A rigourous Code of Conduct

ADHERENCE TO ANTI-MONEY LAUNDERING (“AML”) COMPLIANCE PROGRAM

OCIM is committed to conducting its business dealings in an honest and ethical manner. To achieve this commitment, OCIM maintains a zero tolerance approach against all forms of bribery and corruption in conducting its business. OCIM complies with all applicable laws, regulations and guidelines where it operates.
OCIM’s commitment is guided by its Anti-Bribery and Anti-Corruption Policy (“ABC Policy”), which includes policies, procedures, approval processes, risk assessments, due diligence, and employee training programs. All members of the organization and third parties must uphold the highest levels of integrity and accountability in discharging their duties to ensure that business activities are conducted in compliance with the ABC Policy.
All members of the organization and third parties are strictly prohibited from the following activities:

• Receiving and offering bribes or participate in any form of bribery and corruption in its business dealings;
• Receiving (accepting) or offering (giving) any form of gifts, entertainment and corporate hospitality, whether directly or indirectly with the intention to bribe, to retain or gain a business advantage, or for personal gain;
• Corporate Social Responsibility (CSR), donations and sponsorships made to improperly influence business outcomes;
• Donating or offering political contributions whether in monetary or non monetary form; and
• Making any form of facilitation payments.

Disciplinary actions may be taken against an offender and OCIM reserves the right to terminate any relationships with third parties for breaches of the ABC Policy, including reporting to relevant authorities, where investigations confirm corruption.

STATEMENT OF COMMITMENT TO GLOBAL SANCTIONS COMPLIANCE

OCIM is committed to conducting its business dealings in an honest and ethical manner. To achieve this commitment, OCIM maintains a zero tolerance approach against all forms of bribery and corruption in conducting its business. OCIM complies with all applicable laws, regulations and guidelines where it operates.
OCIM’s commitment is guided by its Anti-Bribery and Anti-Corruption Policy (“ABC Policy”), which includes policies, procedures, approval processes, risk assessments, due diligence, and employee training programs. All members of the organization and third parties must uphold the highest levels of integrity and accountability in discharging their duties to ensure that business activities are conducted in compliance with the ABC Policy.
All members of the organization and third parties are strictly prohibited from the following activities:

• Receiving and offering bribes or participate in any form of bribery and corruption in its business dealings;
• Receiving (accepting) or offering (giving) any form of gifts, entertainment and corporate hospitality, whether directly or indirectly with the intention to bribe, to retain or gain a business advantage, or for personal gain;
• Corporate Social Responsibility (CSR), donations and sponsorships made to improperly influence business outcomes;
• Donating or offering political contributions whether in monetary or non monetary form; and
• Making any form of facilitation payments.

Disciplinary actions may be taken against an offender and OCIM reserves the right to terminate any relationships with third parties for breaches of the ABC Policy, including reporting to relevant authorities, where investigations confirm corruption.

STATEMENT OF COMMITMENT TO THE GLOBAL PRECIOUS METALS CODE

OCIM is committed to conducting its business dealings in an honest and ethical manner. To achieve this commitment, OCIM maintains a zero tolerance approach against all forms of bribery and corruption in conducting its business. OCIM complies with all applicable laws, regulations and guidelines where it operates.
OCIM’s commitment is guided by its Anti-Bribery and Anti-Corruption Policy (“ABC Policy”), which includes policies, procedures, approval processes, risk assessments, due diligence, and employee training programs. All members of the organization and third parties must uphold the highest levels of integrity and accountability in discharging their duties to ensure that business activities are conducted in compliance with the ABC Policy.
All members of the organization and third parties are strictly prohibited from the following activities:

• Receiving and offering bribes or participate in any form of bribery and corruption in its business dealings;
• Receiving (accepting) or offering (giving) any form of gifts, entertainment and corporate hospitality, whether directly or indirectly with the intention to bribe, to retain or gain a business advantage, or for personal gain;
• Corporate Social Responsibility (CSR), donations and sponsorships made to improperly influence business outcomes;
• Donating or offering political contributions whether in monetary or non monetary form; and
• Making any form of facilitation payments.

Disciplinary actions may be taken against an offender and OCIM reserves the right to terminate any relationships with third parties for breaches of the ABC Policy, including reporting to relevant authorities, where investigations confirm corruption.

ADHERENCE TO ANTI-BRIBERY AND ANTI-CORRUPTION (“ABC”) POLICY

OCIM is committed to conducting its business dealings in an honest and ethical manner. To achieve this commitment, OCIM maintains a zero tolerance approach against all forms of bribery and corruption in conducting its business. OCIM complies with all applicable laws, regulations and guidelines where it operates.
OCIM’s commitment is guided by its Anti-Bribery and Anti-Corruption Policy (“ABC Policy”), which includes policies, procedures, approval processes, risk assessments, due diligence, and employee training programs. All members of the organization and third parties must uphold the highest levels of integrity and accountability in discharging their duties to ensure that business activities are conducted in compliance with the ABC Policy.
All members of the organization and third parties are strictly prohibited from the following activities:

• Receiving and offering bribes or participate in any form of bribery and corruption in its business dealings;
• Receiving (accepting) or offering (giving) any form of gifts, entertainment and corporate hospitality, whether directly or indirectly with the intention to bribe, to retain or gain a business advantage, or for personal gain;
• Corporate Social Responsibility (CSR), donations and sponsorships made to improperly influence business outcomes;
• Donating or offering political contributions whether in monetary or non monetary form; and
• Making any form of facilitation payments.

Disciplinary actions may be taken against an offender and OCIM reserves the right to terminate any relationships with third parties for breaches of the ABC Policy, including reporting to relevant authorities, where investigations confirm corruption.

GROUP CODE OF ETHICS & BUSINESS CONDUCT

Our Code of Ethics & Business Conduct outlines OCIM’s commitment to maintaining a workplace free from discrimination and harassment, emphasizing the importance of making employment-related decisions based on values and not discriminating against individuals based on various factors such as family status, race, gender, age, sexual orientation, and more. The company strives to create an inclusive work environment that promotes equal opportunities for all qualified individuals.

OCIM firmly rejects harassment in all its forms, whether it involves verbal remarks, inappropriate sexual advances, offensive comments, or any other behavior that creates an intimidating or offensive atmosphere. Harassment can come from colleagues, managers, vendors, or contractors, and the company emphasizes the need for appropriate and respectful conduct by all employees. Reporting any discriminatory or harassing behavior is strongly encouraged, with employees urged to inform the Director of Human Resources or their manager.

Our Code of Ethics & Business Conduct highlights OCIM’s commitment to ensuring a safe, healthy, and violence-free workplace. It emphasizes the prohibition of behavior that poses risks to the safety, health, or security of employees, with procedures in place for reporting any such risks. The company places a strong emphasis on ethics, discouraging conflicts of interest and the use of insider information for insider trading, while also adhering to anti-corruption, competition, anti-boycott, and money laundering laws.

OCIM underscores the importance of responsible business practices, data privacy, and the protection of personal and confidential information. It emphasizes the appropriate use of company assets, intellectual property protection, and the correct handling of communications with the public, especially in matters concerning the company’s business and financial results.

Our Code of Ethics & Business Conduct also discusses the importance of responsible sourcing, respecting human rights, environmental stewardship, and sustainability. OCIM is committed to preventing child or forced labor, human trafficking, and modern slavery in its operations. The company adheres to environmental protection standards and strives to minimize environmental hazards, conserve natural resources, and manage energy responsibly. Responsible sourcing practices are encouraged, and the protection of intellectual property is highlighted.

OCIM promotes a culture of reporting misconduct and ensures confidentiality in handling reported issues. The company maintains a strict non-retaliation policy, assuring employees that they will not face adverse consequences for raising concerns in good faith. The document emphasizes the importance of cooperating in internal or external investigations and the consequences of making reports in bad faith or retaliating against whistleblowers.

GROUP CONFLICTS OF INTEREST POLICY

Avoiding Conflicts of Interest

Representatives must always prioritize OCIM’s best interests and prevent outside interests from affecting their decision-making or job duties. They should actively avoid conflicts of interest and immediately stop any activities that create conflicts. Representatives must provide written disclosure of any known conflict of interest or potential conflict upon hire or during their employment at OCIM.

Disclosure, Reporting, and Approvals

If a potential or actual conflict of interest arises or if there’s uncertainty about one, representatives must refrain from the activity in question. Prompt written disclosure of conflicts or potential conflicts should be made to the Chairman and CEO. OCIM leadership, along with managers, legal counsel, and relevant groups, will work to address conflicts and obtain necessary approvals. Representatives can contact the Chairman and CEO for guidance on potential conflicts or policy violations. The policy does not intend to limit rights under applicable laws.

Family, Friends, and Personal Relationships

Representatives should avoid personal conflicts of interest. If such conflicts arise, they should make efforts to disclose them in writing and submit to the Chairman and CEO.

Personal Financial Interests

Representatives and those they manage must not participate in or attempt to influence OCIM decisions or business dealings when they have a direct or indirect financial interest.

Disclosure of such financial interests is required to avoid the appearance of a conflict when OCIM plans to engage with relevant entities.

Corporate and Outside Business Opportunities

Representatives should not interfere with OCIM’s existing or potential business opportunities. They must not direct these opportunities to relatives, close friends, or businesses with which they have a financial interest. Outside business activities must not compete with OCIM or create conflicts of interest, even if they give the appearance of one. Engagement in outside activities must not involve disclosing OCIM’s proprietary information or diverting attention from their responsibilities. Even the appearance of a conflict is taken seriously.

Favors and Gifts

Representatives must make business decisions in OCIM’s best interests, without being unduly influenced by gifts, favors, entertainment, payment, or loans. Reference to the Group Anti-Bribery and Corruption Policy for more information is advised.

INSIDER TRADING POLICY

No Trading on Inside Information

Insiders are prohibited from buying or selling securities of external public companies while in possession of Material Nonpublic Information (MNPI) related to those companies or their associates. Insiders or OCIM representatives who possess MNPI about a public company cannot share this information with anyone, including family and friends. Trading, tipping, or recommending securities based on material nonpublic information requires advance approval from OCIM’s legal counsel via the Head of Risk.

Definitions

Material information refers to data that a reasonable investor would find significant in deciding to buy, sell, or hold a security. This includes information that could impact a company’s stock price, positive or negative. Non public information is data not widely disseminated to the marketplace and available only to a limited group, not the general public. Information becomes public only after it has been widely distributed, and there should be a reasonable time for the market to absorb it.

Consequences of Non-Compliance

Insiders who engage in securities transactions in violation of this policy or applicable laws may face severe penalties. Those who pass on nonpublic information to others who then trade face the same penalties as the traders, even if they did not profit from the trading. Failure to comply with this policy may result in sanctions by the Company, including dismissal for cause, regardless of whether it breaches applicable laws.

Additional Trading Restrictions

Insiders have additional restrictions related to MNPI exposure, including needing prior approval from the Chairman and CEO for outside employment related to their knowledge of the Company. Insiders should not respond to market rumors or make public statements about the Company or its prospects without prior approval. Reporting rumors or false statements is encouraged.

Condition of Employment

All Insiders must adhere to the standards, requirements, and procedures outlined in this Policy as a condition of their appointment or employment. Breach of this Policy may lead to sanctions, including possible termination of appointment or employment. Insiders are required to acknowledge and comply with these procedures and restrictions upon their appointment or employment, as requested by the Chairman and CEO or Head of Risk.

INFORMATION SECURITY POLICY

Data Identification and Classification Policy

The Data and Identification Classification Policy of OCIM (Organization for Confidential Information Management) sets out the framework for managing and safeguarding the organization’s data assets. This policy is vital to ensure the protection of critical data, and it mandates that all employees understand and adhere to data classification and handling procedures.

Data Classification Tiers

OCIM classifies data into four tiers based on sensitivity, criticality, and value:

Tier I: Restricted/Proprietary

Data in this tier is of strategic importance, proprietary, or mission-critical. Loss or damage to this data could lead to severe or catastrophic consequences for OCIM. It is meant for internal use and should only be disclosed externally for legitimate business purposes, with coordination from the Legal and Risk departments.

Tier II: Confidential

Confidential data includes information like ID numbers, birthdates, health records, and financial data. Unauthorized access or compromise of this data could result in significant harm to OCIM, its counterparties, or employees. It should be used internally and by those with a legitimate business need.

Tier III: Sensitive

Sensitive data requires protection due to ethical or privacy considerations. Unauthorized use or disclosure could lead to financial loss, damage to OCIM’s reputation, or violations of privacy rights. This data should only be used for purposes related to OCIM’s business.

Tier IV: Public

Public information is not publicly disseminated but is accessible to the general public through legitimate channels. Knowledge of public information does not pose significant risks to OCIM or its stakeholders.

Counterparty Data Policy

Counterparty Data Retention:OCIM commits to retaining Counterparty Data only as long as necessary for its original or subsequent purposes. Legal, regulatory, and contractual requirements will dictate the retention period. In the absence of such requirements, industry best practices applicable to OCIM’s business will guide the retention period. Data should be deleted promptly when no longer needed.

Counterparty Data Protection: OCIM takes measures to secure Counterparty Data, including personally identifiable information, against loss, unauthorized access, alteration, or damage. Security controls are in place to:

• Prevent unauthorized access.
• Restrict access to authorized individuals.
• Protect data during transmission.
• Establish access logs.
• Ensure compliance with data processing by third parties.
• Safeguard against destruction, loss, or corruption.
• Maintain separation of data for different business purposes.
• Avoid unnecessary data retention.

Information Asset Protection Policy

This policy outlines OCIM’s objectives for safeguarding the confidentiality, integrity, and availability of its information assets, including IT infrastructure, data, system and application accounts, software, social media accounts, networks, and office facilities.

Access to these assets is granted based on the principle of least privilege, ensuring that individuals receive only the minimum access necessary for their job responsibilities. Access provisioning and deprovisioning must follow established procedures and include evidence of proper authorization.

Hardware Management Policy

This policy defines the guidelines for managing corporate and BYOD (Bring Your Own Device) hardware. Corporate devices must be approved by the IT Manager, configured to meet OCIM’s standards, and monitored regularly. Personal devices are permitted but come with additional security requirements.

Network and Services Management Policy

The Network and Services Management Policy outlines OCIM’s approach to network segmentation, documentation, and control measures. It emphasizes logical separation of information assets and the need to protect these assets through measures like firewall appliances.

A configuration management database or similar tool may be used to identify, manage, and track assets, network appliances, and services.

Software Installation and Hardware Connection Management Policy

This policy mandates that all software installations on OCIM information assets must be evaluated and authorized by the IT Manager or their delegate. Users are not permitted to install software or connect hardware without permission. Security controls must not be tampered with to bypass this policy.

Account Protection Policy

This policy sets criteria for user accounts, privileges, and account management. User accounts must be unique, traceable, and associated with specific individuals. Group accounts and passwords are not allowed without approval. User privileges are granted based on the principle of least privilege.

Incident Response Policy

The Incident Response Policy outlines the procedures OCIM will follow in response to security incidents. It includes incident reporting, roles and responsibilities, resources, technical requirements, documentation, and periodic updates. It aligns with OCIM’s unique requirements and risk tolerance.

Monitoring, Periodic Testing, and Risk Review Policy

This policy emphasizes threat assessment, monitoring, vulnerability assessment, and risk management. OCIM will periodically identify, analyze, and prioritize threats and vulnerabilities.

Vulnerability assessments and external penetration tests are conducted regularly. The results guide risk management and control measures.

Training, Enforcement, Corrective Action Policy

This policy covers training, enforcement, and corrective actions related to OCIM’s information security program. All users must review and acknowledge information security policies. Security awareness training is provided to new hires. Enforcement includes disciplinary actions for policy violations. Corrective actions are taken based on OCIM policies.

THIRD-PARTY & SUPPLY CHAIN POLICY

OCIM engages in various commercial activities, including investments, trading in commodities and equities, and providing financing services in the extractive sector. To ensure the secure and efficient conduct of these services, OCIM may collaborate with third-party partners. This text outlines guidelines for managing general third-party risks, legal agreements or contracts, termination of services, special requirements for sales agents, and special requirements for mining-related activities.

Managing General Third-Party Risks

Before outsourcing any processes or services to a third-party partner or allowing them access to OCIM’s information or systems, a preliminary risk assessment should be conducted in consultation with the Head of Risk. The assessment should evaluate products, services, budget approval, and other business considerations. Future versions of the policy will address criticality ratings and associated requirements.

Legal Agreements or Contracts

Confidentiality agreements should be executed by third-party partners when exchanging confidential data. The Head of Risk, in consultation with legal counsel, should be consulted before proceeding with such agreements.

Termination of Service

Upon terminating a third-party partner’s services or legal agreement, provisions should be made for the return or destruction of OCIM data. Agreements should ensure the security of information and systems if a contract is terminated or transferred. The OCIM Global Cybersecurity Policy should also be referenced for further information.

Special Requirements for Sales Agents

This section focuses on the employment and treatment of sales agents, who can play a role in corruption scandals. Approval by the Chairman and CEO is required for all contracts with sales agents. Approval is contingent on several conditions, including the adequacy of remuneration, clear description of services, relevant expertise, absence of conflicts of interest, and proper documentation.

Compliance and Final Beneficiary Declaration/Documentation

Sales agents must submit compliance and final beneficiary declarations upon signing the contract and annually thereafter. The responsible Point of Contact (PoC) should obtain these declarations.

Special Requirements for Mining-Related Activities

OCIM finances activities related to precious and strategic metals and adheres to responsible mineral sourcing initiatives, international standards, and OCIM’s Group Code of Ethics & Business Conduct. Transparency in the supply chain and responsible environmental management, including water resources and tailings dams, are crucial considerations.

General Rules

OCIM commits to fulfilling its environmental and sustainability obligations and refrains from involvement in various prohibited acts, such as supporting abuse, illegal activities, bribery, misrepresentation, or non-compliance with government regulations related to mineral extraction and trade from conflict-affected and high-risk areas.