Sustainability Memoirs

MINEROS 2019 SUSTAINABILITY REPORT
SUSTAINABILITY MEMOIRS – 2019
INDEX
Chapter 1 – About these Memoirs 2

Chapter 2 – Who are we? 22
Chapter 3 – Our Social Responsibility Management 42
Chapter 4 – Our Environmental Management 54
Chapter 5 – Our Economic Management 80
Chapter 6 – Our People 86
Chapter 7 – GRI Content Index 105
MESSAGE OF THE PRESIDENT (102-14)
The 2019 Sustainability Memoirs of Mineros Group, which today is made available to all our audiences and
stakeholders, collects a summary of all actions developed in all fields and territories where we perform
mining activities with responsibility and commitment to the surrounding communities’ progress. We are
convinced that we not only have to ensure responsible mining practices for the society and environment, but
we also have to generate wellbeing and better living conditions for communities within our areas of influence.
Therefore, it makes sense when we say we perform mining activities “for the wellbeing of all”, because we
are aware of the positive impact this has on the growth of these communities, from social and environmental
perspectives, as well as in terms of the economic and productive field.
“For the wellbeing of all” is not an ad or a commercial motto to embellish our corporate object. It actually
constitutes the daily commitment of each of the members of our Organization. Responsible and proper mining
activities, like ours during more than 45 years, make sense when you take into consideration the needs of
communities, when we ask our stakeholders with the intention of knowing their needs and offer better
conditions to improve their living standards, and, even more important, when we assume with deep humility
the meaning of wellbeing for these communities and when we share with them, to achieve this.
This commitment is also reflected when we are able to make these territories end up being much better than
what we found when we initiated our exploration phases. We responsibly assume that such areas shall not
stay the same, or in bad conditions; they have to always become better; and this is a challenge that we also
assume on a daily basis.
These Sustainability Memoirs also collect growth results for this Organization, which has gone from being a
mining company, with alluvial exploitation activities only in the municipality of El Bagre (Antioquia), to
become a mid-size mining operator, with presence in several countries (Colombia, Nicaragua, Argentina and
Chile), with different alluvial, underground and open pit projects which show the path to reach our ambitious
and far-reaching goals (Mega), increasing our annual production from 300,000 ounces to 500,000 troy ounces
of gold on a mid-term, with great potential in our operations at each of the above-mentioned countries.
This growth also has to be aligned with better living standards and development for our communities,
stakeholders and municipalities or locations in which we have activities in the four countries. Only in
Colombia, approximately 50% of the budget of municipalities and departments, depend on royalties from the
mining-energetic sector. This translates into the construction of schools, health centers, communication
networks and recreational parks. This also represents an unavoidable commitment from us.
Colombia is not always aware of the importance of its mining activity, or the fact that the sector requires clear
rules which, in a permanent and stable way, protect this way of generating social development and economic
growth. This sector has to be understood and taken care of, as a source of employment generation,
development for communities, and economic growth for the country, in order to be able to operate in more
competitive conditions.
For us, 2019 was a year of growth for our operations in Nicaragua, with important challenges in Colombia,
acquisition of company control in Argentina, and initiation of our take-off stage in Chile. At each of these
countries, we maintain full conviction and commitment to continue working based on our firm principles and
1
values, which are non-negotiable and are the pillars of our engagement with societies and communities near
our areas of operation, to grow together as we participate in sustainable and responsible mining practices.
For that reason, we continue convinced and committed to advance in the consolidation of regional operations,
acting locally. That is why, 365 days a year, we implement make our motto, “For the wellbeing of all”, a
reality. This is our irrevocable commitment, which we confirm today with the delivery of these 2019
Sustainability Memoirs to you.
Andres Restrepo Isaza

President
Mineros Group
MESSAGE FROM THE VICE PRESIDENT OF THE COMPANY IN NICARAGUA
Year 2019 was a year in which teamwork delivered great results for the entire family of Hemco,
the company of Mineros Group in Nicaragua. All actions taken were with the purpose of
guaranteeing the continuity of best mining practices which facilitate the wellbeing of all, including
the Company, our personnel, the environment and the community.
We are proud to see all our achievements, thanks to the effort of everybody, workers and
neighbors. Together, we promote integral development of the municipality of Bonanza and the
country.
In terms of reduction in accident rates, we continue improving, having a 30% decrease in accidents
vs. 2018. Each one of us adopted the commitment with our families and co-workers by adhering
and adopting a safety culture in order to produce gold with zero accidents. For this, the Company
started a program denominated “Life”, with a stronger approach to personal protection. Precisely
because we know our people are worth gold, we have invested in training and providing new
technical and human skills to our workers, through the leaders’ formation program.
We also took an important step towards modernization and standardization of our processes with
the implementation of SAP. Thanks to this system, we will be aligned with the other operations of
Mineros Group, being able to centralize and sort data from all areas, to work in an articulate and
more efficient way, to achieve our goals.
Mining developments promoted by Hemco in 2019 had a very positive impact on the economy
and quality of life of municipalities where we operate, especially at Bonanza, where through an
Ordinance and Urban Development Plan promoted by our Company and the municipal
government, we were able to generate USD$ 8 MM in social investment, purchase of services and
sub-contracts with local companies and cooperatives, during the year. The generation of these
new entrepreneurships cover Hemco’s demands, and offer employments of quality, which cover
social security and work development according to environmental and occupational safety
standards of the country, creating safe work awareness which goes beyond the Company and
consolidates in the region.
2
The Bonanza model was also strengthened. This is a unique work mechanism of small-scale
mining, which strives to organize and sustainably develop such an important commercial activity
for our municipality, which at the same time, translates into wellbeing for all. Specifically, we focus
on promoting the formalization of the sector, with integral development of cooperatives and
training sessions on work safety and environmental management.
With regards to our environmental responsibility, we contribute with soil recovery through the
closure of a total of 226 environmental assets located in the Bonanza concession, emphasizing
small-scale mining assets and closing Vesmisa Tailings Dam.
We also leverage the region’s biodiversity and conservation of water resources, planting 202,542
native species, out of which 76,333 were planted with small-scale miners. We preserved 1,605
hectares of forests located in the buffer zone of Bosawas Biosphere Reserve, receiving recognition
for our excellent waste management in the VI National Recycling Forum and Entrepreneurs Fair for
Watsuna Sanitation Complex, which is “unique in the region”. We contributed to the continuity of
our Company, with environmental responsibility and developing the expansion project of San José
Tailings Dam, with an approximate annual investment in environmental management of USD$
12.2.
These are only a few samples of our achievements. We hope to continue in 2020 with our
entrepreneurial development, always guaranteeing our workers’ safety, improving the living
conditions of the community of Bonanza, and ensuring the conservation of natural resources of
the region.
Carlos Mario Gómez Peláez

Vice President, Hemco Nicaragua
MESSAGE FROM THE VICE PRESIDENT OF THE COMPANY IN COLOMBIA
These 2019 Sustainability Memoirs account for our most important achievements and challenges
in search of our commitment with the “Wellbeing of all”. This motto demands our daily efforts to
increase economic and social wellbeing of our communities, along with taking care of the territory
where we have operations.
In our mining business in Colombia, during 2019, we faced important operational challenges,
which are reflected in a lower than expected production due to delays in making viable our
environmental processes in areas within our mining plans. However, we highlight the Company’s
perseverance in maintaining our operational teams during the whole year, generating an EBIDTA
margin of 32%, in alignment with the strategic objectives of the Group.
Likewise, we had a good year in terms of energy business, with sales of approximately COP 10
billion. As part of lessons learned and a continuous improvement process, we have been adjusting
the Company’s operational structure and processes, creating the Sustainability Management
position and consolidating a new operational model. This is how we intend to maintain our
business value, with main focus on environmental processes, giving greater relevance to feasibility
3
and restoration processes to be sustainable and generate jobs and economic benefits for the
development of the region and country.
Thanks to a negotiation focused on a cordial and respectful environment, we were able to

subscribe the Collective Bargaining Agreement for a period of two years. It is important to mention
the unwavering support from our workers and Union members to understand the needs and
challenges of the organization, as well as their alignment in order to achieve our common goals.
As part of our sustainability model, in 2019 there were no significant incidents with environmental
impact to report, as result of efforts of our workers and contractors.
We continue contributing to the construction of regional development alternatives with a long-

term vision. Partnerships initiated with the United States Agency for International Development -
USAID, in 2018, “Golden Women” and “Let’s Progress, Lower Cauca” programs in operation for 4.5
years, allowed us to focus the efforts of our Company, our Foundation and allies in the economic,
political and cultural development of Antioquia’s Lower Cauca region, with initial results that fill us
with hope.
Let us maintain our commitment to strengthen legal, social and economic development of
Antioquia’s Lower Cauca region, through the promotion of local purchases and support to
entrepreneurships. Regarding formalization and standardization of mining processes, we continue
with a pilot program under the modality of operation contracts that will allow structuring new
work schemes, with benefits for all parties. Also important is having given support to the
acquisition of environmental license by Emijorn (Empresa Minera de Jobo Medio), a pilot program
in the form of areas’ assignment.
We are proud of having finished the first phase of pavement of the road Escarralao – El Bagre,
which allows the connection of El Bagre with the 4G road network that goes from Medellín to
Caucasia. This was performed under the “Work for Taxes” mechanism and has been classified as
the project with highest investment and greater number of beneficiaries in the country. We
especially value the commitment of departmental and municipal governments which ended their
terms in 2019, who helped us make this work a reality. We still have 5.8 additional kms. to go,
which will be ready in the near future.
As a contribution to biodiversity conservation, in 2019 we returned two mining concession titles of

approximately 950 hectares, which were included in the Integral Water Management Project of
the Regional District of El Sapo – Hoyo Grande Marsh, a conservation area declared by
Corantioquia, located in the municipalities of Nechí and Caucasia, with a total area of 12,227
hectares.
We finished 2019 with three very good news, which will be important levers to implement the
planned strategy: in November we were granted the Mining Social Seal in Antioquia, recognizing
us as a company with best practices in social investments made by mine title holders in the area of
influence. Also, in November Corantioquia, the territorial entity which rules our environmental
regulations, awarded us the AA Sustainability Seal, which engages us into continuing doing things
correctly, “for the wellbeing of all”. Finally, in December, our alluvial operation was classified as
Strategic Project of National Interest (PINE, for its acronym in Spanish), for being an operation
which generates impacts in the development of the country and the region, now and in the future.
4
Let me take advantage of this opportunity to reconfirm our gratefulness for contributing to our
operational growth, highlight the commitment of our workers and Unions, enabling us to get
closer to our proposed goals and contribute to comply with the Mega. Today, we are even more
aware that the families making part of the municipalities in our area of influence are the strength
and origin of our operations, who since the beginning have worked “for the wellbeing of all”.
Santiago Cardona Múnera

Vice President, Colombia
MESSAGE FROM THE VICE PRESIDENT OF DEVELOPMENT OF NEW BUSINESSES AND STRATEGY,
VICE PRESIDENT, ARGENTINA AND CHILE
The acquisition of Gualcamayo Mine in Argentina was an important milestone for Mineros. We
added a new deposit, with a new type of mining process and a different culture. However, we
discovered that we shared the same values, the same environmental commitment and the same
desire to generate social and community development, thanks to mining activities. In 2019, we
acquired control of Minas Argentinas and started an integration process with Mineros’ culture,
respecting their working methods and generating an interesting common learning synergy.
Gualcamayo is a mine which mainly makes part of the community of Jachal, a district located north
of the capital of the province of San Juan. It also involves other smaller communities located in La
Rioja province, a political jurisdiction different from San Juan, but close to the deposit. There we
developed different programs to strengthen social institutions, promoting sport activities,
especially focusing on educational development of children and youngsters, contributing with
productive micro-entrepreneurships which generate economic sustainability, as well as positive
impacts generated by the mine, among many other activities.
Gualcamayo also contributes with a percentage of its income to a trust fund allocated to
infrastructure work in nearby communities. The definition of these works is done with local
authorities. In 2019, we committed an important amount of resources to improve and expand
Jachal’s agricultural irrigation network. This is a fundamental project for the agricultural
development of the area, where rainfall barely reaches 200 mm per year. Having irrigation water
determines the success or failure of crops. This work will be executed at the beginning of 2020 and
will benefit approximately 50% of the crop producers of Jachal.
In 2019, Gualcamayo renewed its ISO 1400:2015 Standards on Environmental Management and
OHSAS 18001:2007 for Occupational Health and Safety. Likewise, the International Code for
Cyanide Management was re-certified for three additional years. All this confirms that the
operational standards and practices in the deposit are in compliance with the highest global
standards.
In the arid area where the mine is located, we developed a reforestation plan to help mitigate
impact of sunlight and generate landscaping improvements. This allowed including more than
1,500 native species. In 2020, we will be extending the plan beyond the deposit’s boundaries, in
5
benefit of nearby communities. We will work this initiative along with local authorities and
technical schools of the area will produce and provide varieties to be planted.
With regards to safety, Gualcamayo stood out for not having any serious accidents which affected
our workers’ health. In spite of that, training programs for workers were intensified and continue
in order to maintain good performance in terms of Safety.
We have a challenging year in front of us. In 2020, Gualcamayo will continue working together
with its workers, communities and local authorities to ensure our mining work translates into
works and projects “for the wellbeing of all”.
Eduardo Flores Zelaya

Vice President, Argentina and Chile
ABOUT OUR SUSTAINABILITY MEMOIRS

(102-46) (102-49) (102-50) (102-53) (102-54)
We present to our stakeholders the Sustainability Memoirs according to the Essential Option of
the Global Reporting Initiative (GRI) Standards and the Mining and Metals supplement,
corresponding to the period from January 1st to December 31st, 2019.
There have not been any significant changes in the reporting scope with respect to the previous
report; in terms of coverage, we have included relevant material information about our operations
in Argentina, which were not included in 2018 Sustainability Memoirs, given this operation was
acquired in late 2019.
Compañía Minera de Ataco did not perform any mining activities.
These Memoirs report our performance during 2019, according to principles of social,
environmental and economic sustainability, which implies providing information necessary to
understand the nature of our Entrepreneurial Group, material topics, the most representative
impacts generated and how these issues were managed, as well as our contribution to achieve
sustainable development objectives.
Information reported analyzes the Entrepreneurial Group’s performance to allow internal and
external stakeholders have a clear knowledge of management implemented with the purpose of
reaching our sustainability objectives.
As we have done without interruption since year 2008, when we started presenting our work
under GRI Standards, we ratify in this 2019 version, our commitment to inform with transparency,
our sustainability management results to stakeholders. This is information on company
sustainability for the Mineros Group’s companies: Mineros Aluvial, Operadora Minera, Negocios
Agroforestales, Fundación Mineros, Compañía Minera de Ataco, Hemco from Nicaragua and Minas
Argentinas.
6
Lastly, the opinion of our stakeholders is of vital importance for Mineros S.A. Entrepreneurial
Group. Therefore, we appreciate your sending to www.mineros.com.co, any comments, questions
or doubts about information included in these Memoirs.
Our Stakeholders
[102-42]
We keep friendly relations with our stakeholders, based on compliance and transparency and we
assume the commitment of keeping them informed of what we do at the Corporate Group in terms of
economic, social, and environmental development and to improve life quality of communities around
our operation areas.
Stakeholders
[102-40]
Relations with Our Stakeholders
Shareholders:
We keep a close and transparent relation with our shareholders, who are provided with
relevant information about our performance and results while we seek for sustainable
and profitable growth, as well as value generation.
7
Authorities:
We respect institutions and abide by the law. We interact with national, regional, and
local governments and support social development projects through permanent
dialogue and concertation, without substituting the State’s responsibility. We
acknowledge law enforcement agencies as the only guarantee of public order.
Communities:
We practice responsible mining activities and we work to improve the living standards
of communities around our operations and we promote with them sustainable
development, collective wealth generation, social inclusion, and democracy
consolidation.
*IIRC integrated reporting framework, https://integratedreporting.org/wp-content/uploads/2015/03

/13-12-08-THE-INTERNATIONAL-IR-FRAMEWORK-SPANISH-1.pdf
Employees:
Relations with our employees are based on mutual respect and acknowledgement of
their individuality and integrity. We provide work development opportunities and skills
improvement to retain the best human talent.
Unions:
We keep a close, kind, and respectful relation with four unions that operate under total
freedom to exercise their union activities and are guaranteed dignifying work conditions
under strict compliance with human and work rights.
Small-scale Miners:
In Nicaragua we have relations with small scale miners’ cooperatives and groups, and
we offer them technical support to strengthen their best social, environmental, safety,
and work practices. We support life quality improvement projects for their families and
the communities they are part of. In Colombia, supporting governmental efforts to
formalize small-scale mining.
Third Sector:
With Non-Governmental Organizations (NGOs), associations and foundations that
operate in our production area, we keep a respectful and collaborative relation to
promote common wellbeing and community life-quality improvement.
Suppliers and Contractors:

We promote trustworthy and mutually respectful relations and we have clear and
updated procedures based on transparency and compliance of legal regulations, with
clearly defined standards under the Code of Ethics to guarantee long-term relations.
Guilds:
We are members of the most important sector guilds in each country, with whom we
maintain permanent relations to strengthen the mining sector position and its
contribution to national and local economies, as well as development of best mining,
environmental, and social practices.
Third Sector:
With Non-Governmental Organizations (NGOs), associations and foundations that
operate in our production area, we keep a respectful and collaborative relation to
promote common wellbeing and community life-quality improvement.
8
Opinion Builders and Leaders:

With media and opinion-builders we keep a trustworthy and respectful relation, we
provide them permanent and relevant information about the Corporate Group, and we
develop relating plans with media and leaders that have influence on communities near
our operating areas.
Native Towns:
We respect cultural integrity and ancestral traditions of the native towns present in our
operating areas and we keep constant contact with them to know their needs and to
meet their expectations.
El Bagre
We consider an issue is material when it may affect the capacity to create value at short, medium,
and long term*, and it exerts a significant influence on stakeholders’ decision-making processes. In
order to make more rigorous the identification process of issues that shape materiality, we have
updated our analysis on these issues to reflect more clearly the positive and negative impacts and
affectations that are particularly relevant and meaningful to our internal and external stakeholders.
For the construction of the materiality matrix, we use as information source two processes and
references drafted by Grupo Mineros S.A.; one aimed at the Company team to classify issues they
consider relevant for the operation and stakeholders; the other, conducted with different stakeholders
in each operation, indicating the level of relevance and priority which stakeholders assigned to the
most sensitive issues.
To draft them, we took into consideration different environmental management international

standards, highlighting AA1000/2018, SA8000, GRI Sector Supplements, ISO 26000, in addition to
the experience in different environmental, social, economic, and ethnic contexts of the countries
where we operate.
Materiality Matrix
[102-47]
The issues we searched for to draft the materiality matrix were broken down into five different
categories, as follows:
9
Material Issue Group Searched Issues
Economic development • Employment generation.

• Small-scale mining economic and organizational
development.
• Local goods and service purchasing and sourcing.
• Local economic alternative generation.
Social performance • Ethics and transparency.
• Investment and social development.
• Strengthening of local governance.
The environment • Environmental impact management.
• Natural resources protection and efficient use.
• Environmental management and risks.
• Recovery of exploited areas.
• Mine close down.
Work practices • Occupational health and safety.

Human rights • Human Rights respect.
• Claims and complaint system.
By crossing the relevance assigned by stakeholders and the Corporate Group, we identified which
were the issues that have the greatest potential to influence our stakeholders decision-making
process, that we consider essential for sustainable development of our business strategy. This
becomes a road map to differentiate issues that must be prioritized in our sustainability strategy
performance.
In addition to this, it is important to explain that as a result of the materiality exercise, “strengthening
of local governance” and “mine close down” where excluded from the matrix because they were not
pointed out as a priority by the stakeholders. Nevertheless, these issues are still relevant under the
Group’s sustainability strategy and, thus, we shall keep managing them as important issues to
develop our business.
Finally, although stakeholders’ assessment of our performance in the management of the most
important issues is an important indication to keep building a sustainable relation, we believe it is
important to inquire other aspects that also influence this interaction. This analysis is developed in
the following section.
10
Materiality
Each issue group shown in the Materiality Matrix has a color code to make identification easier, as
follows:
Economic development
Social performance
Environmental management
Work practices
Human rights
1. Employment generation
2. Small-scale mining economic and organizational development
3. Local goods and services purchasing and sourcing
4. Local economic alternative generation
5. Ethics and transparency
6. Investment and social development
7. Environmental impact management
8. Natural resources protection and efficient use
9. Environmental risk management
10. Exploited area recovery
11. Occupational health and safety
12. Human Rights respect
Stakeholders’ Inquiry Results
[102-21] [102-43]
11
As mentioned, to draft our 2019 Sustainability Report we updated

Stakeholders’ Survey
the materiality analysis and included new tools to make it more
rigorous and give visibility to our stakeholders’ main perceptions, Methodological
expectations, and priorities in terms of the way we operate. For Explanation
that purpose, a survey was conducted in Colombia during the first
quarter of 2019 and in Nicaragua and Argentina, in 2020. These Due to corporate policies and
questions sought to assess each material issue identified in agreements with our
terms of: (i) Stakeholders’ knowledge of our performance level on shareholders, the survey
each issue; (ii) perception of our performance; and (iii) relevance process with our stakeholders
assigned by our stakeholders to identified material issues. is conducted every two years.
For our Colombian operation,
Issues asked to our stakeholders are grouped in five dimensions:
it was held in early 2019, with
Social performance, human rights, economic development, work
practices, and environmental management. We shall present the 529 participants. In February
results of the survey in this same order. Each section starts with 2020, surveys were conducted
the added score of our performance according to our in Nicaragua and Argentina,
stakeholders, using a 0 to 10 scoring scale. Then, specific issues with 240 and 180 participants,
inquired in each category are developed. respectively. These surveys
were conducted by an external
Knowledge and Performance of the Mining Group of Material consultant, Arteaga y
Issue Management Asociados. Results of the
three operations were
Before addressing material issue results, we believe it is
homologated for this report.
important to raise awareness of the fact that stakeholders
acknowledge our efforts to provide information on social and
environmental management, guarantee information quality, and
identify and effectively mitigate operation impacts. These were the general perceptions:
90% believe Grupo Mineros identifies and manages operation impacts adequately.
80% state they do receive Grupo Mineros environmental and social performance information.
76% say information provided by Grupo Mineros on performance is good-quality information.
Social Performance
Social Performance Average Score
Colombia Nicaragua Argentina Grupo Mineros
Knowledge 6.6 6.7 6.4 6.6

Performance 6.2 7.1 6.8 6.7
A mutually beneficial relation with the environment that generates Assessed Social
social wellbeing is essential for the Group’s sustainability strategy. Performance Action
However, this is the performance dimension with the lowest score Lines:
among issues submitted for consideration, indicating we have an
improvement opportunity in the implementation of social responsibility • Social investment
actions. projects.
• Timely and quality
In terms of stakeholder’s knowledge of the level of our social communication with
performance, we have: stakeholders.
• Local governance
48% state having high knowledge of social investment. strengthening.
12
54% state having high knowledge of timely and high-quality communication processes with every
stakeholder.
51% state having high knowledge of social performance.
Now, when assessing performance, the relation is inverted. The lowest score, although in general
terms it is in an average level, almost high, is given to Timely and quality communication of our
operation and the best score is given to Social investment program implementation. Nevertheless,
these three considered issues are in an average level, in terms of the score scale.
Performance
Inquired Material Issue Score
Social investment program implementation to
improve people’s wellbeing and life quality. 6
Social .
performance Joint work with local government. 6
.
Timely and quality communications of operation-
related efforts. 6.5
It is important to consider the communication channels issue because it challenges the way we are
managing dialogue and relations processes. Along these lines, there is an opportunity to review if the
way we manage information meets stakeholders’ needs.
Finally, we assessed if our social performance improved, was worse, or remained the same versus
the previous year. To that respect, we highlight that 36% of participants consider our performance
improved versus 2018.
Stakeholders are more reluctant to acknowledge our performance in terms of generating a continuous
and timely communication on the reality of our operations. This creates the need to generate more
proactive communication mechanisms.
Human Rights
Human Rights Average Score
Knowledge 6.4 5.3 6.0 5.9

Human rights compliance and promotion is a priority in our operations.

Guaranteeing high-standard compliance in our way of doing things is Assessed Human Rights
fundamental to efficiently manage risks associated to our business. Action Lines:
Stakeholders gave scores to our performance in the middle of the • Human rights respect
scoring range. Results indicate that the claims and complaint system and promotion.
performance and knowledge is the main aspect to be improved,
keeping close relation with items found in the social performance
assessment.
35% in Colombia consider having high knowledge of Mineros Human Rights performance.
13
58% of the participants in 2020 consider having high knowledge of human rights compliance and
promotion.
38% of the participants in 2020 consider having high knowledge of the claims and complaint system
performance.
It is required to try to achieve more productive and efficient channels to manage our stakeholders’
demands and expectations. Additionally, results show a gap in the performance assessment between
human rights compliance and promotion and the claims and complaint system.
Performance
Inquired Material Issue Score
Human rights compliance and promotion 7.6
Human rights Claims and complaint system correct performance 6.1
The survey in Nicaragua and Argentina on performance of a claim and complaint system, versus the
previous year, which prevents, mitigates, and compensates human rights’ vulnerabilities,
guaranteeing compliance and protection, indicates that it improved by 25% and remained the same
by 37%. It must be highlighted that 30% pointed out that they do not know or do not answer, which is
a challenge, because we must review the way we communicate our human rights efforts
There is an important gap between the way we are seen as a Company that complies with and
promotes human rights and the knowledge of a basic claim and complaint mechanism in our human
rights management strategy. Greater appropriation and knowledge of the claims and complaint
system is required as core of our strategy.
Economic Development
Economic Development Contribution

Average Score
Knowledge 6.4 6.9 6.3 6.5
In a 0 to 10 scale
Our objective to develop mining activities committed to the regions where we operate, implies being
a relevant sector in economic development. This is part of our value promise.
We believe issues directly related to our operation, such as hiring workforce, tax payment, and
strengthening small-scale mining in Nicaragua, have better performance assessment than those
related to strengthening the economic tissue and relation to goods and service purchasing. The
accumulated scores indicate an average level, both in terms of knowledge and performance.
Results also show a remarkable gap between the survey results between Colombia 2019 and
Nicaragua and Argentina 2020, evidenced in the following data:
35% in Colombia considered there was high knowledge in terms of economic development
contribution.
14
58% of participants considered there was high knowledge in terms of hiring labor force and
purchasing goods and services.
69% of participants in 2020 in Nicaragua considered there was high knowledge of efforts made to
strengthen small-scale mining.
Tax payment and local workforce hiring are the best assessed issues in our performance. There is
also a significant gap in the perception on our small-scale mining management: While in Colombia in
2019 only 26% considered we had high performance, in Nicaragua this score was 74%. An
explanation of this difference has to do with the way to operate and the level of articulation small-
scale mining has in Nicaragua.
Inquired Material Issue Performance Score
Local workforce hiring 7

Goods and service purchase from local companies 6
Economic
development Performance of efforts to strengthen other economic
activities in the region, such as agriculture, trade, and 6.2
tourism
Support to the development of artisan and small-scale

mining 6.2
Tax payment 9
,
Finally, we would like to highlight that 55% of participants stated that our performance in terms of
economic development contribution improved versus 2018.
There is a gap between the way we are perceived by our stakeholders in issues related to our
business model and operations and those related to economic strengthening of environmental
conditions. The best assessed issues are workforce hiring, tax payment, and small-scale mining
strengthening in Nicaragua.
Work Practices
Work Practice Average Score
Nicaragua Argentina Grupo Mineros
Knowledge 8.1 7.5 7.8
Performance 7.6 7.8 7.6
Providing optimal conditions to our employee in a friendly corporate

Assessed Work Practice
environment that encourages human and professional development is
Action Lines:
one of our key lines within the sustainability strategy. Both in
knowledge and performance of these issues, the score level was high.
• Development of policies
and activities to guarantee
75% of participants in 2020 considered we have high knowledge of
protection and wellbeing
efforts made to guarantee employee safety, healthcare, and wellbeing.
for every employee.
• Adequate performance of
It is worth mentioning that the work practice issue was not prioritized
work relations and
in our 2019 survey but only the results obtained; therefore, only the
solution to Union issues.
results for Nicaragua and Argentina are indicated.
15
Nevertheless, we evidence a gap in our performance because it is assessed better in the

development of activities and policies aimed at generating wellbeing among employees than with
respect to adequate performance in work relations and union conflicts resolution. However, in both
cases, the scores are high. This is consistent with the perception that, in comparison to the former
year, 54% of the results consider the Group performance has improved.
Development of policies and activities to guarantee 7.2

employee protection and wellbeing
Work practices
Adequate performance of work relations and union 6.1
conflicts resolution
The stakeholders survey shows our commitment to generate wellbeing, both from our employees and
external help, is acknowledged and valued.
Environmental Performance Average Score
Knowledge 7.1 7.1 6.6 6.9
For mining activity to be a sustainable development vector in the places Assessed Environmental
where we operate, it must have high standards that reflect our Management Action
commitment with environmental care and protection. Lines:
Environmental management is the best assessed dimension by our • Water, soil, air, and
stakeholders, with high performance. However, they state having an energy protection and
average level of knowledge on the issue. This indicates the need to efficient use in the
close the gap between knowledge of our performance and the way our operation
performance is assessed: • Development of effective
measures to maintain
50% in Colombia considered they had high knowledge in terms of biodiversity
Mineros’ environmental management. • Environmental impact
prevention and mitigation
62% of participants in 2020 considered they had high knowledge of and liquid waste adequate
impact mitigation measures and operational risk management. management
• Cyanide spill prevention
65% of participants in 2020 considered they had high knowledge of • Intervened area recovery
strategies for protection and conservation of natural resources.
16
Water, soil, air, and energy efficient use and 7,6

protection during exploitation
Environmental
Development of effective biodiversity conservation 8.0
Environmental impact prevention and mitigation and
adequate management of liquid waste. Prevention of 7.9
cyanide waste.
Implementation of effective activities for recovery of

intervened areas by the operation 7.7
In comparison to the previous year, 44% consider our performance in terms of environmental issues
has improved.
Environmental performance was the best assessed issue by our stakeholders. However, it is
important for our sustainability strategy to work to close the gap between assessment and the
knowledge these groups have about our environmental efforts in order to assess our management
and performance.
Stakeholder Groups’ Identification of our way of doing things
For the Group, it is fundamental that our operations are a development factor in regions where we
operate. Results of this survey reflect that our efforts are visible to stakeholders:
83% coincide with the fact that the main contribution of our operation is employment.
85% of our stakeholders indicate that the economy of the regions where we operate would be worse
if we stopped operating there.
Our relations with the environment and our stakeholders should not be exclusively based on a
transactional issue because it is not a sufficient condition for the construction of sustainable long-
term relations. Therefore, we acknowledge that it is not enough to just comply with minimum operation
standards and requirements.
Thus, for this Sustainability Report, we measured levels of legitimacy and credibility in our operations
in order to determine to what extent there is a trust relation with our stakeholders. Therefore, we
resorted to premises by Thomson & Boutilier (2011), whose basic premise is to determine that a good
relation based on trust with communities around the operation is a key factor to reduce socio-political
risks that mining projects might face.
The following table shows percentages of participants who agree with the statements we measured
for the level of trust and empathy with our operation:
Statement Submitted to Consideration GM

We believe the director of HEMCO Nicaragua and MASA (Minas Argentinas) have 66%
taken the initiative to inform us about aspects that might affect our community
The region communities believe in HEMCO and MASA 71%
The community and HEMCO/MASA share a similar vision on the region’s future 75%
HEMCO/MASA directors are interested in community concerns 81%
The community believes HEMCO/MASA treat communities with respect 83%
HEMCO/MASA listen to the community 84%
Communities nearby the operation are satisfied with the relation they have with 84%
HEMCO/MASA
17
So far, HEMCO/MASA have complied with their commitments with communities near 85%
the operation
The community and HEMCO/MASA have a mutually beneficial relationship 86%
HEMCO/MASA respect the community lifestyles and their way of doing things 86%
Information disclosed by HEMCO/MASA is believable 87%
The community sees in HEMCO/MASA a partner to enable life quality improvement. 88%
The community believes HEMCO/MASA has brought more benefits than problems 89%
The community wants to have more activities like the one HEMCO/MASA have in the 89%
region
Our community considers HEMCO/MASA’s presence is positive for the future of the 92%
region
From these questions, and considering levels proposed by Thomson & Boutilier, we have for our
operations in Nicaragua and Argentina a score of 79.3 (in a scale from 0 and 100), within the trust
level:
Range Identification Level Nicaragua Argentina

85 - 100 Psychological identification 38.5% 32.3%
75 - 85 Trust threshold 29.6% 33.2%
60 - 75 Approval 17.3% 23.4%
50 - 60 Credibility threshold 7.8% 5.1%
35 - 50 Acceptance 3.9% 4.3%
25 - 35 Legitimacy threshold 1.1% 1.3%
0 - 25 Retention / Withdrawal 1.7% 0.4%
Median 80.8 77.8
The percentage of each level corresponds to distribution of participants in the different levels of trust
level. Scores obtained prove that our relation with each stakeholder group goes beyond a
transactional matter and is based on the commitment with our environment in search of credibility,
reflecting one of the governing principles of our sustainability strategy: Our commitment with the
development of regions where we operate.
Now, it is required to acknowledge that although the level of trust for each statement is really high (all
of them over 60%), there are gaps that must be closed:
 It is required to address the “proactivity to report issues that might affect the communities”.
This reflects a clear demand by some of our stakeholders for a better communication of
negative issues derived from our operation, as well as the way we manage them.
 It is important to take the initiative, to innovate our processes and constantly interact with our
shareholders to continuously strengthen the trust and empathy links with the way we operate.
 Almost every participating stakeholder group agrees with the fact that our operations
generate wellbeing and development in the regions where we operate. However, we must
strengthen our performance in the creation of links and the development of other local
economic capacities in order to avoid the generation of dependency schemes.
18
Our Commitment with Sustainable Development Objectives
[102-12]
The 17 Sustainable Development Goals (SDG) defined by the United Nations

Organization in 2015, welcomed by every member State, seek to end poverty and
hunger, guaranteeing food security, better nutrition, and protecting the planet for
everyone in the world to have peace and prosperity under a goal set for 2030.
Our alignment as organization with the SDGs supports our management focus in
favor of sustainability, clean production, and responsible mining; we seek to comply
with these goals, reducing poverty in the regions where we operate, strengthening
social programs, and making a responsible use of natural resources.
Grupo Mineros is aware of its commitment with the partnership in this field, including
corporate social responsibility, environmental sustainability, and economic
development promotion.
These are the sustainable Development Goals we align with in every area and
process of our performance:
19
About us
20
No. of Employees in the Corporate Group:
Employees by Country
We are a public company traded over the Colombian Stock Exchange, whose main activity is
extraction of gold and other precious metals. We have had 45 years of uninterrupted operations and
we have grown through acquisitions in other countries, following a path some of the largest mining
companies in the world have followed, going from local players to regional and global players.
21
Corporate headquarters of the Group are located in Medellin, capital of the Department of Antioquia,
in Colombia.
Mining operations in Colombia are located in the towns of El Bagre, Nechi, and Zaragoza in the Lower
Cauca subregion of Antioquia, in two fronts: Alluvial mining, in El Bagre and Nechi; and underground,
mining, in Zaragoza. We have two hydroelectric plants: Providencia I and Providencia II in Anori to
supply required energy to our operations.
In Nicaragua, our company has its mining operations in the town of Bonanza, in the Region Autonoma
de la Costa Caribe Norte (RACCN – Autonomous Region of the Northern Caribbean Coast) –where
it has 26 mining concessions in the Nicaraguan Mining Triangle, made up by the towns of Bonanza,
Siuna, and Rosita, in two large underground and small-scale mining fronts. We also have two
hydroelectric plants: Siempre Viva and Salto Grande.
In Argentina, mining operations are conducted north of San Juan Province where Gualcamayo mine
is located where the operation is conducted underground and on the surface.
Operation Zones
[102-4]
Export Destination
[102-6]
Argentinian operation
22
Main Customers
Corporate Structure
[102-7]
Partnerships that Make up the Corporate Group
23
Strategic Focus
The performance of Grupo Empresarial Mineros is framed by a corporate sustainability model based
on Good Governance, Social Responsibility, Environmental Management, Occupational Safety and
Health, and Quality Assurance pillars.
Our aim is to generate the highest value for our shareholders, increasing liquidity of our share and
access to a larger number of investors and international institutions through the growth and
sustainability of our mining operations, committed to implementing responsible mining work with
24
conservation and protection of biodiversity and natural resources, as well as development of

communities and the regions where we are present.
Our purpose is to develop initiatives with a positive impact among stakeholders, having innovative
proposals aimed at everyone’s wellbeing.
Our strategic vision guides us to make progress in the expansion of our operations in the Americas,
based on best corporate practices and sustainability translated into well-done and responsible mining.
We feature passion, persistence, and dedication to our work to achieve great challenges beyond our
own frontiers.
Main Strategic Goals The Mega Guides us:
Grupo Empresarial Mineros

S.A. shall accomplish an
Increase liquidity of our share in the Colombian Stock
annual production of 500,000
Exchange.
troy ounces of gold with
operations in Colombia,
Nicaragua, and Argentina, as
Access to a larger number of investors and well as other countries in the
international institutions. Americas, complying with our
principle of sustainable mining
and continuous profitable
growth greater than or equal to
Accomplish an annual production of 500,000 troy 30% of EBITDA margin.
ounces through organic growth and small-scale
mining.
Mission Vision
Grupo Mineros is a private organization devoted to gold In 2020, Grupo Mineros shall be
and associated metal mining, aimed at generating the renowned for the profitable growth of
most value for its shareholders with the growth of its its production and its great
mining operations through an excellent management performance in the environmental,
system framed by corporate social responsibility. human, and social responsibility
areas.
Corporate Group Values, Principles, Standards, and Conduct
[102-16]
The Corporate Group has set forth a set of values, policies, and conduct norms that guide our
behavior through the interaction with our employees, communities, public servants, and, in general,
with everyone we interact with as required from a responsible and respectful mining exercise.
Honesty  We are transparent, we tell the truth, and we do the right thing.
 We are guided by ethical principles, we respect authorities, and we comply
with normativity.
 We are coherent with what we think, do, and say.
 We generate trust by consistently complying with our commitments.
Respect  We acknowledge the value of cultural diversity and thought.
25
 We value individual and community diversity and autonomy.

 We promote human rights and encourage environments of healthy co-
existence.
 We build relations based on trust and kind treatment.
Responsibility  We assume causes and consequences of our own actions.

 We act consciously assessing the effect of our behavior and decisions.
 We assume selfcare and maintenance of a safe environment as the
fundamental base of our daily work.
 We apply environmental practices that guarantee sustainability of natural
resources.
Solidarity  We act for the wellbeing of the company, our stakeholders, and the
environment.
 We privilege collective benefit over personal interests.
 We work collaboratively to achieve common results and goals.
 We give aid and support to those in need.
 We seek to be useful and serve others.
Simplicity  We are genuine, we acknowledge mistakes, and we take advantage of

them as an opportunity for personal growth.
 We act authentically without presumption or boasts.
 We learn from one another and we support others in the achievement of
personal growth.
 We listen to opinions and we open our minds to new ways of doing things.
26
Integral Performance Policy
We do responsible mining work to promote sustainable development for

everyone’s wellbeing, seeking operational excellence with innovation and
continuous improvement. We work with empowered, ethical, and competent
staff respecting human rights and legal requirements.
Risk Management Policy
We focus through a systematic process on risks affecting our operations and

on compliance of our strategy to take advantage of business opportunities and
manage events that might vulnerate the achievement of our objectives.
Internal Control Policy
We define the application of our Internal Control Policy under the COSO
(Sponsoring organization of the Treadway Commission) structure, understood
as a process conducted by the Board of Directors, the Management, and the
employees designed to provide reasonable security in terms of operational
effectiveness and efficiency, financial report reliability, asset protection, law and
regulation compliance based on self-control principles, efficiency and
effectiveness, and maintenance of three lines of defense to manage risks and
controls.
Environmental Policy
We respect and value natural resources, encouraging their rational and

sustainable use. We are committed to the protection of the environment by
implementing strategies that enable the responsible development of our
operations, mitigating, controlling, and compensating possible negative
impacts and boosting positive impacts within the applicable legal framework
and agreements voluntarily subscribed.
Occupational Safety and Health Policy
We encourage selfcare and safe behavior in the activities we develop,

foreseeing and controlling associated risks seeking to keep our employees,
contractors, and other stakeholders’ integrity, life quality, and health under the
legal framework and continuous improvement.
Sustainability Policy
We make available for communities where we perform our productive activity,

a set of resources and capacities so mining-generated benefits contribute to
the economic development, responsible use of natural resources, human rights
respect, and better life quality and wellbeing of the community.
Human Rights Policy
We respect internationally acknowledged human rights in every function and at

every level of the organization. We perform due diligence processes to identify,
prevent, mitigate, and respond to negative consequences our activities might
have on human rights during the entire cycle of mining operations according to
set-forth international standards and agreements subscribed in every country
where we operate.
27
Contracting Policy
We respect business with our suppliers based on process transparency and

legal regulations’ compliance. We favor companies located in our sites of
operation, under equal competition and adequacy. This is done by providing, if
required, a training walkthrough to improve technical quality, competitiveness,
and human development of our staff.
Employment Policy
We select and hire human talent under equity, independence, and transparency
principles focused on generating quality, stable, legal, and adequately paid
employment, respecting social, sexual, race, and gender conditions according
to technical profiles required by the organization to keep a highly qualified team.
When new hires are required, we prioritize on people who live in our operation
sites. To fill in vacancies, priority is given to our employees.
Integral Security Policy
We comply with security polices set forth by the State and its legitimate
institutions, we respect citizens’ rights, we acknowledge enforcement agencies
as legitimate guarantee of law and order, we keep good relations with the
community and the government, and we reach through dialogue, the legal ways
to solve potential conflicts to safeguard the integrity of our employees and
assets of the organization.
Communications Policy
We focus on improvement of the perception and reputation of the organization,

within and beyond it, aligning information with the strategy of the Corporate
group, highlighting best performance and sustainability practices that
strengthen and position our brand before its stakeholders and in the countries
where we operate.
Independence Policy
We respect the Rule of Law and exercise of democracy in the locations where
we operate.
Personal Data Policy
We protect adequate treatment of personal data and guarantee the protection

of information and titleholders’ rights, implementing protection mechanisms for
jurisdictions where we operate according to current and applicable legislation.
Information Security Policy
We protect and regulate our information and third parties’ information as a

valuable asset for the organization, respecting, acknowledging, and complying
with licensing and copyright requirements, committing our employees to
responsible and ethical use, both in data management and custody,
confidentiality and disclosure through authorized channels.
28
Prevention of Money Laundering and Terrorism Financing
We conduct due diligence processes and adopt measures to prevent and avoid
any company that is part of the organization from being used as a vehicle for
illicit activities related to asset laundering or terrorism financing.
Corporate Governance
[102 -18] [102-19] [102-20] [102-22] [102-25] [102-28]
Good governance practices at Grupo Mineros is a tool aimed at generating credibility on the way we
operate so human rights of those who invest in shares, seeking for transparency, objectivity, and
equity to treat partners and shareholders, find adequate management of the business, responsibility
before internal and external control bodies, and respect for transparent performance and public
knowledge.
Structure of the Upmost Governance Body and its Committees
[102-23]
• Eduardo Pacheco Cortes
• Jose Fernando Llano Escandón
• Santiago Perdomo Maldonado
• Alberto Leon Mejia Zuluaga
• Juan Carlos Paez Ayala
• Alberto Mejia Hernández
• Miguel Urrutia Montoya
• Nicolas Duran Martinez
• Alvaro Escobar Restrepo
• Carlos Rodrigo Pacheco Cortes
• Lucia Taborda Giraldo
• Alejandro Sanchez
• Carlos Eduardo Caballero Argaez
• Beatriz Uribe de Uribe
In average, members of the Board of Directors have ten-year terms, they are independent members
who do not have any other position in the organization.
The Chairman of the upmost governance body does not have any other executive position in the
organization.
Board of Directors and Top Management Assessment Processes
In 2019, a self-assessment process of the Board of Director for the 2018 – 2019 period was
conducted.
29
Corporate Governance Structure
The Corporate Governance structure sets forth an effective separation between the three levels of
governance: The General Shareholders’ Meeting, the Board of Directors, and the CEO. This structure
is public, clear, and transparent, making it possible to determine clear lines of responsibility and
communication and enabling strategic steering, supervision, control, and effective administration of
the Corporate group.
The Board of Directors has three support committees:
Audit and Risk Committee
The objective is to support the Board of Directors on its duty to supervise through evaluation of
accounting procedures, the relation with the auditor and, in general, the review of the Partnership
Control Structure, including the audit of the risk management system. It also assists the Board of
Directors in compliance with their risk management overseeing their duties.
Good Corporate Governance Committee
Its objective is to support the Board of Directors in the exercise of duties related to analyses,
assessment, and supervision of compliance with the Good Governance Code, the Good Corporate
Governance regulations, policies and, in general, every Good Governance document. It also has the
duty to propose amendments to such documents and policies according to the needs of the
partnership and the current best practices.
Nomination and Remuneration Committee
This committee supports the Board of Directors in the appointment, training, and assessment of
members of the Board of Directors or Top Management, and in the definition of remuneration policies
of the partnership. However, decisions on economic, environmental, and social issues directly
depend on Top Management and the Board of Directors.
Executive Level Positions with Responsibility on Economic, Environmental, and Social Issues
Each operation in the three countries where the Group has exploitation projects, has an executive
position responsible for the leadership of environmental, social, and communications issues.
Economic issues directly depend on the Financial Vice-Presidency of the Group.
Conflict of Interests
With respect to procedures conducted by the upmost governance body to guarantee avoiding and
managing conflicts of interests, the partnership makes sure every case is treated accordingly.
The partnership has a procedure to minimize any such conflict, under the Good Governance Code,
available at www.mineros.com.co when a Board of Directors member or any other manager is part of
a transaction or contract to be executed by the partnership (regardless of whether it is or not a material
relation); when a manager or executive of the party intending to execute a contract or perform a
transaction with the partnership, or has any other type of interest or material relation on any issue
that involves the partnership (hereinafter denominated the “Affected Party”) that may directly or
indirectly influence his/her decisions.
Authority Delegation
Bylaws and Corporate Governance documents set forth duties and powers of the direction bodies
that clearly define which ones are not possible to be delegated. Additionally, through the Institutional
Relations Framework Agreement (Annex 2), the Group established rules and principles that apply to
each company and their managers and employees in regards to economic, legal, administrative, and
30
operational relations to align the interests and objectives of each company that is part of the Group
and generate more value to their shareholders through the growth of their mining operations, with an
excellent integral management system framed by Corporate Social Responsibility.
Main Shareholders
Name Share Percentage
Banderato Corp. 17.70%
Vince Business Corp. 12.13%
Corporación Financiera Colombiana S.A. 8.54%
Inversiones Maga S.A. 5.76%
Fondo de Pensiones Obligatorias Colfondos Moderado 3.73%
Negocios y Representaciones S.A.S. 3.47%
Vasquez Merchan i Cia S C A 3.27%
Fondo de Pensiones Obligatorias Porvenir Moderado 3.21%
Other shareholders with les tan 3% each 36.43%
Note: These are the nine main shareholders of Grupo Mineros as of December 31, 2019.
Directive Team
[102-22]
31
Corporate Ethics
[102-16] [102-17] [205-2]
Ethics for Grupo Mineros represents a set of guiding values for each person to act, which translates
into their behavior.
The Corporate group sets a series of behavior values, principles, policies, and standards available in
the Code of Ethics, which serves as guideline to lead relations and personal and professional
treatment between the organization and its employees, suppliers, communities, and other
stakeholders.
We particularly highlight a series of conducts that seek to set guidelines and directions for the
behavior that Grupo Mineros expects to rule its daily actions. The most outstanding ones refer to
respectful treatment and no discrimination, information management and confidentiality, prevention
of money laundering and terrorism financing, rejection of children’s labor, equitable treatment, no
bribery, economic privileging, human rights respect, partnership assets and resource usage, risk
management, occupational health and safety, work or sexual harassment, accountability, event
participation and sponsorship, gifts, and entertainment, social media and internet, and respect of
copyrights.
Risk Management
[102-15] [102-29] [102-30]
Precious metal exploration and exploitation activities are the base of our business model,
which implies considering potential characteristics and risks that may affect our performance.
32
We focus through a systematic process, on risks that affect our operations and compliance with our
strategy in order to take advantage of business opportunities and manage events that may vulnerate
the achievement of our objectives.
In 2019, the organization adjusted its risk management model under a top-down focus according to
its Corporate strategy.
This focus confirmed most of the Corporate risks identified in 2018, allowing the assessment of new
risks arising in the mining industry and increasing the relevance in the assessment of controls as
enablers for strategic compliance.
According to the defined model, assessment of the corporate risks is evaluated by combining
assessment of the probability and impact (inherent risk matrix) with the level of performance and
control perception applied to each risk, to get the residual risk matrix, as follows:
Number Risks
RC1 Mining opposition resurgence
RC2 Sociopolitical uncertainty (cultural, economic, legal, political, security, and

social)
RC3 Failures in the acquisition and integration of new projects

Strategic
RC4 Inadequate definition and deployment of the corporate strategy
RC5 Difficulty to get licenses and authorizations to operate
RC6 Damage to Mineros reputation
RC7 Incorrect estimate of mineral reserves and resources or lack of them
RC8 Inadequate relations with stakeholders
RC9 Inadequate management of human capital

Operational
RC10 Production (gold) information loss
RC11 Resistance to digital transformation and inadequate cyber-risk management
RC12 Lack of energy sources to support operations (energy matrix)
33
RC13 Fraud or corruption risk

compliance RC14 Incompliance of legal and compliance requirements to operate
RC15 Inadequate management of civil, legal, and social responsibility associated to

Mineros operations
RC16 Cost management inefficiency when generating value

Financial
RC17 Inadequate financial resource management
RC18 Commodity price volatility or loss of relevance
Likewise, risk system governance involved in a

relevant way to every level of the organization,
describing responsibilities that guarantee
employees’ contribution to their duties.
This model was defined at Corporate level in 2019

and in 2020 the plan was to strengthen its
deployment in the different countries where we
operate, through validation of risks and
identification of local risks, training of their
employees, and creation of a risk management
culture.
34
Certifications
[102-12]
Minas Argentinas
Gualcamayo Mine
Gualcamayo, like Minas Argentinas S.A., has been certified for the third time with the Cyanide
Management International Code (April 1, 2019): https://www.cyanidecode.org/signatory-company-
categories/minas-argentinas-sa-argentina. This certification is granted by ICMI (International
Management Cyanide Institute).
Gualcamayo has been certified by its Integrated Health, Safety, and Environmental Management
System in compliance with ISO 14001:2015 and OHSAS 18001:2017. The management system is
audited annually by Intertek.
Mineros Aluvial Operadora Minera
 ISO 14001: Environmental Management  ISO 14001: Environmental Management

System System
 Scope: Gold and associated metals  Scope: Gold and associated metals
exploration and exploitation exploration and exploitation
 OHSAS 18001: Occupational Health and  OHSAS 18001: Occupational Health and
Safety Assessment Series Safety Assessment Series
 Scope: Gold and associated metals  Scope: Gold and associated metals
exploration and exploitation exploration and exploitation
Initiatives We Endorse
[102-13]
Voluntary Initiatives
35
 Company and human rights ruling principles.

 Voluntary principles related to safety and human rights
Organizations We Are Part of
[102-13]
2019 Awards
Argentina – Minas Argentinas
Corporate Merit Award 2019 – 2020
Granted by: Mining Service Chamber (CASEMI) and Supermarkets and Stores members of the San
Juan Chamber (CASSA).
Date: December 2019.
Minas Argentinas was awarded with the Corporate Merit Award 2019 – 2020 under Metalliferous
Mining Company category.
This award was set forth based on a poll conducted by the School of Social Sciences at San Juan
National University, in Argentina.
This is the third year in a row that Minas Argentinas receives an award acknowledging a set of
company or institutions perceptions and qualities, including its:
36
 Social reputation
 Service and/or product quality
 Customer or user satisfaction
 Corporate Social Responsibility
 Market positioning
 Achievements and trajectory
Well-Done Mining Practice Award
Granted by: Nicaraguan Mining Chamber (CAMINIC)
Date: July 1, 2019
 Within the framework of the Mining Worker’s National Day held on July 1st, the Nicaraguan
Chamber of Commerce awarded Hemco for being a company that practices Well-Done
Mining in a responsible way with its employees, the environment, and the community.
 Planting 202,542 native plant species, execution of 12 social projects for the community, and
close work with small-scale mining from the Bonanza Model.
Excellent Management of Waste in the VI Recycling National Forum and Entrepreneur Fair
Granted by: Recycling National Forum (FORARE).
Date: August 23, 2019
Award to Hemco for its excellent waste management at the VI Recycling National Forum and
Entrepreneur Fair. Participation, support, and awareness raising of the Company’s waste
management policies, being the only one in Nicaragua with a sanitation complex with these features.
Mining Pride Award
Granted by: Nicaraguan Mining Chamber (CAMINIC)
Date: December 14, 2019
 Carlos Mario Gomez, Hemco CEO Leadership, for the promotion of mining sector
investments.
 Commitment with economic development of communities through social and environmental
programs and generation of employment in the country.
Civic Merit Honorary Medal
Granted by: Bonanza City Mayor’s Office
Date: October 6, 2019
Contribution to construction of the Bonanza “We dream about” and “For the wellbeing of all”. Bonanza
City Mayor’s Office granted Hemco the Civic Merit Honorary Medal within the framework of its 30 th
anniversary. The participation and support of the Company was also acknowledged for over 30 social
programs performed since 2008, in benefit of 40,000 people in the city.
37
Antioquia Mining Social Seal, Great Mining Project in the Economic Exploitation of Precious Metals
category
Granted by: Antioquia Mining Secretariat
Date: November 14, 2019
For the development of the best private social investment practices in its direct and indirect influence
area, in order to avoid, mitigate, and assist social impacts generated by the development of its mining
projects, as well as for increasing opportunities and generating benefits.
Corantioquia Environmental Sustainability Seal, AA Category
Granted by: Antioquia Center Regional Autonomous Corporation (Corantioquia), valid for one year.
Date: December 6, 2019
 Using environmental management differentiating elements within the framework of its

productive processes.
 Promotion of the implementation of current environmental legislation.
 Committing to the purpose of environmental sustainability in Corantioquia’s jurisdiction.
 Implementation of sustainable consumption and production programs, efficient use of
resources, and reduction of waste generation along with the circular economy concept.
Alluvial Operation, a strategic project
In December, Alluvial Operation was mentioned as a Strategic National Interest Project (PINE) for
being an operation that generates, and shall generate, impact on the development of the region and
the country.
The Media
Corporate
 La Lingotera, Intranet
 Somos Mineros, magazine for employees and their families
 Mineros al Dia, internal electronic newsletter
 Enterate, corporate mailing
 Press releases
 Quarterly contact with investors
Colombia
 e-mail
 En Resumen, newsletter
 Enterate, corporate mailing
 Physical and digital bulletin boards
 Text messages
 Press releases
38
 Mineros de Corazon radio broadcast
Argentina
 Electronic newsletters To make our activities known

 Corporate e-mails and to set permanent and open
 Corporate news application dialogue with our
 Press releases stakeholders, we have different
media and communication
Nicaragua channels we use to relate.
Some of them are:
 HemcOro internal newsletter
 Corporate murals
 Small-scale Mining Cooperative murals
 Employee mailings
 Hemco en La Comunidad, radio broadcast Websites
 Small-scale mining, Whatsapp messages www.mineros.com.co
www.hemco.com.nl
 El Minero educational section and press releases
 El Semanario newsletter Social Media
 Press releases for Private Company Higher Council
(Cosep) and Nicaraguan Producers and Exporters
Association (Apen) magazines, as well as the Nicaraguan
Mining Chamber (CAMINIC) website
 HEMCOmunidad printed newsletter.
39
40
At Grupo Mineros, we are committed to supporting the development and wellbeing of communities
where we have mining operations. Our intervention is aimed at generating better economic, social,
environmental, and human rights conditions, as well as strengthening local governance, peace, and
co-existence, trying to contribute to better living standards in the communities.
Programs and projects that we promote and support in the countries where we have our mining
operations are related to the promotion of economic development, urban and rural infrastructure
improvement, education, health, recreation, and sports, as well as community strengthening.
Our social performance is deployed in Colombia at the Lower Cauca subregion, in urban and rural
areas of El Bagre, Zaragoza, Nechi, and Anori towns.
In Argentina, in San Jose del Jachal, capital of Jachal, and 18 other districts, as well as Colonel Felipe
Varela, Province of La Rioja, bordering with San Juan province, municipal seat, Villa Union and three
other communities near Gualcamayo mine.
In Nicaragua, our social performance mainly takes place in urban and rural areas of Bonanza town.
In the relation we keep with communities and their organizations with local governments and public
and private institutions, we maintain open participation spaces to achieve, through dialogue and
agreements, an answer to their needs and mitigate impacts caused by mining operations.
We highlight the more relevant programs and projects of our social intervention in every country
where we have operations.
41
Social Investment US$
1,809,849
1,986,310
1,393,282
Corporate Social Responsibility programs 762,625
Mineros Foundation 381,383
Social actions (donations) 249,274
Economic Development
Our purpose in this issue is aimed at generating better opportunities and revenues in the communities
by giving support to their productive efforts.
Apiculture Promotion Program:
In Colombia, in 2010, we started the Apiculture Promotion

Program that has become an important economic alternative
that generates income to peasant families in the Lower Cauca
(Antioquia) subregion.
Apicultural families are affiliated to the Lower Cauca and

Southern Bolivar Apiculture Association (Asapibas). Today, the
association assumes administrative duties and supplies them
with required tools and utensils for the activity and is in charge
of commercialization of product wholesale under a private label, as well.
In 2019, production of honey and honey byproducts grew up to 24 tons, representing eight tons vs.
the previous year. On sales of honey and honey byproducts, the association generated revenues for
US$ 152,955 and additional revenues for US$ 85,514 on services, memberships, and donations
received.
To improve productivity, two laboratories are in operation for the production of bee biological cores
with capacity for 125 beehives to keep growing and populating its production units.
To support this program, voluntary contributions of workers of the Company outstands, because it
comes from their own salaries. In 2019, their contribution came up to US$ 7,464.
Fish Farming Promotion Program:
This program is in progress in 17 suburban counties of the towns

in the influence area of mining operations in Colombia, where 69
productive lakes have been built and are farmed by 167 families.
Fish farming activities were strengthened with new species:

87,030 cachama fries, 117,000 bocachico fries, and 13,100 tilapia
fries.
42
Golden Women – USAID Alliance:
In 2019, in alliance with USAID (United States

Agency for International Development) and the
Company Jaime Arteaga & Asociados, as
operator, this program started in Colombia, with
the purpose to contribute to empower women in
mining areas and progress in gender equality
issues in three mining towns: El Bagre, Zaragoza,
and Nechi, developing efforts in areas like politics,
economics, and culture.
The program promotes participation of more

women to lead political and home decision-making
processes to turn knowledge and social attitudes
into gender equity.
In 2019, the first year of the alliance, the

participation of groups of women were outstanding
in debates for mayor election for the 2020 – 2023 period, training programs to empower 124 women
with support of the Learning National Service (SENA) and the development of digital skills and
customer service for 50 additional women.
Let’s Go, Lower Cauca – Alliance with USAID:
With the participation of USAID, Antioquia Family Compensation Institution (COMFAMA) and
Interactuar, as operator, this Colombian program has the purpose of strengthening rural economic
development through agricultural value chains, with particular emphasis on apiculture, based on
productive, corporate, market access, financial services, and employment strengthening for the
economic improvement of actors that intervene in the production chain.
In addition to this, it seeks to strengthen non-agricultural productive units through corporate and
technical walkthroughs, setting up commercial connections, financial services, and employments that
respond to regional and local market opportunities, and contribute to economic development of the
territory. The program is performed in the towns of Caucasia, Taraza, Caceres, El Bagre, Nechi, and
Zaragoza.
43
In 2019, we advanced in the socioeconomical

characterization of producers associations, in
the prioritization of apicultural and fish farming
chains, and identification of performance and
opportunity gaps to speed up local association
and company economic growth and financial
strength. As a complement, technical
assistance was provided to participating
associations.
Other activities developed in Colombia are

those related to economic development of the
region corresponding to Support to the
Environmental Miner Training Center (CFMA)
at SENA, to hold the IV Entrepreneur Fair with
the purpose to awaken innovative processes
and strengthen an entrepreneurial culture and creativity.
In Argentina, through a mechanism called Alliance Seminar, that has taken place for the last ten years
with communities of Jachal and Colonel Felipe Varela, we defined support to projects under two
categories: Income Generating Projects (of productive nature that lead to generation of income for
beneficiary institutions) and Social Projects (seeking to improve work conditions of beneficiary parties,
incorporating infrastructure or equipment into their daily work). Under no circumstances, the Company
delivers money in cash, but we do contribute with supplies, machinery, tools, or elements the
institution needs for the implementation of the project. Each institution may submit up to two projects,
one per category.
This way, in 2019 we achieved the funding of 18 small projects; nine of them seeking for generation
of income to beneficiaries. Projects related to supplies for the production of produce, agricultural
equipment, seeds, agricultural equipment, craft wine facility expansion, printing shop equipment, and
industrial embroidery, among others, are highlighted.
44
Social Development
Social Infrastructure
In Argentina, social performance investments

we made through the Fiduciary Fund of
Gualcamayo mine are outstanding. Minas
Argentinas contributed a percentage of its
gross invoicing to this fund allocated to
construction of infrastructure in Jachal, where
the mine is located.
Hence, with these resources a hospital was

built in Huaco and the freshwater network was
renewed in that district. A sports center, an
urban solid waste processing plant, the sewer
network of San Jose del Jachal and its
effluent treatment plant, and the freshwater
distribution plant in that urban center were
also built to benefit over 14,000 people. In
2019, about 2.3 million dollars were allocated
for the expansion and improvement of the
agricultural irrigation channel network to
benefit producers and farmers in the district.
In Nicaragua, we continue with our support to Bonanza Land Use and Development Program
(PODU). In 2019, we supported the municipal government in hiring specialists to promote
coordination work, design, review, performance, and management of 18 projects for the community.
In 2019, about 2.3 million dollars were allocated to the expansion and improvement
of the agricultural irrigation channel network in the city of Jachal, San Juan,
Argentina
Our support to improve urban and rural streets and roads (94 kilometers) and the donation for the
maintenance of equipment and materials to fix roads, as well as contribution of resources for the
construction of sidewalks – Vuelta de la Morava, public lights, rainfall drainage improvement, recovery
of the water system, and installation of benches and garbage cans, are highlighted.
45
We contributed with the supply of electricity for the urban and rural
area of Bonanza, to benefit 2,287 housing units. 982.2 MW were
donated to the two water supply municipal systems that provide the
In an alliance with El Bagre essential liquid to Bonanza’s urban area.
Mayor’s Office, we
intervened the educational In Colombia, we finished the first stage of Escarralao road paving
infrastructure (six project in El Bagre through the mechanism of Infrastructure
institutions), for the benefit of through Taxes contemplated under the current legislation. The first
4,556 students and we five kilometers were paved to Jobo Medio (Zaragoza) Suburban
assisted the paving and County. This reduced traveling time between El Bagre and
adequation of roads for the Caucasia. For the next stage, the remaining 5.8 kilometers are
communities of El Bagre and expected to be concluded up to the bridge over the Nechi River
Zaragoza. that connects to the city of El Bagre.
In Argentina, we supported sports activities optimizing facilities and

contributing with required equipment.
We supported the construction of a tower (50-meter tall) at Videla

Cuello de Jachal School to concentrate at that educational
In Argentina, we developed a
institution information on climatic survey required to fight fruit fly
work training program for
the Special Education School and codling moth (that affects producers), improving internet
“Abejitas de Santa Rita” that connectivity at school and enabling the installation of an
provides education to disabled educational radio broadcasting transmitters.
students.
Additionally, we contributed with materials to improve Manuel
Belgrano Agrotechnical School facilities.
Education
In Argentina, we developed a work training program for students at

In Nicaragua, at the Special Education School “Abejitas de Santa Rita” that provides
Children’s Development education to disabled students.
Center for working women,
small-scale miners, and single In Nicaragua, through the Quality and Culture Educational
mothers, we support daily Program, we provided scholarships to 22 teachers that graduated
nursery care and educational in Physics and Mathematics and we contributed with 32
training for 149 children scholarships to youngsters at Bluefields Indian & Caribbean
between 0 and 5 years of age. University (BICU), one of the two universities that operate on the
Nicaraguan Caribbean Coastal Area providing the Initial Education
Majors.
We contributed with different music, storytelling, painting and drawing workshops, paint art gallery,
visits of the travelling library, library-bingo, and community movie cultural events for children, as well
as with the weekly programming to read tales to first-grade children in the urban area and rural nearby
schools.
Note: To start working in 2020, we expect to have clearance from the national Government on tax amendments applicable to
the Works for Taxes program.
At Cristina Rugama Children Development Center a total of 149 children between 0 and 15 years of
age are assisted, in terms of training and education. These are children working in small-scale mining,
or single mothers. We support the Center with the maintenance and improvement and provision of
equipment and materials (games and toys).
In Colombia, we delivered 70 scholarships to youngsters in the influence area for higher education at
Minuto de Dios University (Uniminuto) in El Bagre. Additionally, we provide financial support to ten
46
college students in El Bagre, Zaragoza, and Nechi who attend classes at Antioquia University (Lower
Cauca campus).
In alliance with Proantioquia Foundation, we continued with the “Become a Better Teacher” program,
whose purpose is to walkthrough school climate improvement programs, under two components: 21st
century competencies (socio-emotional and communication skills) and pedagogical and didactical
dynamization of the classroom addressed to Nechi and El Bagre schools. At the end of 2019, 66
teachers participated in the program.
Also, with SENA, and with contribution of the organization, 80 students from Liberia Suburban County
(Anori town) were certified in solid waste management and agroecology use.
In alliance with Secretor para Contar Foundation, we distributed and promoted the reading of 1,100
collections, contributing with 22 institutions and 145 teachers in El Bagre, Zaragoza, Nechi, and
Caucasia.
With Iberacademy Foundation, we supported El Bagre Symphony Orchestra, where 25 young

musicians participate.
We support the maintenance of the school day in

our area of influence county subdivisions
mobilizing 30 teachers for 40 weeks and delivering
300 school kits to students at six Anori rural
educational centers.
Recreation and Sports
In Argentina, we support sports activities such as soccer, basketball, rugby, cycling, and hiking, as
well as training sessions to sports directors and referees, the sponsorship of local events and
tournaments in different sports, and encouraged participation of youngsters in every sports discipline.
In Nicaragua, 50 youngsters had our sponsorship for their participation in regional baseball events-
We also sponsored the Caribbean Coast baseball team that participated in the First Division National
Tournament. We also sponsored karate, basketball, and boxing sports academies.
In Colombia, in alliance with El Bagre, Zaragoza, Nechi, and Anori municipal governments and the
local sports and recreation secretariats, we supported participation and celebration of regional and
national recreation events in different sports disciplines. We highlight our support to the Chess
Colombian Federation and Antioquean Chess League which made possible, among other things, to
hold the male and female Chess National Championship that nominated the eight best chess players
that will represent Colombia in the Chess World Olympics in Russia in 2020.
47
We supported participation and celebration of regional and national

recreation events in different sports disciplines
Health
In Nicaragua, we support the Ministry of Health with logistical resources, reposition of surgical
material, purchase of medications, equipment maintenance, and conservation and improvement of
physical facilities (restroom systems, painting, water, furniture, and equipment).
In Colombia, we participated in the implementation of the Promotion and Prevention Project (PyP) in
rural communities through Community Nurses Program. With a preventive focus, the program has
developed conferences on healthy life habits, sexual education, and the building of coexistence skills.
In addition to this, we supported the mobilization for health emergencies of 50 people in the rural
influence area to El Bagre healthcare centers.
We promoted the update of the Social Program for Potential Beneficiary Identification System
(SISBEN) and affiliation to the Healthcare Promoter Entity (EPS), as well as registration in certified
personal hygiene, microorganism, sanitation requirements, food manufacturing and preparation, food
packaging, transportation, distribution, commercialization, handling, and sanitation plan courses at
SENA.
At San Juan de Dios Hospital, in Anori, we conducted four health brigades at Liberia Suburban
County, with attendance of 120 people each, in average.
Small-scale Mining in Nicaragua
Our social performance highlights Hemco Nicaragua’s experience with small-scale mining activities,
which became a successful model of coexistence with industrial mining. This has been consolidated
excellent economic and social benefits for small-scale miners and for the Company.
48
Hemco assigns between 3.0% and 4.0% of the concession for

small-scale mining, operated by 14 cooperatives, including two
Cooperatives, between Bonanza and Rosita, two independent
mining groups. in Bonanza and Rosita, three Sand Workers’
Cooperatives, and a Transportation Cooperative. According to We support and finance
the 2019 census, these organizations had 1,697 miners (1,307 cooperatives for the acquisition
male and 390 female) who produced 8,080 ounces of gold. of transportation means; 3.7
hectares were reforested with
In 2019, we kept our commitment to strengthen these native species; a strategic
cooperatives that gather small scale miners with important alliance was built to protect and
activities, like training on occupational safety, the environment, keep Bonanza woods; Small-
first aid, geological guidance, Act 387, and the strengthening of scale Mining Production Unit
corporate governance through managerial information systems was opened in Nueva America
(UPMA) and conferences were
and socio-economic diagnosis, among other issues.
given along with the Ministry of
Family to avoid underage labor.
In the
previous year, 222 liabilities generated by small-
scale mining in Hemco properties were closed
down with an investment of US$ 4,268.60.
In terms of small-scale mining accidentality, 32

events or accidents were registered, involving 44
people. From them, 42 are not members of the
cooperatives, but workers in small-scale mining
sites. Accidents were classified as 27 mild, 8
serious, and 9 fatal.
Mining Formalization in Colombia
As a contribution to mining formalization, we

continued with the implementation of a pilot project through an operation contract with Suministros
Agromineros, a company that operates with a production unit and generates 60 direct jobs. It performs
its operation in a closed pitl with a production of 5,006 ounces of fine gold with zero mercury.
In addition to this, assessment, segmentation, and prioritization processes and procedures were
authorized for candidates to develop a new business model and link new operation contracts. As a
result of its application, seven formalization requests were submitted. These passed the required
internal and external due diligence, selecting four potential operators.
Requests and Complaints Management
In 2019, in the mining operation in Colombia, we received and processed 310 support requests
submitted by El Bagre, Zaragoza, and Nechi communities.
Also, we have a request, claim, and complaint attention mechanism (PQR) for communities,
authorities, and other stakeholders.
Five complaints were received for affectations perceived as caused by the operation (four of them
have been already solved) and 31 for affectations caused by the construction of the Escarralao –
Jobo Medio – El Bagre road (14 of them have been already processed).
49
Visits to the Mining Operation
In Argentina, the Open Doors Program was conducted and in 2019, we received 26 visits and about
600 people in the mining operation of Gualcamayo Mine, where they were exposed to procedures
and standards we work with.
In Colombia, a visit was conducted to the alluvial operation, to the agroforest lots, and the
environmental and social programs with directives and academic staff from Uniminuto University,
Delaware University, the Secretariat of Government, the Secretariat of Transit, and the Mines Director
of El Bagre, as well as Afro-descendant community council representatives from Nechi.
Relations with Institutions and Local Administrations
In Colombia, we promote the

creation of dialogue opportunities
and agreements with communities,
authorities, and institutions. In
2019, different work instances were
developed, such as the
Coordination Group with the Nechi
Mayor’s Office that held three
meetings with participation of the
Mayor and the secretaries.
Additionally, with Zaragoza’s

Community Development office we
held a meeting to exchange
information and define support
agreements to strengthen the
Community Action Boards (JAC).
With representatives from new fishermen associations from Nechi and the Aquaculture and Fishing
National Authority (AUNAP), meetings were held to plan joint actions to support the strengthening of
these associations and the development of a second meeting to review commitments and deployed
performance.
For 2020, we plan to strengthen coordination and mutual support spaces between the Company and
the new city administration which is starting a four-year government term. An agenda was designed
to program visits to mining operations, participation in the drafting of development and land use plans,
as well as destination of joint efforts for the design, performance, and leveraging of initiatives of
mutual interest.
Community Strengthening
In Colombia, we continued having meetings and workshops with communities to raise awareness in
the participation and support of community initiatives.
In 2019, most subjects spun around socialization of the environmental performance plan and
discussion of impact management alternatives and opportunities to socialize the expansion of the
alluvial operations towards the North.
50
51
Environmental Compliance
[307-1]
We conduct our mining operations rigorously complying with control instruments and environmental
legal management. Among these are the Environmental Management Plan, Environmental License,
Environmental Performance Plans, the Statement of Environmental Impact, and all other
authorizations for the use of natural resources in compliance with applicable legislation in the
countries where we operate.
The assessment, control, and follow up of environmental obligations of the different legal control
instruments is regulated in Colombia by the Environmental License National Authority (ANLA) and
Antioquia Center’s Regional Autonomous Corporation (Corantioquia), to whom we periodically report
our compliance and the developed environmental performance.
The Regional Environmental Commission is the authority in charge of assessment, control, and follow
up of environmental legal obligations in Nicaragua. Required licenses for operation of mining
extraction, tailings, and plants, among other projects are granted by the North Caribbean Coastal
Area Autonomous Regional Council (CRACCN) and other authorizations for minor projects are
granted by the Natural Resources and the Environment Secretariat (SERENA). Licenses for forest
use, water management and disposal are processed before the Forest National Institute (INAFOR)
and the Water National Authority (ANA), respectively.
In Argentina, Mining Environmental Control and Audit Direction, affiliated to the Environmental
Management and Mining Control Secretariat, is the organism that controls strict compliance of
environmental and health and security legislation applicable to the operation, as well as conditions
set forth under the Gualcamayo Mine Environmental Impact Statement. This statement was granted
by the Mining Ministry before we started exploitation of the mine, and we update it every two years;
as of this date, it is current, without compliance observations.
In our operation in Colombia, ANLA authorized in 2019 the modification of our Environmental
Management Plan for the alluvial operation, authorizing selective dredging for cargo ships,
exploitation under the closed pit model, and licenses for the use of natural resources, such as forest
use and water concessions. In addition, we executed with Corantioquia a voluntary agreement that
52
would, among others, encourage and support environmental performance and rational use of natural
resources in our territory.
In Nicaragua and Argentina, we continue complying with all environmental legal requirements
keeping and managing the required licenses for the different areas of the operation, giving viability
and continuity to our projects.
For Grupo Mineros, it is a priority to comply with general obligations and, particularly, with national
and regional regulations where we operate which is systematically controlled through routine
inspections to the different areas of operation and through external audits, duly registered in our
performance reports.
Energy and Climate Change
By far, energy consumed in Colombia and Nicaragua comes from renewable sources because we
generate the required energy for our mining and support operations through our own hydro-electric
plants. In Colombia, we have Providencia I and Providencia III hydroelectric plants with an installed
capacity of 18.2 MW, generating through run of Anori river without direct intervention of the water
basin or reservoir.
In Nicaragua we have Siempre Viva and Salto Grande hydroelectric plants, with an installed capacity
of 5.3 MW which are mostly supplied by the Pis Pis river, which springs at Siempre Viva hydroelectric
plant and supplies downstream to Salto Grande plant.
In 2019, Grupo Mineros operation did not have any administrative or judicial
penalties for legislation breaches in terms of environmental protection.
At Grupo Mineros, we recognize the burden of climate change and the challenges its adaptation and
mitigation entail; we have made related efforts, like the reduction of emission of greenhouse gases
through self-generated energy with clean sources in two of our operations, the operation of dredges
with electric engines, carbon footprint measurements, forest compensation, forest plantations, and
the development of measures to manage physical and biotic components. In 2020 we expect to
channel these efforts under a corporate strategy focused on mitigation, adaptation, and governance.
Energy Consumption
[302-1] [302-2] [302-3]
Our operations consumed a total of 198,316 MWh and 60% of them came from renewable sources –
our hydroelectric plants, 27% was bought from the electric grid in each country, and just 13% came
from non-renewable sources, like diesel fuel and Liquified Petroleum Gas (LPG).
Providencia I and III hydroelectric plants in Colombia generated 139,557 MW; from them, we
consumed 96,316 MW to meet our alluvial and underground mining operation needs, our industrial
zone, and our campsites. We sold 43,241 MW as energy surplus. Due to maintenance of our
substations and networks, we operated our diesel plants to supply the operation that generated
79,678 kWh and bought from the national electric grid the amount of 2,038 MWh.
In Nicaragua, 47% of energy consumption came from hydroelectric plants renewable sources,
corresponding to 22,079 MWh; the remaining energy was generated by diesel plants and was bought
from the national electric grid. In this country we did not have any energy surplus to be sold, because
we donated 1% of produced energy to Bonanza freshwater municipal company, consumed for the
collection and distribution of water for home use in nine sectors of the city.
Energy required to operate in Argentina is bought from the national electric grid with a total
consumption of 42,364 MWh. However, given seasonal conditions, we generated heating to the
53
process and administrative areas of the campsite, consuming a total of 11,112 MWh from LPG
combustion.
Energy Consumption in Grupo Mineros Facilities (kWh)
Colombia Nicaragua Argentina
Source 2018 2019 2018 2019 2018 2019
Non-renewable – Diesel/LPG 49,890 79,678 9,431,000 14,797,091 9,712,684 11,111,982
Renewable – hydroelectricity 105,495,129 96,316,224 29,592,000 22,079,126 0 0
Bought from the national electric 2,602,253 2,038,288 7,932,000 9,589,687 45,814,000 42,364,000
grid
Total per operation 108,147,272 98,434,190 46,956,000 46,465,903 55,526,684 53,475,982
2019 Group Total 198,376,075
According to energy consumption in Grupo Mineros facilities and the 296,444 ounces of gold sold in 2019, there is an energetic
intensity ratio of 669 kWh/oz.
As energy consumption out of the Organization, we report consumed energy in our capital assets,
under the upstream activity category, such as our administrative offices in the cities of Medellin,
Managua, and San Juan (Colombia, Nicaragua, and Argentina), where we consumed 684,185,
62,508, and 111,391 kWh, respectively.
To encourage energy saving in Nicaragua,

we run campaigns to promote culture and to
raise awareness on energy use and
implementation of a savings policy through
the installation of gauges at the most critical
points of the process.
54
Reduction of Energy Consumption
[302-4] [302-5]
In Nicaragua we reduced energy

consumption vs 2018 by 1.1%.
Reductions were not higher because in
2019 we started new projects, such as
the Pioneer underground mine, the
expansion of San Jose reservoir, and
underground mining development in
Elefante and Toboba sectors, which
required a greater energy consumption.
This energy consumption reduction was

mainly because in 2019 we conducted
mass campaigns at corporate level to save energy and for the efficient use of energy; we concluded
circuit independence in some areas of the operation; we replaced obsolete or worn-out equipment
with more efficient and energy-saving equipment; we changed 50 outdoor lights for photovoltaic
controlled lights; we centralized five photocontrols and installed three public lighting systems and
started the installation of automatic LED stadium-like lights in new projects.
In Colombia we continued with our “Luz Clarita” program to encourage our employees and contractors
to save and use energy efficiently. We reported energy consumption savings of 9% due to external
factors that affected exploitation progress and, therefore, energy consumption of the dredges.
The project we formulated two years ago, “Efficient Use of Energy”, was materialized seeking to
replace integrated gauging equipment with a software to manage our energy consumption. In 2019,
we installed capacitor banks on dredges to improve the power factor which achieved a loss reduction
in our transmission system, saving 48.58 kW, estimated at US$ 19,000 through the sale of energy
that was to be lost.
In our administrative facilities in Medellin, we implemented a photovoltaic system with generation

capacity of 14.88 kWh which allow us to reduce consumption of energy purchased from the national
network and sell energy surplus.
Our operation in Argentina reported a 7.5% reduction of energy consumption due to production
changes and in part, due to replacement of halogen lamps with LED lamps in our facilities.
Risks and Opportunities Derived from Climate Change
[201-2]
Our operation in Colombia has a risk management system. However, it currently does not identify in
full the potential implications of climate change in our operations. Anyway, having understood the
relevance of the issue and addressing its possible impacts, we have conducted a series of studies
and measures that will be useful as input to identify and quantify risks associated to this problem.
We set forth a baseline to assess risk an identify required measures for the adaptation to climate
changes in Colombia. Therefore, in 2019 we conducted studies and measures for US$ 229,000 to
know the conditions in our environment to be able to control operational impact caused by water level
increase of the Nechi and Anori rivers, drought scenarios for generation of energy, for mining
operations, and for damages to the alluvial control structures (longitudinal mounds) due to increases
in water flow.
55
In Argentina we have not identified major risks or opportunities derived from

climate changes
In Colombia, as a climate change mitigation measure, we conducted flood projections along the Anori
River in our hydroelectric plant for US$ 3.050 and projected for 2020 a hydric balance in our alluvial
operation, as well as the definition of a methodology to analyze risks, with a budgeted investment of
US$ 47,300.
Climate change is progressively affecting precipitation in our areas of influence in Nicaragua. Thus,
in recent years, our hydroelectric plants, Siempre Viva and Salto Grande, notably reduced water
availability and their generation capacity.
We have had the need to generate energy with diesel fuel, causing an increase in our energy
investment and operating costs, estimated in US$ 1.8 million. If we compare hydroelectric generation
in 2018 and 2019, it had a 25% decrease, from 25,590 MWh to 22,079 MWh, increasing diesel
generation by 64%, due to the climate factors and the development of new projects.
To manage this risk in Nicaragua, we conducted a prefeasibility study for the Rosita – Bonanza
transmission line budgeted in US$ 1.8 million, to reduce diesel plant operation and to meet energy
demands in five years, capturing 4.5 MW from the national energy grid, guaranteeing greater energy
availability and stability to comply with our demands generated by the growth of our operation. In
2020, we will also make alliances with the owners of real estate properties for the conservation and
recovery of river basins where our power plants are supplied from.
In our operations in Argentina, we have not identified major risks or opportunities derived from climate
changes which would significantly affect our operations and require the implementation of adaptation
and mitigation measures. We just registered Gualcamayo River’s highwater level due to persistent
rainfall in summertime, which could cause serious damage to the mine’s access roads and,
consequently, paralyze the operation until the emergency is over. To manage this risk, we have
implemented meteorological alerts through upstream cameras.
Atmospheric Emissions
[305-1] [305-2] [305-4] [305-5] [305-6] [305-7]
In our 2019 operations, we continued periodically monitoring air quality and fixed source emissions
to guarantee compliance with defined allowable limits according to applicable legislation in each
country.
Having understood climate change mitigation and adaptation policies and needs, we conducted the
calculation of greenhouse gas emissions in Colombia and Argentina, scopes 1 and 2, for the proper
identification of our emissions to be able to set operational control and make efforts for their reduction,
expecting our operation in Nicaragua to join this effort in 2020.
Greenhouse Gas (GHG) Direct Emission (Scope 1)
In Colombia and Argentina, the main sources Greenhouse Gas Emissions (GHG) are generated by
the combustion of gas and diesel fuels: In Colombia, it is required for the operation of boats, heavy
machinery, and helicopters; in Argentina, for mobility, such as diesel-operated heavy machinery,
trucks, vans, buses, vehicles and support trucks.
In 2019, we achieved GHG reductions versus 2018: In Colombia, equivalent to 2,861 tons of
equivalent CO2, (tCO2e) on less consumption of purchased energy and, in Argentina, 26,476 tCO 2e
56
on lower fuel consumption caused by operating reductions, as well as

the adjustment of the emission factor. In Colombia, we reported a
reduction of emissions versus de base year of 2015 (18,924 tCO2e)
due to changes in operation and less purchases of energy from the
national system.
Greenhouse Gas (GHG) Indirect Emission (Scope 2)
GHG indirect emissions are product of consumption of electrical

energy in our facilities in Colombia, highlighting we are mostly auto-
supplied through the operation of our hydro-electric plants
Providencia I and Providencia III. In Argentina, it corresponds to
electrical energy bought form the national grid.
Given our hydroelectrical auto-supply in Colombia, we do not report

significant GHG indirect emission changes between 2018 and 2019.
There was a considerable reduction versus the base year, 2012,
(5,022 tCO2e), because energy consumption of our operation on that
year depended about 80% on the national electrical interconnection
system.
According to direct and indirect emissions generated and based on

ounces of gold sold in 2019 in our operations in Colombia and
Argentina, there was an intensity ratio of GHG emissions of 0.21
tCO2/oz in Colombia and 0.36 tCO2/oz in Argentina.
In 2019, there were no reductions of GHG emissions as consequence of any initiative or project in
our operations. Reduction reported was mainly due to reasons external to our production capacity.
Emissions of Substances that Deplete the Ozone Layer
In Colombia, we implemented refrigerating gases with HCF like R22 and R410 and HCFC123
(Solkaflam) for portable fire extinguishers that generated 355 kilos of CO 2e in emissions, being R410
the main emission source. In addition, in Argentina we used refrigerant gases R134a, R22, and
R404a, causing an emission of 1,117 tCO2e of substances that deplete de ozone layer.
In Nicaragua, we used refrigerant gases R141B, R22, R410A, R410, and R134A and we are gradually
investing in reduction of these substances, focusing our substitution efforts through technologies free
of CFC and HCFC in refrigeration
systems and water cooling. This
challenge shall be strengthened in 2020
and part of the first initiatives shall be the
calculation of the carbon footprint to make
an inventory of GHG for the entire
organization.
Emission of Particulate Matter and Nitric

Oxide and Sulphur Trioxide
Complying with what was set forth in our

environmental management and control
instruments in each one of our
operations, we conducted air-quality and
fixed-source-emissions monitoring
according to frequency and methodology
defined for each one. We corroborate that
57
we do not have significant emissions into the air, because figures for most parameters are well below
the allowed limits defined under legislation applicable to each country.
Average emissions from our fixed sources located in the metallurgical laboratories of alluvial and
underground operations in Colombia were, in that same order, 6.53 and 164.76 mg/m 3 of particulate
matter (PM10); 1.57 and 2.99 mg/m3 of Sulphur Trioxide and 8.32 and 30.43 mg/m3 of Nitric Oxide,
complying with legislation admissible emission standards, except for the emission of PM10 in the
underground operation that went over the permissible limit of 9.8% due to flaws in the pumping device
of the emission control system; therefore, we proceeded to change the defective components to
guarantee reduction of these emissions.
In Nicaragua, we conducted air-quality monitoring in different areas of our facilities, with an average
emission of 0.04 ppm/day of NOx, 0.02 ppm/day, 0.25 ppm/day of volatile organic compounds, 50.7
ug/m3/day of particles, and 28.5 ug/m3/day of particle matter – PM10, complying with permissible
limits defined under Nicaraguan legislation.
Likewise, in Argentina we have seven fixed-source points of emissions corresponding to the process
area whose PM10, SO2, NOx, and CO parameters are quarterly monitored and provided order
emissions between 0.00079 – 0.07612 mg/m3 of PM10 (concentration -C -24h)), <0.000041 –
0.000386 mg/m3 of SO2 (C 24h), complying with permissible limits set forth under the norm, except
for the CO parameter, that at Caldera’s monitoring point slightly exceeded the legislated limit;
therefore, boiler combustion was regulated as a corrective measure.
Used Materials
[301-1] [301-3]
Mining operations require the use of diverse materials coming from renewable and non-renewable
natural resources used for the extraction and benefit of gold, as well as for support and administrative
activities.
We list main materials used in our operations, which are bought from external vendors. According to
their category, we control and manage them under the required procedures and measures, in
accordance with applicable legislation and standards. Bottling and packaging material are not
reported because they are not applicable to our final product.
Main Materials Used by Grupo Mineros
Material Classification Material Unit Colombia Nicaragua Argentina
Paper Kg 4,147.8 4,400 6,930
Raw Material Wood T 319.7 1,083 0
Iron T 11,477 19 145
Steel T 357.8 1,037 986
Cyanide T 128.79 1,512 2,683
58
Drilling reagents T 134.6 6 3.09
Ancilliary Material Lime T 1,629.2 1,701 10,996
Explosives T 159.1 1,064 2,413
Oils Gallon 61,572.4 30,453 94,782
Gas Gallon 347,609.8 7,769 0
Diesel Gallon 262,081 2,075,676 2,076,438
Semi-Finished Product Grease T 32,712 37 12.04
Oxygen T 60,642 136 2.21
Acetylene T 714 42 0.51
LPG T 6,673 15 793.71
In Nicaragua, we highlight the implementation of new follow-up options and alliances with vendors in
coordination with forest regulating bodies to provide usage alternatives of generated plastic waste,
favoring substitution of wood for plastic wood. In 2020, we expect to reduce pressure on native wood
natural resources and encourage the strategy of circular economy within the Organization, as
incorporated in Colombia to optimize material consumption.
We have implemented preventive maintenance practices strengthening management integral models

like Total Productive Maintenance (TPM), enabling us to achieve reduction of the use of steel in
Nicaragua’s benefit plants, as well as chemical raw materials, like cyanide, through recirculation of
industrial waters.
We have boosted consumption of biodegradable products, like degreasers or exploration raw

material, achieving reduction of hazardous waste generation and, consequently, reduction of
environmental impact associated to final waste disposal or treatment.
Reusable Raw Materials
[301-3]
In our operations, we reuse some raw materials which are reincorporated for different purposes in
our facilities or as contribution to communities in our area of influence, establishing a small-scale
circular economy optimizing some materials, reducing our waste, and favoring our communities’ living
conditions:
 In Colombia, for instance, we reincorporated 25 tires in ports and dredges to buffer the
bumping of our river fleet and after having washed three times 90 steel and plastic containers,
we used them as garbage cans, where required.
 In Nicaragua, we reused materials to be used in our facilities and to support small-scale
mining projects and our communities, such as: 501 steel barrels, 334 steel parts , 647 steel
ladders, 724 rails and sheeting, 1,011 zinc sheets, 458 PVC pipes, 20,591 HDPE and
polyethylene pipes, 469 plastic containers, 607 tires, and 1,797 wooden crossties.
 In Argentina, we reused some materials for other uses, including sleeves we use for
underground mining container tents, remaining of steel fences used for subfloors, fencing
post-hole diggers, bench lumber, oil drums as trash containers, unused hoses to transport
water, and roofing sheets.
59
Water Management
[303-1]
Grupo Mineros is concerned with the protection and efficient use of natural resources. Water
resources are an essential element, not only for our operations, but for the communities and
ecosystem which requires us to take the measures to use this resource responsibly to avoid its quality
deterioration and current and future availability.
Environmental impact of water management is identified through different environmental studies we

conduct to get the required licenses for its use, from relevant environmental authorities who establish
flows to be collected for domestic or industrial use, as required, safeguarding the availability and
quality of surface or underground water resources.
Alteration of availability, quality, and dynamics of water, as well as the negative impact on water-
based utilities, are what we have identified in our environmental studies, finding our they are moderate
or irrelevant given our model of exploitation, where we favor recirculation, and the availability and
quality of water resources in our operations.
We have the licenses from environmental authorities required to collect and dispose of waste from
the different Grupo Mineros operations; we have measuring and gauging systems in order to not
exceed authorized flows, and we conduct periodic monitoring at each associated point under these
authorizations, verifying with certified laboratories the quality parameters and permissible limits of
domestic and industrial wastewater, demanded by the legislation of each country, guaranteeing
compliance and not affecting water resources.
To mitigate impacts generated on the water resources, we apply physical management duly availed
by environmental authorities, being the most outstanding ones, the domestic and industrial
wastewater treatment systems, water recirculation systems, water saving and efficient use programs.
In Colombia and Nicaragua, we use surface and underground water for our alluvial and underground
operations, benefit and support activities, and energy generation recirculating water from alluvial and
underground extraction and benefit processes. In Argentina, we use underground water coming from
two wells to supply the process, areas, campsites, and open-pit and underground mining recirculating
water.
For generation of electricity in Colombia and Nicaragua, we guarantee minimum affectation of water
resources and the aquatic ecosystem using water without altering its quality and quantity. For this
process in Colombia, we use the Anori river water, controlling the ecological quality and flow of the
river by checking its level and flow, enabling us, furthermore, to have early alerts for eventual floodings
during the rainy season.
60
In Nicaragua, we use Pis Pis River water which springs from the discharge of Siempre Viva and flows
into the Salto Grande hydro-electric plant downstream, to flow then into the Waspanona River,
guaranteeing the ecological flow between both hydro-electric plants.
Water Extraction
[303-3] [303-5]
The Corporate group mining operation in 2019 required a volume

of 2.6 m3 of freshwater for the development of exploration,
exploitation, and benefit processes, always complying with Mining and Support Process
criteria and amounts set forth under the legislation of each Water Extraction (M3/year)
country where we operate and encouraging water recirculation
to reduce the affectation of the water resources, to contribute to
its permanence. To generate energy, we used a non- Surface water: 1,325,217
consumptive amount of 561.5 Mm3/year in Colombia and 3.3 Underground water: 219,576
Mm3/year in Nicaragua. Total Operation: 1,544,793
In Colombia, water extraction volume registered comes from

surface sources of Nechi, Anori, and Tigui Rivers and Villa water
stream, as well as from underground water from its exploitation Surface water: 25,156
sites at La Ye mine. Underground water: 99,067
Total Operation: 124,223
In Argentina, water comes exclusively from underground sources
which recirculate in the benefit process and, in Nicaragua, from
surface sources of the Pis Pis and Waspanona Rivers and Surface water: 0
Pioneer and Bonancita canals, as well as from underground Underground water: 1,126,660
waters for domestic and industrial use in Grupo Panama mine, Total Operation: 1,126,660
highlighting in this operation water recirculation in underground
exploration, exploitation, and benefit processes. MINEROS GROUP TOTAL:
2,795,675
In Colombia, we extracted 1.5 Mm3, 14% of which come from
underground waters in our underground mining operation used to benefit gold and for domestic use
in the field. The remaining 86% of water is used to benefit the alluvial operation and for domestic use
in the fields. From the total volume collected, just 14% is required for industrial use, corresponding to
218,863 m3 emphasizing that for our alluvial operation in 2019, we did not extract water, since we
operated on closed-well basis.
61
From extraction reported in Nicaragua, we contributed 22,600 m3 for supply in two sites of the
Bonanza town complying with our
commitment with the community and
the improvement of their life quality.
In Argentina, underground water

extracted was 1.1 Mm3, that we used
to supply process areas, campsites,
open-pit mining and underground
mining, as well as fresh water added
to the recirculating circuit of
processes to moisturize mineral
added to the piles and to supply
evaporation losses.
Volume reported in 2019 vs 2018

evidenced a decrease of extracted
water from available sources,
reflecting our commitment to rational
water use and optimization in our processes. In Nicaragua, through recirculation, water collection was
reduced by 86%, with extraction of 734,129 m3. In Argentina, we reduced 340,481 m3 of underground
water, and in Colombia we reduced a volume of 491,072 m3.
62
Wastewater Generation and Treatment
[303-2] [303-4] [306-1] [306-5]
To manage domestic and industrial water, in every

operation we have water treatment systems at
campsites, industrial and mining areas that, depending
on the physical layout of the facilities, are made up by
domestic and industrial treatment plants or
decentralized treatment plants.
Parameters we measure for domestic wastewater are

DBO5, DO0, grease and oil, total suspended solids,
and pH. These same parameters are measured for
industrial waters that, in addition, are monitored for
cyanide, chrome, arsenic, phosphorus, and nitrogen,
among others, that vary depending on regulatory
demands in each country where we operate.
We perform periodic controls to guarantee achieving

the minimum quality criteria of wastewater, being
cyanide a parameter of special interest in our
underground operations. We have expert staff to
analyze cyanide solution waters and to determine its
concentrations; we also have cyanide measuring
equipment to make onsite revisions of compliance of
permissible limits.
Our industrial processes, both to benefit and to exploit,

are designed to recirculate used water, guaranteeing
permanence of water resources, reduction of wasted
volumes, efficient use of raw materials, and reduction
of investments linked to water treatment. In Nicaragua.
Industrial waste due to possible pluvial water surplus
during recirculation process are previously treated
through primary and secondary systems, in
compliance with permissible limits demanded by the
legislation.
In 2019, the 2.3 Mm3 of discharges generated by

Grupo Mineros were planned and comply with quality
parameters defined under environmental legislation of
the countries where we operate. It must be said that
turbined water is not accounted for in our hydroelectric
generation, because since the quality of the water in this process does not vary, it is not considered
discharged water. Given the location and/or absence of other companies in our area of influence,
discharged water is not reused by any other organization.
63
Since we perform wastewater treatment, as generated in our Total Water Consumption:

domestic and industrial processes, complying with permissible
limits set forth under the legislation of each country where we
operate, the bodies of water in our area of influence are not
significantly affected by treated discharges or runoff water.
[303-5]
In Nicaragua, for instance, considering that water bodies near In 2019, our operations reported
our operation are highly intervened by anthropogenic activities,
a water consumption of 2.3
the quality of water has improved in some parameters.
Mm3
The volume of discharged water in 2019 in Colombia was
365,370 m3, and 292,250 m3 of them had domestic sources, Discharged Water (m3/year):
while 73,120 m3 had an industrial nature. 54% of it is discharged
onto seepage fields and 46% goes to surface sources, such as
Nechi and Tigui rivers, as well as Sin Nombre and San Pedro
streams. Our alluvial operation, under the closed-well model, did
not generate industrial spills.
In Nicaragua, seepage underground waters coming from our

underground operation, are the greatest contributor of industrial Mineros Group Total
discharges, although they are not directly used, but are treated 2,307,757
for elimination of solids and pH control, guaranteeing permissible
limits set forth by the legislation.
In 2019, in our operation in Nicaragua, we generated about 2.0 Mm3 of treated domestic and industrial
residual water which was discharged into three hydric sources located in the area of influence. Due
to recirculation strategies that we have implemented in the exploration, exploitation, and benefit
processes, we reduced our spill 27% versus 2018; that is, 736,756 m3 were not spilled due to
recirculation processes.
The sewage effluents we generate in our operation in Argentina are only domestic and are treated
with an aerobic process which is spilled onto a seepage gallery and a lower fraction is used to irrigate
plant coverage and planted trees in our facilities. We do not generate industrial spill, because we
recirculate our benefit process.
Water Spill (m3/Year)
Destination Colombia Nicaragua Argentina
Surface water 169,167 312,136 0
Cloacal water 196,203 1,632,010 78,280
Operation total 365,370 1,944,146 78,280
Grupo Mineros total 2,387,796
Biodiversity Management
[304-2]
64
The sensitivity of ecosystems where we operate, the more demanding regulations, as well as the
expectations of our stakeholders on biodiversity protection, lead us to develop strategies for their
protection in order to have sustainable conservation, together with the government and communities.
Thus, biodiversity protection is a priority responsibility for our operations which, as any productive
activity, affect Nature.
Impacts of our operations are identified, assessed, and graded through our environmental studies, in
compliance with our operational model and environmental characterizations of areas to be
intervened, where we identify effects generated on biodiversity by changes on land coverage,
modification in fauna population, and land habitat modifications, to see if they are reversible,
recoverable in the midterm, mitigable, or compensable.
At local level, we foresee, mitigate, and compensate through execution of physical, biotic, or
socioeconomic management, framed by management and control instruments, as well as
environmental management plans and statement of environmental impact.
Among programs we conduct to manage impact on biodiversity, we highlight in Colombia the scaring
off, rescue, and relocation of wildlife in our operation sites; the cleaning of water bodies in areas of
influence, the river turtle (Podocnemis lewyana) release program, forest compensation for native
species with some level of threat, as well as environmental education of employees, contractors, and
communities over the importance and care of fauna and flora. In 2019, we cleaned 11 hectares of
bodies of water, rescued 1,363 amphibians, 411 mammals, 24,152 fish, 431 birds, and 1,440 reptiles,
as well as the salvage of 5,700 orchids and bromeliads that were relocated in strategic areas for their
conservation.
Our Flora and Fauna of Relevance
[304-4] [304-3]
According to our environmental impact studies

in habitats where we have our areas of
influence, such as fragmented forests,
foothills, and continental waters, we have
reported some species under some level of
threat due to anthropic pressures, particularly
in Colombia and Nicaragua, that have been
suffered by these ecosystems for several
decades.
Therefore, it is fundamental that our operation

model and biotic management measure,
prevent, mitigate, and compensate
affectations on biodiversity, such as scaring
off, rescue, and relocation of wildlife, rehabilitation of intervened areas, forest compensations, fauna
and flora monitoring, and environmental education of our employees and neighboring communities.
In Nicaragua we keep 1,605 hectares of woods in the buffer area of Bosawas biosphere reserve,
including 130 hectares located in the Wastuna private reserve, where you find two of the most
important rivers of the town: Aguas Claras and Concha Urrutia. The sowing of 202,542 native plants
also contributed to the conservation of biodiversity in the region and the permanence of flora and
fauna in the town.
In Colombia, due to the level of threat, endemism, and impact we may cause to river turtle species
(Podocnemys lewyana) and cativo (Priora capaifera), we have developed two management programs
and specific conservation programs for each one of them.
65
One of them, is the river turtle conservation program that seeks to increase in the Nechi low basin
the population of this critically endangered (CR) species, according to the International Union for
Conservation of Nature (IUCN). Through participation of communities in our area of influence, we
collected and incubated eggs for further release of turtles in strategic areas. In 2019, we released a
total of 3,422 turtles.
The other conservation program promotes the care of forest endemic species, cativo, that is critically
endangered (CR) according to Colombian legislation. In 2019, we sowed through forest enrichment
in appropriate areas and the development of a greenhouse 96,000 trees to be transplanted in 2020.
Location Identified Species IUCN Endangerment

Category
Scientific Name Common Name CR EN VU NT LC
Podocnemis lewyana Magdalena River turtle X
Trachemys scripta callirostris Colombian slider X
Rhinoclemmys melanosterna Colombian wood turtle X
Lontra longicaudis Neotropical otter X
Chauna chavaria Northern screamer X

El Bagre, Aotus lemurinus Gray-bellied night monkey X
Colombia
Saguinus leucopus White-footed tamarin X
Ajaia ajaja Roseate spoonbill X
Alouatta seniculus Red howler X
Cebus albifront White-fronted capuchin X
Agouti paca Lowland paca X
Pecari tajacu Collared peccary X
Tamandua mexicana Northern tamandua X
Butorides striatus Striated heron X
Amazona auropalliata Yellow-naped amazon X
Caiman-crocodilus Spectacled caiman X
Leptophis ahaetulla Parrot snake X
66
Alouatta palliata Mantled howler X
Bonanza, Ara ambiguus Great green macaw X

Nicaragua
Agalychnis callidryas Red-eyed treefrog, X
Tamandua mexicana Northern tamandua X
Dasyprocta punctata Central American agouti X
Cuniculus paca Lowland paca X
Lepus europaeus European hare X
Lama guanicoe Guanaco X
Pseudalopex griseus South American gray fox X
Microcavia australis Southern mountain cavy X
Anairetes lavirostris Yellow-billed tit-tyrant X

Jachal, Asthenes steinbachi Steinbach's canastero X
Argentina
Ardea alba Great egret X
Bolborhynchus aymara Grey-hooded parakeet X
Carduelis crassirostris Thick-billed siskin X
Catamenia analis Band-tailed seedeater X
Cyanoliseus patagonus Burrowing parrot X
Zonotrichia capensis Rufous-collared sparrow X
Protected or Restored Habitats
[304-3]
In Colombia we continued with the conservation and protection of forest areas in the towns of
Caucasia, Anori, El Bagre, and Nechi where we had monitoring activities of vertebrate fauna and
reforestation or enrichment with vegetal material. We kept protection of wood coverage; 803 hectares
in Anori, 398 hectares in Caucasia, and 124 hectares in El Bagre and Nechi.
In our operation in Colombia, in 2019 we focused our efforts in sowing cativo, planting 120,000 trees
in 22 hectares to enrichen the forest areas and we plan to sow 250,000 in 2020. It must be said that
we do not have recovery activities in intervened areas by the alluvial operation because we conduct
selective dredging in these areas, leaving rehabilitation for a later phase, once mining operations are
concluded.
In Nicaragua, we have 1,605 private hectares in conservation located at the buffer area of Bosawas
biosphere reserve where Pis Pis River springs, an especially important water source in the region.
Likewise, within these areas, there is Wastuna, a Private Wild Reserve (RSP), owned by Hemco,
classified by the Ministry of Environment and Natural Resources (MARENA) in 2009, with an
extension of 130 hectares where Aguas Claras and Concha Urrutia spring. This way, we are
contributing to the preservation of protected areas and the biodiversity of the region, as well as the
protection of the main water sources of the town of Bonanza.
67
In 2019, we restored and preserved 2,267 hectares in Nicaragua;

1,605 of them will be destined to the conservation in association
with the Ministry (MARENA) and Bonanza town: 215 hectares
correspond to commercial plantations with a protection- Protected and Restored Habitats:
production character and 404 hectares were reforested to be
conserved in compliance with reposition (compensation) set forth
under the legislation. In other 43 hectares, we have started the
recovery process.
In these areas we planted a total of 202,542 trees – native

species – sowed by municipal cooperatives; 160, 477 of them were sowed in compensation to enrich
areas we own and small-scale miners own; 34,456 plants were used for maintenance and replanting
in reposition areas of previous years; and 3,609 were donated to environmental authorities for
development of joint activities.
We highlight alliances we made with land owners, small-scale miners, and environmental
organizations to guarantee sustainability of compensations in the territory and to boost the offer of
environmental goods and services to make miners participate in the restoration; thus, we acted on
91.23 hectares, equivalent to 49% of the intervened area, with 76,333 trees in reposition for 2019.
Being that the economic activity of Bonanza is mostly mining, with

a high potential on small-scale mining and wood extraction,
environmental impact is evident in the region because these
activities have been conducted for over 50 years without any
control measure. Therefore, seeking to mitigate these impacts,
and increase the offer of environmental goods and services, in
2019 we recovered 226 inherited liabilities, highlighting the
closing of Vesmira I tailings dam.
For our operation in Argentina, given its exploitation model, we

do not report restoration of intervened areas, because it is a
process to be conducted under the closure and abandonment
plan once mining resources are depleted.
Protected areas
[304-1]
In our alluvial operation in Colombia, we exploit an extension of 30

hectares of new reserve blocks, six kilometers away from Rio
Magdalena national forest reserve, acknowledged as such
through Act 1959 for the “Protected Forest Area”.
In addition, we are seven kilometers away from “El Sapo and Hoyo
Grande Marsh Integrated Management Regional District”, created
by Corantioquia – the regional environmental authority – in 2017.
None of our mining areas of interest are within these protected
areas at national or regional level and there is no incompatibility
with our activity.
Understanding the importance of these protected areas and

complying with a voluntary agreement with Corantioquia, in our
operation in Colombia we returned to the mining authority 1,128 hectares of mining concession area
that overlapped the regional protected area denominated Integrated Management Regional District,
68
seeking together with authorities and the community to help protect it and enrich it with forest
resources.
Bonanza, our mining concession in Nicaragua, where

we are conducting extraction activities, takes 122.7
hectares including Grupo Panama and Grupo Pioneer
underground mines, Pioneer, Capitan and Neblina
pits, La Curva, Vesmisa, and Hemco camps, Aguas
Claras, Concha Urrutia, and San Jose tailing dams,
and Siempre Viva and Salto Grande hydroelectric
plants. This concession is in the buffer area of
Bosawas biosphere reserve, 30 kilometers away from
this reserve and 10 – 15 kilometers from Cola Blanca
and Banacruz natural parks, respectively, which
ratifies the effort and results obtained in the
conservation and recovery of over 2,000 hectares of
woods, contributing to the preservation of these
reserves.
Our operations in Colombia and Nicaragua do not

generate affectations to nearby protected areas, but
our location next to them gives us the opportunity to
implement more effective biotic measures, such as the
relocation of fauna and forest compensations to
reduce the affectation on wildlife and increasing and enriching forest areas, also contributing to the
protection objectives of these areas.
Our operation in Argentina is not close to any protected areas. The closest areas are Talampaya
national park and La Cienaga natural area, located over 70 kilometers away from our facilities.
Commercial Plantations
In Colombia, since 2004, we have had rubber plantations (Hevea brasiliensis) seeking to enable in
the Lower Cauca region a productive alternatives to contribute to territorial sustainability, having
currently five properties with 1,200 hectares planted with 503,069 different-age trees. In 2019, we
69
achieved a production of approximately 360,000 liters of latex from 65,938 trees that were sold to
local transformers, generating added value to the rubber production chain in this region.
In addition, considering rubber becomes a sustainable life option for the Lower Cauca communities,
we created training programs in association with local and social actors, along with governmental
agencies, exchanging knowledge with educational institutions in the region and with rubber
associations around the country. We also enabled spaces in the plantations for our employees to
start apicultural and fish-farming programs.
In Nicaragua we have 184 hectares planted with teak (Tectona grandis) and 31 hectares planted with
pine (Pinus) sowed between 2009 and 2010, guaranteeing the permanence of plantations until their
maturity; we conducted maintenance pruning in 2018 and 2019 and demonstrated that these
plantations are a great productive alternative in the region due to their adaptability and because they
are framed within the forest development strategy included in Bonanza’s Territorial Land Use Plan.
In Nicaragua we were able to make progress in the development of teak, pine, and rubber commercial
plantation projects and started, in addition to them, a pilot program with 30,000 rubber plantlets, a
species that preceded mining activities in the region and that will generate economic benefits through
the production of latex. This will also contribute to the mitigation of the climate change.
Solid Waste Management
[306-2] [306-3] [306-4] [301-2]
Waste we generate in our operations is responsibly managed and treated according to its
characteristics and the specific regulations for each country; we separate at source, collect, and
dispose of waste at landfills or assess with third parties, depending on waste classification, seeking
its reduction or reintegrating them as matter or raw material to local communities in our facilities.
We also conduct training and awareness-raising programs for our employees and communities in the
area of influence to have the knowledge of adequate disposal processes, while we generate local
employment with commercialization of recyclable waste.
In Colombia and Nicaragua, we have landfills where we have adequate final disposal of common
waste; we temporarily collect and separate by types of recyclable material (metal, plastic, cardboard,
paper, and glass) and hazardous material waste. We also value organic waste and compost it. This
way, we not only manage waste well, but encourage an environmental culture and knowledge transfer
to those visiting us.
In Argentina, non-hazardous waste generated is transported separately as recyclable and ordinary

waste to the landfill in Jachal, with whom we have an agreement, and waste is treated and disposed
of according to its classification.
70
In this country, we reported a waste increase in 2019, in spite of our migration in some sectors through
maintenance workshops, as well as the remediation plans implemented.
In our three operations we generated a total of 4,905 tons of waste in 2019; 46% of them correspond
to non-hazardous waste and 12% of it was recyclable material reused within our facilities, where we
commercialized it, or delivered it to third parties to be assessed in the market.
In Colombia, we continued with the solid waste management program that has been developed and
improved for over 15 years, by the hand of our Environmental Management Plan. In 2019, we
conducted an analysis and assessment of the life cycle to identify possible environmental impacts
generated in the different processes, starting with the purchase of raw materials, striving for waste
reduction within the company. Additionally, we incorporated the circular economy strategy achieving
a reduction in the purchase and consumption of materials, representing 28,005 kgs. of waste vs.
2018, increasing the recyclable and organic fraction.
We highlight in our operation in Nicaragua, that of the 566,070 kgs. of non-hazardous waste we
generated, 84% was recyclable material and we reduced by 40% the generation of hazardous waste
versus 2018, despite of the fact that we had three new projects.
As far as recyclable material, we reduced it by 76%, mainly due to the promotion of programs to reuse
and reduce plastic consumption, reducing the generation of non-hazardous waste by 26% and a
significant reduction of 67% in organic waste, product of the Waste-No-Food campaign.
In Nicaragua we were acknowledged at national level as a leading company in terms of recyclable

waste donations and for the “Pipitos Parents with Disabled Children Association” that received 46
tons of recyclable material in 2019. Through donation programs to the community and Los Pipitos
foundation, we have positively contributed to the wellbeing of the region and the social inclusion of
people with limited capacities.
Environmental awareness-raising conducted with our employees and contractors, for equipment
preventive maintenance, spill kit placement at strategic places, and development of total production
maintenance programs, such as TPM, enabled us not to have significant spills in our operations in
2019 and to reduce the volume of hazardous waste.
Generated Solid Waste (kg)
Type Colombia Nicaragua Argentina
Hazardous 54,633 281,435 2,310,851
Non-hazardous – recyclable 30,270 468,404 693,763
Non-hazardous – ordinary 294,669 88,673 601,344
Non-hazardous – organic 72,430 8,989
Total country operation 452,002 847,505 3,605,958
Grupo Mineros – total hazardous waste 2,646,919
Grupo Mineros – total non-hazardous waste 2,258,546
Grupo Mineros total 4,905,465
71
Hazardous Waste Management
[306-4]
Guaranteeing compliance with

current legislation in each country
where we operate, the totality of
the hazardous waste we
generated (2,647 tons), is
processed by certified and
endorsed companies by
competent authorities for this
purpose, who have environmental
and safety conditions required for
optimal transportation, treatment,
elimination, and/or final disposal.
In addition, we seek the valuation

of this waste through the
commercialization in the national market of used oil and disposed acid-lead batteries, so we do not
have the need to import/export any kind of waste.
In Nicaragua, we generated a total of 281,435 kgs. of hazardous solid waste and 24,877 gallons of
used oil that we commercialize with an authorized third party for energy recovery. From them, 189,250
kgs were processed through certified contracting companies to be incinerated, treated, or valued and
92,185 kgs of waste coming from mineral blasting obtained in the mills were disposed at the San
Jose tailings dam which complies with water-proof requirements and was designed for this purpose.
We highlight the 31% reduction of hazardous waste generation versus 2018 due to improvement of
best maintenance practices.
In Argentina, we generated 2,311 tons of hazardous solid waste and 247,632 gallons of used oil
which were incinerated by an authorized supplier in the province of San Juan. In the meantime, in
Colombia we generated 54,633 kgs of hazardous solid waste that were transported, incinerated, or
disposed of with an availed contractor and 12,551 gallons of used oil that were commercialized with
an accredited third party.
72
Used Oil Generated
Operation Gallons Kilograms
Colombia 12,551 39,908
Nicaragua 24,877 85,694
Argentina 247,632 853,025
Grupo Mineros Total 285,060 978,627
Environmental Performance Investment
In accordance with our commitment to the sustainability of territories where we operate, in 2019
Grupo Mineros invested US$ 18.4 million to manage our environmental impact, the care of
biodiversity, and the sustainable use of natural resources.
We highlight an increase of 38% in our environmental investment in 2019, given our efforts in
Nicaragua, where we focused our activities in the development of projects, such as the expansion of
San Jose tailings dam, the closing down of inherited liabilities, and small-scale mining.
Environmental Performance
Investment (US$ millions):
Total: 18.4 (2019) vs. 11.4

(2018)
73
74
With the consolidation of our operations in Colombia and Nicaragua, where we have had direct
presence since 2013, and with recent operations acquired in Argentina, at Grupo Mineros we are
progressing towards ranking high in the regional and international arena.
We are heading to accomplishment of our goal, we know that active participation in this sector not
only demands experience, knowledge, and persistence, but also capital and technology. We believe
we have the necessary experience and knowledge to keep identifying growth opportunities in a sector
with a great potential, which is an incentive to look for new businesses.
Gold Production
Gold Total Sales and Share by Country, 2019
Equivalent gold ounces 296,444 Share %
Colombia 70,947 23.93%
Nicaragua 128,164 43.23%
Argentina 97,332 32.83%
Total Sales, US$ 408,690,230
Colombia 94,861,870
Nicaragua 177,307,894
Argentina 136,520,466
75
Created, Distributed, and Withheld Economic Value
[201-1]
Contributions to Colombia, Nicaragua, and

Argentina through taxes, royalties, and other
contributions, become a direct support to the
economic and social development of each
country, as well as to the progress and wellbeing
of communities and regions where we perform
our mining operations.
Created, Distributed, and Withheld Economic

Value
Created Economic Value Grupo Mineros

(US$)
Operating revenues 411,335,595
Non-operating revenues 3,270,271
Total 414.605.866
Distributed Economic Value
Operating expenses (excluding personnel, 246,750,821

depreciations, and amortizations)
Administrative expenses (excluding personnel, 4,519,259

depreciations, and amortizations)
Personnel costs and expenses 54,764,437
Other expenses (excluding interest expense) 23,994,831
Interests 6,181,715
Paid dividends 3,904,288
Investments in the community 523,575
Total 340,638,929
Withheld Economic Value
Depreciations 6,123,537
Amortizations 5,725,187
Accumulated reserves 208,100,777
Total 219,949,901
76
Significant Indirect Economic Impacts
[203-2]
We fully comply with taxes imposed on Companies in our sector. Contributions we made to state
entities at national, regional, and local levels in Colombia, Nicaragua, and Argentina, adding up to
US$ 38.9 million in payment of taxes, royalties, and other contributions; they became a direct support
to economic and social development in each country where we have mining operations.
Grupo Mineros Contribution to the State
Concept US$
Municipal, vehicle, and stamp tax 1,478,251
Income tax 8,804,625
Gold, silver, and platinum tax 2,486,769
Royalties 9,517,208
Industry and commerce 219,019
Retributive fees 1,652,016
Mining Fund 1,395,826
Export duties 9,020,569
Import duties 1,477,027
Carbon dioxide and fuel 741,152

Other Financial transactions 1,642,998
Consumption 241,663
Registration 2,939
Custom services 207,211
Other fees 24,108
77
Total 38,911,381
Employment Generation Impact
[203-2]
A positive and especially important impact in the economic

development of influence areas of our mining operations is the
generation of employment and income for a broad sector of the
local population.
In our operations in Argentina, generation of employment is an

important contribution to the local economy and development.
The company has 714 direct and 423 indirect employees. From
them, 93% are from the San Juan province (and over 45% live in
the communities closer to the mine). In Jachal, the mining salary
impact is sensibly higher than funds managed monthly by the city.
In Colombia, from a total of 1,639 employees, 90% come from El

Bagre and Zaragoza, both towns in the area of influence of the
mining operation. In Nicaragua, over 90% of the workers come from the Northern Caribbean Coastal
Autonomous Region.
Supply Chain
[102-9]
Our commercial relations are ruled by compliance with the legislation of countries where we operate,
as well as purchasing policies, environmental regulations, and occupational safety and health defined
by the Corporate Group.
In addition, we have set forth clauses for the prohibition of infant labor and we encourage clear ethics,
transparency, and anticorruption standards in the purchase of materials, equipment, and services.
We have an important number of vendors who provide us with elements, materials, and spare parts
of different nature for metalworking, casting, electrical, electronic, and hydraulic work, personal
protection gear, chemical precursors, and routine maintenance processes throughout the mining
operation in each country where we operate.
78
Supplier Relations
In each country we have a group of local and foreign goods and service vendors:
At Grupo Mineros we give priority to procurement of goods and

services in the country and, especially, in the regions where our
mining operations are located:
* In Nicaragua, we have performed a number of contracts for
acquisition of goods and services with local suppliers: 8% of all goods
and services are bought locally, specifically, in Bonanza and the
North Caribbean region.
* In Colombia, 18% of all purchases take place within the country,
most of them concentrated in the Aburra Valley (where Medellin, the
base of the Group, is located) and the Lower Cauca region.
* In Argentina, 90% of all purchases take place within the Republic
of Argentina, particularly from vendors from the San Juan region and
areas near the project.
Total Purchases of US$ Percentage of Products and

Materials and Services Services Locally Bought*
Colombia 45,466,474 18%
Nicaragua 52,632,943 57%
Argentina 67,260,783 90%
Suppliers Environmental Assessment
[308-1-2]
Within Grupo Mineros policies we have set forth guidelines to assess vendors and contractors based
on environmental criteria and compliance of legal and safety legislation standards, which are included
in the respective contracts. Failure to comply accordingly shall be penalized with termination of the
contract or with fines, depending on the specificity of the non-compliance.
In Argentina, for bids for services provided in our mine, we make a vendor evaluation in terms of
health, safety, and environmental issues; results are considered in the selection criteria. In 2019, we
assessed 9% (60) new suppliers, but did not identify any significant negative environmental impacts
that required improvement actions.
Every vendor coming into our facilities must comply with all health, safety, and environmental
regulations set forth by our Company. If a vendor does not comply with them, we immediate request
the prompt remediation but we have not had any cases in which we had to terminate a contract due
to environmental issues.
In Colombia we assessed 50% of our new vendors with the above-mentioned environmental criteria.
In the precontractual phase, we analyzed the essential requirements to bid, including absence of
penalties from environmental authorities and verification of current environmental authorizations and
an environmental management system in place. Those who comply with these requirements, are
analyzed under additional criteria, for their final selection that, depending on results of the evaluation,
79
are accepted depending on the Contractor Strengthening program with restrictions or routine follow
ups.
Additionally, in the contractual phase in Colombia, and according to the service’s environmental
relevance, we conducted the evaluation and follow up for 19 contractors. From them, we identified
eight who hay issues requiring improvement in terms of water, emissions, and waste management.
They were trained in issues related to services contracted (chemical substances and solid waste
management, best environmental practices, and water and energy management, efficient use and
savings).
In 2019, we worked in the formulation of guidelines to lead sustainable procurement performance

within the Purchase Policy of our operation in Colombia. We try, as long as advisable in the market,
to use greener materials, to perform with consumers the rationalization of materials in processes, and
determine efforts that enable the reduction of industrial surplus.
80
81
Employment Generation and Work Management
At Grupo Mineros, our employees are of great importance to the organizational structure because
they are the base for achievement of corporate objectives. That is why our work practices are based
on respect, care, and safety: Our corporate culture keys.
Work Relations and Human Development are in charge of assistance to our employees and their
performance is led by strict compliance of the work legislation currently in effect in the countries where
we operate.
82
Grupo Mineros Employees by Type of Contract and Gender
[102-8]
Colombia
Type of Gender Alluvial Mining Miners Agroforestry Mineros Temporary Total
Contract Miners Operators Business Foundation
Indefinite Female 73 14 49 1 0 0 137

term
Male 722 620 37 0 0 0 1,379
Fixed term Female 2 0 1 0 2 0 5
Male 12 10 1 0 2 0 25
Project Female 0 1 2 0 0 19 22
term
Male 52 11 2 0 0 7 72
Total 861 656 92 1 4 26 1,640
Nicaragua
Type of Contract Direct Employees
Male Female
Indefinite 1,265 161
Fixed term 19 5
Total 1,284 166
Argentina
Type of Contract Direct Employees External Employees*
Male Female Male Female
Indefinite 680 34 402 21
Fixed term 0 0 0 0
Project term 0 0 0 0
Total 680 34 402 21
* External employees (hotel, building maintenance, facility safety, explosive handling, personnel
transportation, etc.)
83
Direct and External Employees Related to the Organization by Region and Type of Contract
Argentina
Region Direct Employees External Employees
Indefinite Term Indefinite Term
San Juan 330
Jachal 290
Huaco 39
Other 55
Total 714 423
Colombia
Region Type of Alluvial Mining Miners Agroforestry Mineros External Total

Contract Miners Operators Business Foundation
El Bagre 749 0 0 1 0 0 750
Zaragoza Indefinite 0 634 0 0 0 0 634

term
Medellin 48 0 86 0 0 0 132
El Bagre 13 0 0 0 4 0 17
Zaragoza Fixed 0 10 0 0 0 0 10
term
Medellin 1 0 2 0 0 0 3
El Bagre 52 0 0 0 0 6 58
Zaragoza Project 0 12 0 0 0 0 12
term
Medellin 0 0 4 0 0 20 24
Total 861 656 92 1 4 26 1,640
Nicaragua
Region Direct Employees
Indefinite Term Fixed Term Project Term
North Caribbean Coastal Autonomous Region 1,426 24 0
Total 1,426 24 0
84
Collective Bargaining Agreements
[102-41]
New Hires and Layoffs
[401-1]
The generation of dignifying and stable

employment is one of the permanent tasks of
Grupo Mineros. In Colombia, 93 people were hired
by the Organization in 2019, 142 in Nicaragua and
73 in Argentina. Nevertheless, there were layoffs
for different reasons: 80 in Colombia, 188 in
Nicaragua, and 53 in Argentina.
Fulltime Employee Benefits
[401-2] [401-3] [203-1]
This item includes directs benefits granted to fulltime employees, such as: Life insurance, production
bonus, medical assistance, and basic food basket.
Colombia
Program Hierarchical Level Type of Contract Benefited Employees
Life insurance Workers, Vice- Indefinite, fixed, and 544

presidents, and CEO project term
Medical insurance None
Disability coverage Everybody Indefinite, fixed, and 1,540

project term
85
Maternity or paternity Everybody Indefinite, fixed, and 1,540

leave project term
Pension fund Everybody Indefinite, fixed, and 1.540

project term
Shares Vice-presidents and Indefinite 4

CEO
Argentina
In Argentina, every fulltime employee is granted:
 Life insurance
 Medical insurance
 Disability coverage
 Maternity and paternity leave
 Pension fund
Nicaragua
Benefit Description Benefited Employees
Life insurance Due to collective bargaining, employees with indefinite-term 1,374

contract receive life insurance: 18 months of salary in case of
natural death and 36 months of salary in case of work accident
death
Medical insurance Mandatory by law – applicable to any type of contract 1,450
Disability coverage Mandatory by law – applicable to any type of contract 1,450
Maternity and paternity Due to a legal regulation, this leave is granted to any type of
leave contract. In case of paternity, because of collective bargaining:
Five days for the birth of a child within a stable family unit
Pension fund Percentage paid by legal regulation; the employee also 1,450
contributes, regardless of the type of contract
Basic food basket 1,450
Production bonus Percentage applied to the basic salary, depending on 1,374

achievement of monthly goals
Quarterly slippage Dollar is updated applied to the basic salary 1,374
Maternity, seniority, water, According to an agreement, a maternity basket is granted, as 10

and energy bonus well as a seniority tenure bonus to pay energy and water
Family assistance Every benefit described in the collective bargaining 1,374
Scholarships 13
Prescribed glass bonus 1,374
Note: The benefit plan includes everyone in the company without any distinction or type of contract.
Governance Bodies and Employee Diversity
86
[405-1]
In general, at Grupo Mineros we respect gender

diversity and we opt to hire employees for each
position according to his/her profile and
competences, but at the organization there is a male
gender predominance at most hierarchical levels.
 In Colombia, at high direction positions,

there are 15 people (12 male and three
female with an 80% - 20% ratio). In mid-
direction positions, there are 44 people (36
male and eight female) with an 82% - 18% ratio). In low management positions, there are 55
people (48 male and seven females with a 73.8% - 26.2% ratio).
 Most staff are concentrated in administrative positions (792 employees), being that in
Colombia (Medellin) operates Grupo Mineros’ general direction. However, the greatest male
share is concentrated over the female: 597 – 132 with an 82% - 18%) ratio).
 By age groups, most staff (507) are between 30 and 50 (69.5%), while between 18 and 30
there are 131 employees (17.9%).
 In Nicaragua, the operative management concentrates the greatest number of employees
(179), being 100 of them male and 79 females with a 93% - 7% ratio). At administrative levels,
amounts are remarkably similar, with 171 and 174, respectively) but share percentages show
that male participate with 87% - 64%, while female do it 13% - 36%.
 High positions and middle management take less staff: Five top management people (four
male and one female, with an 80% - 20% ratio) and in middle management there are 19
people (16 male and three female with an 84% - 16% ratio).
 By age groups, most staff (513) are between 18 and 30 (47%), while between 30 and 50
there are 508 employees (47.6%).
 The operation in Argentina is led by two people in top management, a male and a female
between 30 and 50. In middle management, there are 15 people (14 male and one female)
and 80% of them are between 30 and 50. In low management positions, there are 25 people,
all male, and 90% of them (23) are between 30 and 50. In the administrative area, there are
159 people: 130 male and 29 female with an 82% - 18% ratio. 77% of them are between 30
and 50 and 14% of them between 18 and 30.
 In the operative area, is where most people (513 workers) work. From them, 99% are male
(510). 77% (399 operators) are in the range between 30 and 50 and 15% of them (75 people)
between 18 and 30.
87
Occupational Safety and Health
[403-1]

Management System (SG-SST)
In the operation of Gualcamayo

mine, in Argentina, we comply with
national and international
requirements in terms of
occupational health and safety. We
have implemented and kept the
Management System (SG-SST)
under international standard
OHSAS 18001, which was certified
recently for the third time.
The system reaches own employees and contractors controlled by the Organization; that is, everyone
who develops his/her activities within the Company.
At Hemco operation, in 2019, we implemented and matured SG-SST based on international standard
OHSAS 18001:2015. We highlight the level of performance and the legal compliance through the
review of current legislation, in issues like:
 Follow up through legal matrixes

 Risk identification, assessment, and management under IPERC methodology.
 Change management in maintenance duties like major maintenance jobs, projects and
assemblies
 Cross-operational control of high-risk jobs and their required authorizations.
 Operational control of areas with the implementation of ATS (Safe Work Analysis),
emergency plans, brigade, and training plans certified by the competent authority.
The legal requirements we give compliance to under Occupational Safety and Health Management
System (SG-SST) are:
 Act 185, Nicaragua Work Code.

 Act 539, Social Security Law.
 Act 618, Occupational Safety, Sanitation Act and related regulations.
 Work Sanitation and Safety Mixed Commission – CMHST.
 Work Sanitation and safety license.
 Act 837, firefighters’ general direction.
 NTON 22 001 04, fire protection.
 NTON 22 003 10, emergency plans, Act 510. Special law for firearms, ammunition,
explosives, and related materials control and regulation.
88
The system covers direct workers, contractors,

subcontractors, and visitors to our plants and facilities who
must go through an access administrative control, including
industrial safety induction.
We also contemplate other types of activities under the SG-

SST, including routine and non-routine activities for
contractors and suppliers within Hemco facilities.
In Colombia, SG-SST is based on PHVA cycle, according

to diagnosis the regulatory framework included under
Regulatory Decree 1,072 of 2015 and Resolution 0312 of
2019, in compliance with main factors of each cycle. In our
case, we achieved 95% compliance with the matrix.
We have available an applicability analysis tool under a

requirement matrix to identify legal requirements that arise
from regulatory bodies, we review their impact on
operations and we apply them where required.
We work with standards, norms, and procedures for daily

duties, including:
 AROS (Risk Analysis by duty).

 Standards for performance of high-risk duties.
 Blocking and labelling procedures.
 ATS (Safe Work Analysis).
 Load hoisting standards.
 Chemical substances labeling and control
standards.
 PPE (Personal Protective Equipment)
manual.
 It is our objective to strengthen contractors
in terms of occupational safety and health
and we develop with them a program
based on legal compliance and continuous
process improvement.
 In terms of other types of activities
contemplated under SG-SST, we conduct
training activities, field inspections to
identify risks, auditing and advisory in
terms of safety.
Identification of Hazards, Risk Evaluation, and

Incident Investigation
[403-2]
In our operation in Argentina, we have implemented, as part of the Integrated Management System,
a complete hazard identification, risk evaluation, and control determination measure process to
eliminate hazards and minimize risks at levels as low as reasonably possible. Contractors are
engaged with this process, that complies with guidelines under Standard OHSAS 18001 and it is
annually audited by external professionals.
89
Employees have a risk evaluation tool applicable at the workplace, called PEACE. It is run before
starting a task and allows assessing risks associated to the activity, detecting the applicable control
measures under safety standards.
All our employees and contractors are empowered to stop any activity they consider unsafe. When
this happens, they are congratulated for their attitude towards safety and are formally recognized in
a meeting with the General Manager.
Every incident is investigated to determine its root causes and to implement corrective measures that
minimize recurrence possibilities. High real and/or potential consequence incidents are analyzed
using ICAM international method.
Lessons learned from incidents are presented in monthly meetings to the Safety Committee of the
Company.
In Hemco Nicaragua, risk identification and assessment are conducted through valuation of duties,
detecting different types of risks and each one is applied a probability valuation and consequence to
determine the level of risk through the IPERC methodology of the Peruvian legislation.
Through ATS (Safe Work Analysis), we detail steps of the activity, identifying risks, and determining
controls. Through inspections, risks are reviewed and assessed in the areas, adding to the follow-up
matrixes the ones valued as critical. The rest are followed up through periodical inspections.
Control hierarchy to manage identified risks is conducted in compliance with Standard OHSAS 18001-
2015 and homologated with Standard ISO 45001-2008 (Risk Identification, Assessment, and
Control).
The quality of employee’s health and safety risk identification, assessment, and control is guaranteed
through the selection and use of a recognized methodology and its strengthening by training middle
management and managerial levels.
The definition of improvement activities for the Occupational Health and Safety Management System
is conducted through performance indicators, setting improvement action plans, accidentality
analysis, and investigation of accidents as a corrective measure to improve the system and avoid
recurrence of accidents using corrective and preventive action procedures.
For the report of risks by employees, we use TPM methodology through safety yellow cards that are
loaded generating warnings which call their attention under the SAP platform.
Processes defined for employees to withdraw from work situations that may cause injuries or health
affectations are conducted through risk evaluations SAL-PRO-001, Risk Identification, Assessment,
and Control (IPERC), when assessment of an activity yields a high score and risk is warned as critical.
In the Colombian operation we use SAL-PRO-005 to investigate occupational safety and health
incidents. For that effect, an investigation committee is set up with participation of the injured person,
his/her direct supervisor, the industrial safety supervisor, a member of the joint committee, and
anyone else deemed convenient to contribute with his/her experience in the analysis of causes and
determination of actions.
Occupational Health Services
[403-3]
In Gualcamayo, Argentina, we have a fulltime occupational health physician who leads medical
services at the facilities of the micro-hospital located in the mine. The occupational physician works
90
together with the Hygiene and Safety service

conducting inspections at workplaces,
evaluating risks, and studying ergonomics.
In Colombia, work environment factor

surveillance services are conducted through
safety in housing units and mess halls, plague
control services, surveillance, employee
supervision, and epidemiology programs.
Employees are monitored, in terms of work,
using the Epidemiology Control Program to
prevent musculoskeletal injuries, hearing and
lung conservation, and mercury, lead, cyanide,
metal fume, and other material intoxication
prevention.
Work health, safety, and hygiene advisory services are offered

through implementation of cardiovascular risk prevention,
healthy lifestyles, alcohol consumption and abuse prevention,
drug use prevention, tobacco consumption and abuse
prevention programs
The walkthrough for proper ergonomics and individual and collective protective equipment is
conducted through training teams in matters related to adequate maintenance of personal protective
equipment, respiratory protective equipment adjustment, inspection of administrative workplaces with
videos, and inspection and assessment of biomechanical risks in operating workplaces, as well as
implementation of the Activados program.
To offer first aid and emergency treatment at El Bagre mining operation facilities, we have Nuestra
Señora del Carmen Hospital (ESE – State Social Company) and Medi-Cauca Clinic, managed by the
Franklyn D. Roosevelt Hospital.
In Nicaragua, factor control services in the work environment are controlled through a preemployment
checkup, as one of the initial occupational health services we have determined to identify pathologies
that may affect the employee’s health and work performance.
To monitor employees’ health in terms of work, we conduct occupational medical checkups and follow
ups of employees who turn out having illnesses or decompensations.
We provide prevention conferences to strengthen occupational health, safety, and hygiene to treat
issues that affect work performance, generated by common or work illnesses.
For ergonomics and individual and collective protective equipment advise, as well as work adaptation
promotional services in the Industrial Services and Occupational Health area, we have available a
procedure to test personal protective equipment substitution when an improvement opportunity and
comfort for the employee is detected.
We also conduct workplace risk assessments when required: New hires, promotional transfers,
reintegration, or when the employee has work restrictions.
For first aid and emergencies, we have a physician for treatments after a work accident or a common
accident occur.
91
In terms of medical information organization and confidentiality, we have a clinic with private offices
for the physician, where the employee is taken care of, under privacy standards. We also have a file
storage area where all patient information is filed under restrictions for unauthorized personnel.
Occupational Health and Safety Workers Participation, Inquiries, and Communications
[403-4]
In Argentina, we implemented a Mixed Committee to treat

occupational safety and health issues. It is made up by three
employee representatives (one of them from the Union) and
three Company representatives (one from the open-pit mine,
one from the underground operation, and one from the process
plant) with additional participation of the Health and Safety
Department, as advisors.
Monthly meetings are held; thus, employees have formal

participation in health and safety issues.
At Hemco, employees participate and are engaged in issues

related to Occupational Health and Safety Management System
through the Hygiene and Safety Mixed Commission, whose
intervention was relevant because it enabled us to improve
many work conditions.
Among the Occupational Health and Safety commitments that are covered under the Collective
Bargaining Agreements, there are:
 Having a clinic within the facilities with medical staff to transfer patients to specialized
hospitals and/or clinics, if required.
 Lodging, internal transportation, and food expenses for the patient and an accompanying
party.
 Ophthalmologic exams with periodic checkups to employees.
 Milk and basic food basket for breast-feeding mothers and maternity leaves.
 Reconstructive orthodontics for work accidents and orthopedics expense support to
employees’ children (up to 50%).
 Lodging, transportation and food for medical checkups in Rosita and Siuna area.}
 Availability of a hygiene and safety policy.
 Training programs.
 Have first-aid cabinets.
 Provide employees with free Personal Protective Equipment (PPE).
In Colombia, we have participation of workers every time there is a norm and procedure update and
responsibilities in terms of safety are clearly determined. We have defined the Occupational Safety
and Health Joint Committee (COPASTT) responsibilities and duties, as well as for Work
Togetherness and Emergency Committees.
In Argentina, Mixed Committee monthly meetings are held and, in this way,
we achieve formal participation of employees in occupational health and
safety issues
In Argentina we have a training system based on the need of each position and on the Integrated
Management System needs. Before starting to work, employees are fully induced in the general
conditions and later they receive specific training on health and safety related to their specific
92
positions and the identified hazards and risks associated to their activities. These trainings are held
within the working schedule.
In terms of training processes in Colombia, every year the Occupational Safety and Health team
meets to assess the management system from an accidentality perspective, for identification of
hazards, and work plans; based on that, training is determined with Human Development, as required
throughout the year.
Employee Training on Occupational Health and Safety Total Number of Employees

[403-5] Trained on Occupational
Health and Safety
In Colombia
Issues addressed are mainly related to electrical, mechanical,

work on heights, hazardous energy, integral care, chemical
product handling, personal protective equipment, load hoisting,
emergency control, health and safety management system, and
system responsibility risks. Employees Vendors’ and
Contractor’s
In Nicaragua Employees
Training needs are identified when conducting procedures under

SAL-PRO-002 – Change Management and SAL-PRO-001 –
Safe Work Analysis, and direct employees as well as contractors
and subcontractors who perform high-risk work, receive training.
Issues treated in training sessions are related to workplace risk

factors (physical, chemical, biological, ergonomic, etc.) and their
controls, high-risk work, technical training, and emergencies to
exposed employees. These trainings are conducted with annual
frequency and have evaluations at the end of the session to
determine the level of understanding by the employees.
In Argentina
Issues addressed in these training sessions deal with hazards,

risks, controls, hazardous chemical products, defensive
handling, energy control and blocking, equipment safe operation,
work at heights, confined spaces, explosives handling, and
inflammable material, among others.
Employees’ Health Encouragement
[403-6]
In the mines in Argentina we have implemented a health program to encourage wellbeing and healthy
habits, as well as the reduction of cardiovascular risks of employees. Efforts addressed to reduce
obesity and tobacco consumption are highlighted. Gualcamayo employees and contractors have
coverage (social work) to access medical services for non-work-related illnesses.
At Hemco Nicaragua, we have a clinic where we offer basic services and specialized urology,
dermatology, gynecology, internal medicine, orthopedics, otorhinolaryngology, and general surgery
consultation with coverage for every company employee, as well as other services provided to their
beneficiaries.
93
In Colombia, we have developed healthcare promotional services to address main non-work-related

risks, including cardiovascular risk, prevailing cancer, visual health, nutritional conditions, and
transmissible and non-transmissible illness prevention. In addition to this, we have agreements with
external suppliers for prevention and/or promotion of healthy lifestyles and healthcare brigades with
specialists.
Occupational Health and Safety Management System Coverage
[403-8]
 In Argentina, 100% of our own workers and contractors are covered by the integrated
management system. In 2019 coverage of the management system reached an average of
704 Gualcamayo employees and 501 contractors’ employees.
 We conducted internal and external audits to a third of the safety and health management
system by certified internal auditors and renowned external auditors with local and
international trajectory. Audits included every employee of the Company and the contractors.
 Both in Nicaragua and Colombia, 100% of employees are covered, as well In Nicaragua, the
Management System covers 1,446 direct employees and 147 indirect employees. In
Colombia, it covers 1,752 direct employees and 26 indirect employees, whose work or
workplace is controlled by the Organization.
Work-Accident Injuries
[403-9]
 In 2019, 2.5 million worked hour-men were accomplished.

 No fatal accidents were registered. Total fatal injuries = 0.
 12 work-related accidents were registered. Registered injury rate = 0.956.
Note: Rates are calculated based on 200,000 worked hours. Accidents and rates include own staff
and contractors. Registered injury rate is calculated according to ICMM (International Council of
Mining and Metals) and GRI (Global Reporting Initiative) guidelines.
In Colombia, just three serious accidents and 136 minor accidents were reported, and employees
received first-aid care. In 2019, there were no fatal accidents. In general, accidentality rate in
Colombia was 0.58%.
In Nicaragua, one company employee died under activities related to his duties. Additionally, there
were 15 serious accidents, with an accidentality rate of 0.77%. Other 49 accidents were registered
as work-related, with an accidentality rate of 2.53%; just one of them was not related to the Company.
94
Professional Ailments and Illnesses
[403-10]
In Colombia, there were no work-related illnesses

in terms of direct or indirect employees.
Nevertheless, the most frequent ailment in both
groups was neurosensorial hypoacusis - rotator
cuff syndrome.
In Nicaragua’s case, moderate and severe disc

herniation was evidenced as main illness. Just
three employees suffered a work-related illness
and one direct worker died in the Company for the
same cause.
In Argentina, there were no ailments or

professional illnesses in 2019.
Human Development
[401-2] [401-3] [404-2]
Coverage Percentage
Miners 81%*
Alluvial miners 74%*
Hemco 100%
* This value considers new

directors that shall be covered in
the 2020 training programs.
2019 was an adjustment and change year, marked by internationalization challenges and practice
homologation between the Corporate group headquarters and operations in the different countries.
Leadership, Succession, and Career Development
For the first time in the Corporate group we made an exhaustive critical talent characterization and
classification for future sustainability of the business, that at the end derived in identification of
successors in different timelines for 40 of the most important positions in the three companies and in
the Corporate Center.
This review shall continue expanding in 2020 and 2021 to reach more layers of the organization, until
we have completely clearly defined lines of succession for most positions and actions to be developed
95
individually and collectively, as required, to

guarantee fluency and consistency in mobility
cycles and talent growth in the Corporate group.
This gets the company closer to human
practices which are more aligned with demands
imposed by the current growth rhythm of the
business and the development expectations of
our employees.
Leadership Development Programs
In 2019, we continued strengthening the

training of our leaders in Colombia and we
started the program in Nicaragua with a first
group of leaders.
This year, we increased coverage of the

Leadership Development Program (PDL) to
reach the Steering Committee (CEO and Vice-
Presidents) engaging them in the thinking style
assessment, competence measurements, and 360° accountability, as well as in-class training
workshops and individual results feedback.
This exercise with the Steering Committee strengthens global impact of the program and gives a
coherence message in terms of the importance of leadership development at every level of the
organization as a fundamental lever to mobilize sustainability results and the corporate growth we
are committed to.
Manos Limpias Program Activation
After the update of Grupo Mineros Ethics

Code in August 2019, we detected the need
to go beyond and disclose it even further.
Thus, we generated a reflection and
appropriation space of the code through in-
class workshops in every branch where we
have operations.
At the end of 2019, we had covered 87% of all

Argentinian operation employees and in 2020,
under the Compliance area and the countries’ legal area’s guidelines, the remaining population shall
be reached, as well as operations in Nicaragua and Colombia.
96
Deployment of Corporate Strategy
A decisive step taken in the organization is the

democratization of the understanding,
appropriation, and mobilization of the Corporate
strategy as the milestone for its alignment and
deliberate performance.
At the end of 2019, under the leadership of the

Business Development Vice-Presidency and
support of other areas, strategic alignment local
workshops were conducted in Nicaragua, Colombia,
and Argentina, where about 150 leaders were called
to know, analyze, debate, and contribute with
concrete ideas for the achievement of results that Grupo Mineros is committed to.
From a future sustainability point of view, we emphasize the relevance of profitable growth, respect
and care for the environment, a cost-efficient operation, talent performance commitment and impact,
and socioeconomic contribution to the regions and communities where we have our operations.
In 2020, we will keep the growth and strengthening of new practices and alternatives of performance
and development of the Company. In terms of talent sustainability, we must increase the knowledge
we have, boost succession and career plans, enable people mobility between companies and
positions, as well as rolling out a formal scheme of individual follow up, performance, and competence
development. These will be the main focus of our performance throughout the year.
For future sustainability, we emphasize the relevance of profitable growth,

respect and care for the environment, a cost-efficient operation, and
socioeconomic contributions to regions and communities where we have our
operations.
97
98
Contents
[102-55]
Key:
Reported: R Not reported: N.R. Not applicable: N.A. Not material: N.M.
Indicator Type of ODS Page Status
Indicator
Profile of the Organization
102-1 Name of the organization Essential R
102-2 Activities, brands, products, and services Essential R
102-3 Headquarters location Essential R
102-4 Operations location Essential R
102-5 Ownership and legal form Essential R
102-6 Markets served Essential R
102-7 Size of the organization Essential R
102-8 Employee and other workers’ information Essential R
102-9 Supply chain Essential R
102-10 Significant changes in the organization and supply Essential R

chain
102-11 Caution principle or focus Essential R
102-12 External initiatives Essential R
102-13 Affiliation to associations Essential R
STRATEGY
102-14 Statements from top management, responsible for Essential R

decision-making
102-15 Main impacts, risks, and opportunities Essential R
ETHICS AND INTEGRITY
102-16 Values, principles, standards, and conduct norms Essential R
102-17 Advisory mechanisms and ethical concerns Essential R
GOVERNANCE
102-18 Governance structure Essential R
102-19 Authority delegation Essential R
102-20 Executive level positions with responsibility on Essential R

economic, environmental, and social issues
102-21 Stakeholders’ survey results Essential R
102-22 Structure of the upmost governance body and its Essential R

committees
102-23 Chairman of the upmost governance body Essential R
99
102-24 Appointment and selection of upmost governance body Essential N.R.
102-25 Conflict of interests Essential R
102-26 Function of upmost governance body in the selection of Essential R

purposes, values, and strategy
102-27 Collective knowledge of the upmost governance body Essential N.R.
102-28 Assessment of t upmost governance body performance Essential R
102-29 Identification and management of economic, Essential R

environmental, and social impacts
102-30 Risk management process efficacy Essential R
102-31 Assessment of economic, environmental, and social Essential R

impacts
102-32 Function of upmost governance body in the draft of Essential N.A.

sustainability reports
102-33 Critical concerns communication Essential N.A.
102-34 Nature and total number of critical concerns Essential N.A.
102-35 Remuneration policies Essential Confidential
102-36 Remuneration determination process Essential Confidential
102-37 Stakeholder involvement in remuneration Essential Confidential
102-38 Annual total compensation ratio Essential N.A.
102-39 Annual total compensation percent increase ratio Essential N.A.
STAKEHOLDER PARTICIPATION
102-40 List of stakeholders Essential R
102-41 Collective bargaining agreements Essential R
102-42 Stakeholders identification and selection Essential R
102-43 Focus for stakeholders’ participation Essential R
102-44 Mentioned key issues and concerns Essential N.A.
PRACTICES TO DRAFT REPORTS
102-45 Entities included in the consolidated financial Essential N.A.

statements
102-46 Definition of contents of reports and issue coverage Essential R
102-47 List of material issues Essential R
102-48 Information re-statement Essential N.A.
102-49 Report drafting changes Essential R
102-50 Report period Essential R
102-51 Latest report date Essential R
102-52 Report drafting cycle Essential R
102-53 Contact point for report questions Essential R
100
102-54 Report drafting in compliance with GRI statement Essential R
102-55 GRI content index Essential R
102-56 External verification Essential N.A.
ECONOMIC
ECONOMIC PERFORMANCE
201-1 Generated and distributed direct economic value Essential ODS8 R
201-2 Financial implications and other risks and opportunities Essential R

derived from climate change
201-3 Obligations of the defined benefit plan and other Essential R

retirement plans
201-4 Financial assistance received from the Government Essential N.A.
MARKET PRESENCE
202-1 Standard initial category salary ratio by gender vs. local Essential N.A.
minimum salary
202-2 Proportion of high executives hired from local Essential N.R.

communities
INDIRECT ECONOMIC IMPACTS
203-1 Investments in infrastructure and supported services Essential N.A.
203-2 Significant indirect economic impacts Essential R
PURCHASE PRACTICES
204-1 Proportion of expense with local vendors Essential R
ANTICORRUPTION
205-1 Assessed operations for corruption-related risks Essential N.R.
205-2 Anticorruption policy and procedure communication Essential R

and training
205-3 Confirmed corruption cases and measures taken Essential N.A.
UNFAIR COMPETITION
206-1 Legal actions related to unfair competition, monopoly Essential N.A.

practices, and against free competition
ENVIRONMENTAL
MATERIALS
301-1 Material used per weight and volume: Renewable Essential R

materials
301-2 Percentage of used recycled raw materials Essential R
301-3 Reused products and bottling materials Essential R
ENERGY
302-1 Energy consumption within the organization: Essential R
 Total consumption of fuel coming from non-

renewable sources
101
 Total consumption of fuel coming from

renewable sources
302-2 Energy consumption out of the organization Essential R
302-3 Energy intensity Essential R
302-4 Energy consumption reduction Essential R
302-5 Product and service energy requirement reduction Essential R
WATER AND EFFLUENTS
303-1 Interaction with water as shared resource Essential ODS6 R
303-2 Water discharge related impact management Essential ODS6 R
303-3 Water extraction Essential ODS6 R
303-4 Water discharge Essential ODS6 R
303-5 Water consumption Essential ODS6 R
BIODIVERSITY
304-1 Owned, leased, or arranged operation centers located Essential ODS15 R

within or nearby protected areas or zones with great
value for biodiversity out of protected areas
304-2 Significant impact of activities, products, and services Essential ODS15 R

on biodiversity
304-3 Protected or restored habitats Essential ODS15 R
304-4 Total number of species in UICN Red List and in Essential ODS15 R
national conservation lists whose habitats are in areas
affected by the operation and by the level of extinction
risk
EMISSIONS
305-1 GHG direct emissions (scope 1) Essential ODS13 R
305-2 GHG indirect emissions when generating energy Essential ODS13 R

(scope 2)
305-3 GHG other indirect emissions (scope 3) Essential ODS13 R
305-4 GHGemission intensity Essential ODS13 R
305-6 Emission of substances that deplete ozone layer (SAO) Essential ODS13 R
305-7 Nitric Oxide and Sulphur Trioxide and other significant Essential ODS13 R
emissions into the air
EFFLUENTS AND WASTE
306-1 Discharge of water in function of quality and destination Essential R
306-2 Waste by type and disposal method Essential R
306-3 Significant spills Essential R
306-4 Hazardous waste transportation Essential R
306-5 Bodies of water affected by water discharges and/or Essential R

runoff water
102
ENVIRONMENTAL COMPLIANCE
307-1 Non-compliance of environmental legislation and Essential R

regulations
ENVIRONMENTAL ASSESSMENT OF VENDORS AND CONTRACTORS
308-1 New vendors that have gone through evaluation and Essential R
selection filters according to environmental criteria
308-2 Negative environmental impacts in the supply chain and Essential R

measures taken
SOCIAL
EMPLOYMENT
401-1 New hires and employee turnover Essential R
401-2 Benefits for full-time employees that are not given to Essential R
part-time or temporary employees
401-3 Parental authorization Essential R
EMPLOYEE-COMPANY RELATIONS
402-1 Minimum warning term on operational changes Essential N.R.
OCCUPATIONAL HEALTH AND SAFETY
PERFORMANCE FOCUS
403-1 Occupational health and safety management system Essential R
403-2 Identification of hazards, risk assessment, and incident Essential R

investigation
403-3 Work health services Essential R
403-4 Employee participation, inquiry, and communication on Essential R

occupational health and safety
403-5 Occupational health and safety employee training Essential R
403-6 Employees’ health promotion Essential R
403-7 Health and safety impact prevention and mitigation of Essential N.A.
employees casualties related to commercial activities
403-8 Occupational health and safety management system Essential R

coverage
403-9 Work accident injury Essential R
403-10 Work ailments and illnesses Essential R
TRAINING AND TEACHING
404-1 Training hour average per employee Essential R
404-2 Programs to improve employee attitude and transition Essential R

assistance programs
404-3 Percentage of employees who have periodic Essential R

professional performance and development
evaluations
DIVERSITY AND OPPORTUNITY EQUALITY
103
405-1 Governance body and employee diversity Essential R
405-2 Base salary and female vs. male remuneration ratio Essential N.R.
NO DISCRIMINATION
406-1 Discrimination cases and corrective actions taken Essential N.M.
ASSOCIATION FREEDOM AND COLLECTIVE BARGAINING
407-1 Operations and suppliers whose right of free Essential N.R.

association and collective bargaining might be at risk
INFANT LABOR
408-1 Operations and vendors with significant risk of infant Essential N.R.
labor cases
FORCED LABOR
409-1 Operations and vendors with significant forced labor Essential N.A.
risk
SAFETY ISSUE PRACTICES
410-1 Security personnel trained in human rights’ policies and Essential N.R.
procedures
INDIGENOUS RIGHTS
411-1 Indigenous rights violation cases Essential N.R.
HUMAN RIGHTS ASSESSMENT
412-1 Operations submitted to human rights impact reviews Essential N.R.

and assessments
412-2 Employee training on human rights’ policies and Essential N.R.

procedures
412-3 Agreements and contracts on significant investments Essential N.R.

with clauses on human rights or submitted for human
rights assessment
LOCAL COMMUNITIES
413-1 Operations with local community participation, impact Essential ODS1- R

assessment, and development programs 2-3-4-
5-6-10
413-2 Operations with significant negative impacts (actual or Essential N.R.

potential) on local communities
VENDORS’ SOCIAL ASSESSMENT
414-1 New vendors who have gone through selection filters Essential N.R.
according to social criteria
414-2 Negative social impact on supply chain and measures Essential N.R.
taken
PUBLIC POLICY
415-1 Contributions to political parties and/or political Essential N.A.

representatives
CUSTOMER HEALTH AND SAFETY
104
416-1 Assessment on health and safety impacts on goods or Essential N.A.

service categories
416-2 Cases of non-compliance related to impacts on health Essential N.A.

and safety under products and services categories
MARKETING AND LABELLING
417-1 Requirements for information and labelling of products Essential N.A.

and services
417-2 Cases of non-compliance related to information and Essential N.A.

labelling of products and services
417-3 Cases of non-compliance related to marketing Essential N.A.

communications
CUSTOMER PRIVACY
418-1 Claims based on violations of customer privacy and Essential N.A.

loss of customer data
SOCIO-ECONOMIC COMPLIANCE
419-1 Non-compliance of socio-economic laws and Essential R

normativity
105
106
107

Sustainability Memoirs

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Sustainability Memoirs

Uploaded by

Copyright:

Available Formats

MINEROS 2019 SUSTAINABILITY REPORT

SUSTAINABILITY MEMOIRS – 2019

Chapter 1 – About these Memoirs 2

MESSAGE OF THE PRESIDENT (102-14)

Andres Restrepo Isaza

MESSAGE FROM THE VICE PRESIDENT OF THE COMPANY IN NICARAGUA

Carlos Mario Gómez Peláez

MESSAGE FROM THE VICE PRESIDENT OF THE COMPANY IN COLOMBIA

Thanks to a negotiation focused on a cordial and respectful environment, we were able to

We continue contributing to the construction of regional development alternatives with a long-

As a contribution to biodiversity conservation, in 2019 we returned two mining concession titles of

Santiago Cardona Múnera

Eduardo Flores Zelaya

ABOUT OUR SUSTAINABILITY MEMOIRS

Compañía Minera de Ataco did not perform any mining activities.

Relations with Our Stakeholders

*IIRC integrated reporting framework, https://integratedreporting.org/wp-content/uploads/2015/03

Suppliers and Contractors:

Opinion Builders and Leaders:

To draft them, we took into consideration different environmental management international

Material Issue Group Searched Issues

Economic development • Employment generation.

Work practices • Occupational health and safety.

Stakeholders’ Inquiry Results

As mentioned, to draft our 2019 Sustainability Report we updated

76% say information provided by Grupo Mineros on performance is good-quality information.

Social Performance Average Score

Colombia Nicaragua Argentina Grupo Mineros

Knowledge 6.6 6.7 6.4 6.6

51% state having high knowledge of social performance.

Human Rights Average Score

Colombia Nicaragua Argentina Grupo Mineros

Knowledge 6.4 5.3 6.0 5.9

Human rights compliance and promotion is a priority in our operations.

Economic Development Contribution

Inquired Material Issue Performance Score

Local workforce hiring 7

Support to the development of artisan and small-scale

Work Practice Average Score

Nicaragua Argentina Grupo Mineros

Knowledge 8.1 7.5 7.8

Performance 7.6 7.8 7.6

Providing optimal conditions to our employee in a friendly corporate

Nevertheless, we evidence a gap in our performance because it is assessed better in the

Inquired Material Issue Performance Score

Development of policies and activities to guarantee 7.2

Environmental Performance Average Score

Colombia Nicaragua Argentina Grupo Mineros

Knowledge 7.1 7.1 6.6 6.9

Performance 8.0 7.6 7.7 7.8

Inquired Material Issue Performance Score

Water, soil, air, and energy efficient use and 7,6

Implementation of effective activities for recovery of

Stakeholder Groups’ Identification of our way of doing things

Statement Submitted to Consideration GM

Range Identification Level Nicaragua Argentina

Our Commitment with Sustainable Development Objectives

The 17 Sustainable Development Goals (SDG) defined by the United Nations

No. of Employees in the Corporate Group:

Partnerships that Make up the Corporate Group

conservation and protection of biodiversity and natural resources, as well as development of

Main Strategic Goals The Mega Guides us:

Grupo Empresarial Mineros

Corporate Group Values, Principles, Standards, and Conduct