Sustainability Policy

Document No. DM-SHEC-0003 Version 1.0

Objective of document This document describes the sustainability commitments for Dynamic Mining in
Guinea.

Verifications and Approvals

Role Head of Function Signature Date
Social and Environmental Lead Catherine Garcia 08/14/2019

HSE Lead Tom Steytler 08/15/2019

Director General Biranchi Pati 08/15/2019

CEO Manas Agarwal 08/15/2019

Version Revision comments Date

1.0 Version 1 14 August 2019

Page 1 of 7 DM SHEC 0003 Sustainability Policy v1

1. INTRODUCTION
Dynamic Mining has adopted a set of policies and procedures related to ESHS (environment, social, health and
safety). These policies and commitments are aimed at aligning with the following standards and norms:
• Guinean legislation, regulation, permits, approvals and strategies. In particular;
o 2010 Guinea Constitution
o Mining Code, Law L/2011/006/CN, 9 September 2011
o Environment Code 045/PRG/87, 28 May 1987 amended by 022/PRG/89, 10 March 1989
o Marine Environment Decree no 201/PRG/SGG/89, 8 November 1989
o Decree no 199/PRG/SGG/89, 8 November 1989 - Environmental Impact Study (EIES)
o Order no 990/MRNE/SGG/90, 31 March 1990 – Environmental Impact Study (EIES)
o The Code of protection of wild fauna Law L/97/038/AN, 9 December1997
o The Forestry Code Law L/99/013/AN, 22 June 1999
o Water Code Law L/94/005/CTRN, 14 February 1994
o Land Code L/99/013/AN, 1992
• Good International Industry Practice (GIIP) that include;
o The IFC Performance Standards, in particular:
− Performance Standard 1 – Assessment and Management of Environmental and Socials
Risks and Impacts
− Performance Standard 2 – Labour and Working Conditions.
− Performance Standard 3 – Resource Efficiency and Pollution.
− Performance Standard 4 – Community Health, Safety, and Security.
− Performance Standard 5 – Land Acquisition and Involuntary Resettlement.
− Performance Standard 6 – Biodiversity Conservation and Sustainable Management of
Living Natural Resources.
− Performance Standard 7 – Indigenous Peoples. Not applicable in Guinea.
− Performance Standard 8 – Cultural Heritage. The Equator Principles.
o The World Bank, including the IFC and its Environmental, Health and Safety Guidelines.
o United Nation’s Universal Declaration of Human Rights and the Voluntary Principles on Security
and Human Rights.
o The Extractive Industry Transparency Initiative.
o The Equator Principles.
o The World Health Organization (WHO)

Page 2 of 7 DM SHEC 0003 Sustainability Policy v1

 o The International Labour Organization (ILO)
1.1. Purpose of Document
The purpose of this document is to describe our sustainability commitments. It describes company leadership,
occupational health and safety, environment and biodiversity, communities, governance, and human resources
commitments. The Sustainability Policy applies to all company executives, management, employees,
contractors and subcontractors. Dynamic Mining is committed to maintaining high standards of ESHS
performance.

1.2. Leadership
We recognize the importance of demonstrating sustainability leadership at all levels of the organization:

• The ultimate accountability for the approval and delivery of our Sustainability Policy rests with the
Dynamic Mining Board.
• Our executives are responsible for leadership in demonstrating commitment to achieving sustainable
outcomes and applying our sustainability policy, principles, rules and procedures in decision-making
and in the allocation of resources.
• Our departmental managers are responsible for ensuring the achievement of sustainable outcomes and
to application of the sustainability policy, principles, rules and procedures and taking appropriate steps
to ensure that the workforce, including contractors and subcontractors meet the policy requirements.
• All staff are responsible for applying the sustainability policy and principles in decision-making and day
to day activities.
• We foster a working environment that leads to continuous improvement of sustainability performance.

1.3. Principles
Dynamic Mining Sustainability Policy is based upon the following principles:
• To provide value to our shareholders, Guinean Government and the communities.
• To comply with, where practicable, Guinean legislation and Good International Industry Practices (GIIP).
• To embed sustainability into business decisions.
• To conduct all business with integrity and honesty.
• To avoid, and/or minimize impacts, and where avoidance is not possible offset residual impacts.
• To ensure all staff, contractors, subcontractors and suppliers are aware of the Dynamic Mining
Sustainability Policy.
• To develop sustainability targets and to continually strive to improve our sustainability performance.

Page 3 of 7 DM SHEC 0003 Sustainability Policy v1

 • To recognize that integration of community concerns and protection of natural resources in the early
planning phases and engagement supports sustainable development, helps keep livelihoods, natural
resources and land for future generations, leading to more constructive outcomes, dialogue and
reduces the risks of community conflict.

2. DYNAMIC MINING COMMITMENTS TO SUSTAINABILITY

The policy describes a set of rules and procedures aimed at addressing leadership commitment towards
sustainability, occupational health and safety, environmental, community, governance and human resources
issues. These Sustainability commitments apply to all our operations in Guinea during the design,
construction and operations phases. The Policy is the main policy document of our ESHS Management
System. The Sustainability Policy commits us to:

2.1. Occupational Health and Safety

• Strive towards a culture of Zero harm to our workforce, contractors, subcontractors and suppliers by
providing a safe working environment.
• Commit to not compromising the safety of anyone to meet production targets.
• Embed health and safety considerations into all business processes.
• Provide occupational health and safety training appropriate to each task, including identifying hazards
and how to work safely around them and take measures to eliminate or minimize risks.
• Ensure and encourage all the workforce to report health and safety incidents and accidents and conduct
immediate investigations, remedial action and take appropriate measures to avoid reoccurrences.
• Provide the necessary equipment and tools to conduct the job in a safe manner and ensure its use.
• Establish procedures that are aligned with best practices regarding occupational health and safety.
• Maintain and promote a positive safety culture, behavior and attitude.
• Encourage individual commitment and responsibility towards a positive safety culture.
• Proactively monitor health and safety performance.

2.2. Environment and Biodiversity

• Embed environmental and biodiversity risks into our wider risk identification and mitigation processes.
• Consider the protection of biodiversity, natural habitats, and ecosystems as a key aspect of
sustainability when designing and developing projects.
• Ensure and encourage all the workforce to report environmental incidents and undertake immediate

Page 4 of 7 DM SHEC 0003 Sustainability Policy v1

 investigations, remedial actions and take appropriate measures to avoid reoccurrences.
• Monitor compliance with Guinean legislation and GIIP and commitments.
• Monitor water, air quality, noise and biodiversity on a regular basis and set targets for continuous
improvement of environmental and biodiversity performance.
• Develop participatory monitoring with the communities, including water, air quality, and noise.
• Avoid, minimize and/or restore negative environmental impacts according to GIIP. We will consider
offsets only after appropriate avoidance, minimization and restoration measures have been applied.
• Aim to minimize use of natural resources including water, land, greenhouse gas emissions, energy
consumption, and generation of waste by avoiding their unnecessary use, reusing or recycling where
possible and selecting techniques with the lowest impact options, wherever possible.
• Minimize generation of dust, noise and pollution from our activities by designing, constructing, and
operating according to industry best practices. In addition, by monitoring and taking appropriate
measures to minimize impacting wildlife and flora and community complaints.
• Aim to achieve “No Net Loss of biodiversity and achieve net gain on critical habitats”.
• Where possible, and after consultation with stakeholders, restore all sites as close as possible to the
original habitat.
• Promote and provide awareness regarding the responsible use of natural resources to the workforce
and the communities.
• Maximize the use of existing infrastructure to minimize project footprint.

2.3. Communities
• Embed social risks into our wider risk identification and mitigation processes.
• Consider the protection of community land and assets, cultural and archeological sites, community
health and safety as a key aspect of sustainability when designing and developing projects.
• Ensure and encourage all the workforce to report all social incidents and grievances and undertake
immediate investigations, remedial actions and take appropriate measures to avoid reoccurrences.
• Engage with communities, NGOs and Government to develop community conservation programs that
focus on community livelihoods and sustainable forests and ecosystems.
• Communicate and consult with the community, including women, young people, the elderly, and
vulnerable people in all matters that concern them, and encourage community participation in decision-
making.
• Participate in the growth and development of the communities where we work.

Page 5 of 7 DM SHEC 0003 Sustainability Policy v1

 • Establish constructive and transparent relations with communities, local and regional government, and
engage with them regarding actions taken and the results achieved in relation to the project and social
and environmental impacts and mitigations.
• Analyse the requests that arrive from the communities based on the positive effect and scale and
manage and develop community programs through a community development fund to maximise the
positive impacts to the communities. Priority areas include culture, sports, livelihoods, small businesses,
training and skills, agriculture, conservation, water, health, and education.
• Develop mitigation measures regarding cultural heritage and archeological sites in close collaboration
with the impacted communities and archeologists.
• Develop and implement a Local Content Strategy and ensure staff and contractors, develop regional
and local targets regarding local employment, training and procurement. Embed the Local Content
Strategy in all contractor requirements.

2.4. Governance
• Not tolerate any form of corruption or unethical conduct by executives, staff and contractors.
• Raise awareness regarding corruption and unethical conduct to all the workforce, contractors and
suppliers.
• Apply the highest standards of honesty and integrity across all our operations in Guinea in all business
dealings and with the Government, partners and communities.
• Uphold laws aimed at combating corruption and bribery.
• Encourage all staff and contractors to report all suspicious behavior regarding bribery or corruption.
• Communicate all authorized payments made to local authorities and to the communities in a
transparent and culturally appropriate manner.

2.5. Human Resources

• Respect the principles recognized by the Universal Declaration of Human rights, the Voluntary Principles
of Security and Human Rights, and the declaration of the International Labour Organization on
Fundamental Principles and Rights and Work.
• Respect the Guinean legal obligations regarding employees or their representatives, guaranteeing
equal opportunities, without any discrimination based on political affiliations, nationality, age, sex, race,
ethnicity and sexual orientation.
• Recognize employee’s freedom to join and/or associate with trade or workers’ unions.

Page 6 of 7 DM SHEC 0003 Sustainability Policy v1

 • Define policies and activities to help with work-life balance and provide a working environment that is
safe and secure, free of harm and harassment.
• Support professional development training initiatives and develop job descriptions that are well
understood.
• Comply with the Guinean minimum age of recruitment, 18 and ensure all contractors and suppliers
apply this requirement.
• Respect and encourage diversity in the workforce.
• Identify, prevent, mitigate and report any actual or potential violation of labour standards.
• Develop and communicate an employee grievance mechanism.
• Employ and promote workers based on merit and ability.
• Treat all the workforce with respect and not tolerate any form of sexual harassment, discrimination,
bullying or violence.
• Maximize employment opportunities and capacity building from the local communities and region.

Page 7 of 7 DM SHEC 0003 Sustainability Policy v1