Public Policy
Governing responsible mineral trading across Southern Africa

Explonat Minerals ("the Company") is the minerals trading division of Explonat, operating across the mineral supply chain in Zimbabwe and the wider Southern African region. This Public Policy sets out the principles, standards and commitments that govern how the Company conducts its mineral trading business in a manner that is lawful, ethical, transparent and beneficial to the communities and countries in which it operates.

This Policy is published to provide clarity and assurance to government authorities, regulators, host communities, business partners, employees and the general public regarding the standards the Company holds itself to. It reflects the Company's recognition that mineral resources are a shared national asset, and that trading in these resources carries a responsibility that extends beyond commercial gain to encompass sustainable development, good governance and respect for human rights.

This Policy applies to:

• All directors, management and employees of Explonat Minerals, whether permanent, contracted or seasonal.
• All agents, brokers, transporters and intermediaries acting on behalf of the Company.
• All suppliers, buyers, joint venture partners and contractors engaged in mineral sourcing, processing, transport or trading activities connected to the Company.
• All operations, offices and trading activities conducted by the Company, in Zimbabwe or in any other jurisdiction where the Company does business.

Every business relationship entered into by the Company is conditional on the counterparty's willingness to operate in a manner consistent with the principles set out in this Policy.

Licensing & Registration

The Company will only trade in minerals sourced from holders of valid mining, dealing or export licences issued by the relevant national authority, including the Ministry responsible for Mines and Mining Development, the Minerals Marketing Corporation of Zimbabwe (MMCZ), or equivalent bodies in other jurisdictions of operation.

Documentation & Traceability

Every consignment must be accompanied by complete, verifiable documentation — certificates of origin, mineral movement permits, royalty and tax clearance records, and export or transfer permits where applicable. The Company maintains a chain-of-custody record for all minerals from point of purchase to point of sale or export.

Taxation & Royalties

The Company will meet, in full and on time, all applicable royalties, levies, duties and taxes due to national and local authorities, and does not engage in or knowingly facilitate under-declaration of mineral value, smuggling, or any form of illicit financial flow.

Sanctions & Prohibited Trade

The Company will not knowingly trade with any individual, entity or jurisdiction subject to applicable international sanctions, nor participate in the trade of minerals originating from conflict zones where such trade would fund armed conflict, human rights abuses or unlawful armed groups.

Know Your Supplier

Before entering into any purchasing relationship, the Company conducts reasonable due diligence on suppliers to confirm lawful ownership or right to sell, the legitimacy of the mining or extraction activity, and the absence of association with unlawful armed groups, forced labour or child labour.

Artisanal & Small-Scale Mining (ASM)

Where the Company sources from artisanal and small-scale miners, it does so in a manner that supports formalisation of the ASM sector, fair and transparent pricing, and safe working conditions, consistent with national efforts to bring small-scale mining into the formal, taxed economy.

Quality, Weighing & Fair Pricing

All minerals purchased or sold are weighed, assayed and valued using calibrated, verifiable methods. Prices offered to suppliers reflect prevailing market rates and mineral grade, and are communicated transparently before any transaction is concluded.

Conflict-Free Commitment

The Company aligns its due diligence practices with recognised regional and international frameworks, including principles consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, and regional frameworks promoted through the ICGLR and SADC, where relevant to its operations.

• The Company prohibits bribery, facilitation payments, kickbacks or any other form of corrupt inducement, whether offered or received, in any dealing with public officials, business partners or private individuals.
• Gifts and hospitality extended in the course of business must be modest, transparent, properly recorded and never intended to influence a decision improperly.
• Employees and agents are prohibited from using Company resources or position to obtain undue personal advantage.
• Conflicts of interest must be declared promptly to management and recorded in the Company's conflict-of-interest register.
• The Company applies a zero-tolerance approach to fraud, money laundering and the falsification of records or mineral documentation.

While Explonat Minerals is principally a trading entity rather than an operator of mines, the Company recognises its responsibility to use its market position to encourage environmentally responsible extraction among its suppliers and partners.

• The Company will not knowingly purchase minerals from sources engaged in illegal mining in protected areas, water catchments or ecologically sensitive zones.
• Suppliers are encouraged to implement land rehabilitation, erosion control and responsible tailings management at their extraction sites.
• The Company minimises the environmental footprint of its own logistics, storage and processing operations — responsible fuel use, waste management, and dust and noise control at trading facilities.
• The Company supports national efforts to combat environmental degradation associated with unlawful and unregulated mining activity.

• The Company provides a safe working environment for all employees at its offices, weighbridges, storage and trading facilities, in line with applicable occupational health and safety legislation.
• Personal protective equipment, safety training and incident reporting procedures are provided and enforced for all relevant roles.
• The Company promotes safe handling, storage and transport practices for all minerals, including any materials requiring special handling.
• Suppliers are encouraged to uphold basic safety standards at extraction sites, including protection against unsupported pit collapse, safe equipment use, and access to first aid.

• The Company does not use, and will not knowingly trade with suppliers who use, forced labour, bonded labour or child labour in any form.
• The Company upholds the right of employees to fair wages, reasonable working hours and freedom from discrimination or harassment on the basis of gender, ethnicity, religion, disability or any other status.
• Employees have the right to organise and to raise concerns without fear of retaliation.
• The Company respects the land, cultural and livelihood rights of communities located near mineral sourcing areas, and expects the same of its suppliers and partners.

The Company views the communities in which it sources and operates as key stakeholders, not merely as sites of extraction. Explonat Minerals commits to:

• Engaging openly with traditional leaders, local authorities and community structures in areas where the Company sources minerals.
• Supporting local economic development through fair local procurement, employment of local labour where practicable, and community investment initiatives.
• Providing accessible channels for communities to raise concerns about the conduct of the Company or its suppliers.
• Reporting periodically, where appropriate, on the Company's contribution to local development, including employment, local spend and community support.

• The Company maintains accurate and complete financial and trading records, available for inspection by relevant regulatory authorities.
• The Company supports national and regional mineral revenue transparency initiatives and cooperates fully with lawful audits, inspections and reporting requirements.
• Personal and commercially sensitive information relating to employees, suppliers and partners is collected, stored and used responsibly, and is not shared with third parties except as required by law or with proper authorisation.
• This Policy itself is published and made available to the public, regulators and business partners as an expression of the Company's commitment to openness.

Explonat Minerals maintains a confidential channel through which employees, suppliers, community members or any other stakeholder may report suspected violations of this Policy, including corruption, unsafe practices, environmental harm, or human rights abuses.

• All reports are treated confidentially and investigated promptly and impartially.
• The Company prohibits retaliation of any kind against a person who raises a concern in good faith.
• Where a report reveals unlawful conduct, the Company cooperates with the relevant law enforcement or regulatory authority.

This Policy is reviewed by the Board of Directors at least every twenty-four (24) months, or sooner where there is a material change in law, regulation, or the operating environment. Compliance is monitored through internal audits, supplier due diligence records, and periodic reporting to the Board. Amendments take effect upon Board approval and are communicated to all employees, agents and relevant business partners.