Effective date: 01 January 2026
Waymark Metals Limited (“Waymark Metals”, “we”, “us” or “our”) is committed to responsible, ethical and sustainable practices across all aspects of its operations, sourcing activities and supply chains. This Environmental, Social and Governance (“ESG”) and Responsible Mining Policy sets out the principles that guide how we operate, partner and make decisions across our business, with particular emphasis on responsible mineral sourcing and conflict-free supply chains.
This Policy applies to Waymark Metals Limited and all of its 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 (together, the “Waymark Group”).
This Policy operates alongside, and must be read together with, the Waymark Metals Code of Conduct, which sets the mandatory standards of behaviour expected of all directors, officers, employees, contractors, suppliers and counterparties.
1. ESG framework, international standards and Code of Conduct alignment
Waymark Metals’ ESG approach is grounded in practical implementation, strong governance and disciplined risk management. Our Code of Conduct provides the ethical and behavioural foundation for this Policy and applies to all activities, decisions and relationships across the Waymark Group.
Waymark Metals seeks to align its practices with internationally recognised frameworks for responsible mineral sourcing, including:
- the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- the LBMA Responsible Gold Guidance and Responsible Gold Mining Principles, where applicable
- relevant United Nations, World Bank and IFC environmental and social principles
Compliance with the Code of Conduct and this Policy is a condition of employment, engagement and partnership. Breaches may result in disciplinary action, suspension or termination of relationships.
2. Conflict-free gold and responsible mineral sourcing
Waymark Metals is committed to sourcing and trading gold and other minerals in a manner that is conflict-free and does not directly or indirectly finance armed conflict, organised crime, human rights abuses or illicit activities.
In line with LBMA and OECD expectations, Waymark Metals seeks to:
- source gold and minerals from legitimate, lawful and verifiable sources
- avoid sourcing from areas or counterparties where credible conflict or human rights risks cannot be mitigated
- conduct risk-based due diligence on gold supply chains, including origin, ownership, transport and export
- support traceability and transparency of gold from mine or aggregation point through to export and sale
Where applicable, Waymark Metals supports the principles of the LBMA Responsible Gold Guidance and expects counterparties involved in gold production, aggregation, trading or refining to demonstrate alignment with responsible sourcing standards.
3. Environmental responsibility
Waymark Metals seeks to minimise environmental impact and promote responsible resource development by:
- encouraging efficient and responsible use of land, water and energy
- supporting rehabilitation, remediation and responsible closure planning where extraction occurs
- promoting reduced environmental harm in artisanal and small-scale mining through improved practices and equipment
- complying with applicable environmental laws, permits and regulatory requirements
Environmental responsibilities outlined in this Policy are reinforced by the environmental and compliance obligations set out in our Code of Conduct.
4. Responsible engagement with artisanal and small-scale mining
Where we engage with artisanal and small-scale mining (“ASM”) communities, Waymark Metals acts in accordance with this Policy and our Code of Conduct by:
- encouraging safer working practices, improved recovery rates and reduced environmental impact
- supporting practical measures to reduce health, safety and environmental risks where practicable
- promoting transparency, fair pricing, traceability and lawful trading
- respecting local customs, land rights and recognised community structures
Waymark Metals does not support exploitative practices, child labour, unsafe working conditions or unethical conduct in ASM supply chains.
5. Health and safety
The safety of people is fundamental to responsible mining and ethical conduct. In line with our Code of Conduct, Waymark Metals seeks to:
- promote a safety-first culture across operations and partnerships
- encourage appropriate training and awareness for local operating conditions
- support practical measures that reduce accidents and occupational health risks
While Waymark Metals does not typically operate large-scale industrial mines directly, we recognise our responsibility to influence safety standards within our sphere of control and commercial relationships.
6. Social responsibility and community impact
Waymark Metals recognises that mining activity directly affects communities and livelihoods. In accordance with our Code of Conduct, we aim to:
- support local employment and local supply chains where feasible
- engage constructively with communities and legitimate stakeholders
- avoid practices that create long-term social harm, instability or dependency
- respect human rights, dignity, lawful land use and cultural heritage
Our objective is to ensure that mining activity contributes positively and sustainably rather than extractively.
7. Supply chain due diligence and traceability
Waymark Metals adopts a risk-based approach to supply chain due diligence consistent with OECD guidance. This includes:
- conducting proportionate due diligence on suppliers, intermediaries and counterparties
- assessing risks relating to origin, ownership, transportation, export and payment flows
- taking appropriate action where risks are identified, including enhanced due diligence, risk mitigation or disengagement
- maintaining records and documentation to support traceability and auditability where required
Where risks cannot be adequately mitigated, Waymark Metals reserves the right to decline or terminate sourcing relationships.
8. Governance, ethics and business integrity
Strong governance underpins all ESG commitments. Waymark Metals is committed to:
- acting with integrity, transparency and accountability
- complying with all applicable laws and regulations
- maintaining appropriate internal controls and oversight
- preventing bribery, corruption, money laundering and improper influence
- conducting proportionate due diligence on projects, partners and counterparties
These principles are mandatory under our Code of Conduct and supported by our Anti-Bribery and Corruption Policy, AML and Sanctions Policy and related governance frameworks.
9. Human rights and modern slavery
Waymark Metals does not tolerate forced labour, child labour or modern slavery in any form. Consistent with our Code of Conduct and international standards, we seek to:
- conduct reasonable and proportionate due diligence on supply chains and partners
- avoid engagement where credible human rights risks cannot be addressed
- align with internationally recognised human rights principles and expectations
10. Compliance, oversight and continuous improvement
ESG obligations are subject to ongoing oversight by senior management. Waymark Metals is committed to:
- monitoring ESG risks and performance across its operations and supply chains
- reviewing and improving practices as projects develop and scale
- aligning with evolving international standards, regulatory requirements and investor expectations
All personnel and counterparties are expected to cooperate with ESG and compliance processes as required under the Code of Conduct.
11. Accountability and enforcement
Responsibility for ESG oversight rests with senior management of Waymark Metals. Breaches of this Policy or the Code of Conduct may result in corrective action, suspension or termination of employment, engagement or commercial relationships.
12. Policy review
This Policy will be reviewed periodically and updated as required to reflect changes in law, regulation, international standards or business practice.