due Diligence and Third Parties
Waymark Metals conducts due diligence on projects, partners and counterparties. Covered persons must cooperate fully with due diligence and compliance processes.
We expect third parties acting on our behalf to adhere to standards consistent with this Code.
13. Breaches and Enforcement
Breaches of this Code of Conduct may result in disciplinary action, termination of employment or engagement, and where appropriate, referral to authorities.
Waymark Metals reserves the right to suspend or terminate relationships where conduct falls below acceptable standards.
14. Responsibility and Review
Senior management is responsible for oversight and enforcement of this Code of Conduct. This Code will be reviewed periodically and updated as required.