Policies | METCON

Environmental, Social & Governance (ESG) Policy

METCON LIMITED is committed to operating in a manner that is environmentally responsible, socially equitable, and governed by the highest ethical standards. Our ESG framework guides all business operations and strategic decisions.

We actively monitor and work to reduce the environmental impact of our trading and logistics operations, including carbon emissions, waste management, and resource efficiency across our supply chain.

We engage with local communities in our sourcing regions to ensure our activities contribute positively to socio-economic development, supporting education, healthcare, and infrastructure initiatives.

Our governance structure ensures accountability, transparency, and compliance with both Nigerian regulations and international best practices. The Board of Directors oversees ESG performance and risk management.

Supply Chain Due Diligence Policy

METCON LIMITED adheres to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We have established robust management systems to identify, assess, and mitigate risks throughout our supply chain.

We conduct thorough Know Your Counterparty (KYC) checks on all suppliers, miners, and trading partners. This includes verification of mining licenses, operational permits, and compliance with local and international regulations.

Our five-step due diligence framework includes: establishing strong company management systems, identifying and assessing supply chain risks, designing and implementing a strategy to respond to identified risks, carrying out independent third-party audits, and reporting annually on supply chain due diligence.

We maintain full traceability of all materials from mine site to end-user, documenting chain of custody at every stage of the transaction process.

Responsible Sourcing Policy

METCON LIMITED is a member of the Responsible Minerals Initiative (RMI) and sources all materials in strict compliance with international responsible sourcing standards.

We do not tolerate, profit from, contribute to, assist with, or facilitate the commission of any form of torture, cruel, inhumane or degrading treatment, forced or compulsory labour, child labour, human rights abuses, or war crimes in connection with mineral extraction, transport, or trade.

We do not provide direct or indirect support to non-state armed groups or public or private security forces that illegally control mine sites, transportation routes, or trading points.

All sourcing partners are required to demonstrate compliance with our responsible sourcing standards, and we reserve the right to suspend or terminate relationships with any party found to be in violation of these principles.

Anti-Bribery & Anti-Corruption Policy

METCON LIMITED maintains a zero-tolerance stance on bribery and corruption in all forms. This policy applies to all employees, officers, directors, agents, and third parties acting on behalf of the company.

No employee or representative of METCON LIMITED shall offer, promise, give, request, or accept any bribe, kickback, facilitation payment, or other improper advantage in connection with our business activities.

We comply with all applicable anti-corruption laws and regulations, including the Nigerian Corrupt Practices and Other Related Offences Act and applicable international anti-corruption frameworks.

All employees receive regular training on anti-corruption compliance, and we maintain confidential reporting mechanisms for suspected violations.

Privacy Policy

METCON LIMITED respects the privacy of all individuals and is committed to protecting personal data in accordance with the Nigeria Data Protection Regulation (NDPR) and applicable international data protection standards.

We collect and process personal data only for legitimate business purposes, including client relationship management, regulatory compliance, transaction processing, and communication. Data is collected with appropriate consent and processed lawfully, fairly, and transparently.

We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. Access to personal data is restricted to authorised personnel who require it for their duties.

Individuals have the right to access, rectify, or request deletion of their personal data held by METCON LIMITED. Requests should be directed to our Data Protection Officer at metcontrading@aipecgroup.com.

Health & Safety Policy

METCON LIMITED is committed to providing a safe and healthy working environment for all employees, contractors, visitors, and partners. We comply with all applicable occupational health and safety legislation and industry best practices.

We conduct regular risk assessments of our operations and implement appropriate controls to eliminate or minimise hazards. All employees are provided with the necessary training, equipment, and resources to perform their duties safely.

We actively promote a safety-first culture where every individual is empowered and expected to identify, report, and address potential safety concerns without fear of reprisal.

Incidents and near-misses are thoroughly investigated to determine root causes and prevent recurrence. We continuously review and improve our health and safety performance.

General Working Condition Policy and Procedure

1. Purpose

The aim of this General Working Condition Policy and Procedure (the "Policy") is to establish a formal framework for the management of labour practices, human rights, responsible sourcing, and working conditions at Metcon Limited ("METCON" or the "Company"). This Policy ensures compliance with Nigerian labour and mining regulations, alignment with relevant international standards. It fosters a safe, inclusive, ethical, and productive work environment across all METCON operations.

2. Scope and Applicability

This Policy applies to:

a. All permanent and temporary employees of METCON;
b. Contract and outsourced personnel engaged to perform work at the mine site; and
c. Any other individuals providing services under the control or supervision of the Company.

Section 2 — Terms and Conditions of Employment

4.3 Remuneration

a. The Company shall ensure fair and competitive remuneration practices.
b. Salaries shall not fall below the statutory minimum wage and shall be paid monthly.
c. Employees shall, upon request, receive payslips detailing gross earnings, deductions, and net pay.
d. Unauthorized or unlawful deductions are strictly prohibited.

4.4 Leave Entitlements

a. Employees are entitled to a minimum of 10 days' paid annual leave per annum in accordance with the Labour Act.
b. Additional leave entitlements (e.g., sick leave, maternity/paternity leave, compassionate leave) shall be provided in line with statutory requirements and Company policy.
c. Leave requests must be submitted in writing and approved by the relevant line manager.

4.5 Pensions and Statutory Benefits

a. Eligible employees shall be enrolled in the statutory pension scheme as provided under applicable law.
b. The Company shall make mandatory contributions promptly and accurately.
c. Other statutory benefits such as health insurance, NSITF, and ITF (where applicable) shall be administered in compliance with legal obligations.

5. Code of Conduct

5.1 Equal Opportunity and Non-Discrimination

a. Employment decisions shall be based on merit, qualifications, and business needs.
b. Discrimination, harassment, or unfair treatment based on gender, age, religion, ethnicity, disability, or any other protected status is strictly prohibited.

5.2 Workplace Behaviour

a. Employees shall conduct themselves with professionalism, honesty, and respect towards colleagues, contractors, and stakeholders.
b. Bullying, harassment, or any form of intimidation will not be tolerated.
c. Confidential information must be safeguarded at all times.

5.3 Health, Safety, and Environment (HSE)

a. Employees must comply with all health and safety regulations, procedures, and training requirements.
b. Unsafe practices, negligence, or deliberate disregard of HSE standards shall be subject to disciplinary action.
c. All incidents, hazards, and near-misses must be reported promptly.

5.4 Ethical Conduct

a. Employees shall avoid conflicts of interest and must disclose any potential conflicts to management.
b. Zero tolerance for bribery and corruption; acceptance of improper gifts or favours is prohibited.
c. Company resources must be used responsibly and only for authorised business purposes.

5.5 Compliance with Laws

a. Employees must comply with all applicable national labour laws, industry regulations, and internal policies.
b. Violations of laws or Company rules may result in disciplinary action, up to and including termination of employment.

6. Human Rights Due Diligence (HRDD)

a. The Company shall adopt a structured approach to the management of human rights across all operations and supply chains.
b. METCON shall conduct regular human rights risk assessments to identify, evaluate, and mitigate potential adverse impacts on workers, communities, and other stakeholders.
c. The Company shall implement systems for performance monitoring, including KPIs on labour practices, HSE incidents, community impacts, and grievance resolution.
d. Human rights performance shall be subject to periodic auditing, including internal audits and, where appropriate, independent third-party reviews.
e. Findings from HRDD assessments and audits shall be reported to the Board of Directors and, where relevant, disclosed to stakeholders.

7. Responsible Sourcing & Traceability

a. All minerals produced or traded by METCON shall be subject to a traceability and chain-of-custody system evidencing origin and legitimacy.
b. The Company shall not source or trade in minerals associated with conflict, human rights abuses, or child/forced labour.
c. METCON shall conduct and document supply-chain due diligence in line with recognised international standards (including the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals).
d. Counterparty KYC and sanctions screening are mandatory prior to engagement and on a periodic basis.

8. Community Engagement

a. METCON shall engage openly, transparently, and respectfully with host communities.
b. The Company shall maintain effective grievance mechanisms and respond promptly to concerns.
c. Where feasible, the Company shall promote local employment, training, and community development initiatives.
d. Land access and resettlement (if any) shall follow lawful processes and FPIC-aligned consultation practices.

9. Transparency & Reporting

a. METCON shall maintain accurate records of production, exports, royalties, and taxes and operate in line with EITI principles.
b. Compliance with this Policy, including HRDD and Responsible Sourcing, shall be reviewed annually and reported to the Board.
c. Relevant ESG performance indicators may be disclosed in the Company's sustainability or annual reports.

10. Commercial Practices

a. The Company shall ensure fairness and transparency in pricing, contracting, and delivery of minerals.
b. While respecting confidentiality, the Company shall remain audit-ready for regulatory and contractual reviews by offtakers, lenders, and authorities.
c. All commercial transactions shall be conducted in accordance with internationally accepted business ethics and applicable trade controls.

11. Responsibilities

a. Board of Directors: Provides oversight of this Policy, HRDD, and ESG obligations; reviews annual compliance reports and audit findings.
b. Legal & Compliance: Advises on legal obligations; coordinates supply-chain due diligence, HRDD audits, and reporting.
c. Human Resources: Administers labour-related provisions, training, and grievance mechanisms; monitors KPIs.
d. Line Managers: Ensure fair application of labour practices within departments; support employees in accessing entitlements.
e. Employees & Contractors: Comply with Company rules and procedures relating to labour practices, HSE, human rights, and the Code of Conduct.

12. Grievance & Non-Retaliation

The Company shall provide confidential, accessible, and non-retaliatory grievance channels for employees, contractors, and communities to raise concerns. Retaliation for reporting misconduct or participating in investigations is strictly prohibited.

13. Monitoring, Review & Continuous Improvement

a. This Policy shall be reviewed annually or earlier as required by changes in legislation, international standards, or operational needs.
b. METCON is committed to continuous improvement in labour, HSE, human rights, and ESG performance.
c. Non-compliance with this Policy or the Code of Conduct may result in disciplinary action, including termination of employment or contracts.

14. Effective Date

This Policy is effective on 1 March 2025.

Annex A — Human Rights Risk Matrix

Risk Area	Potential Risks	Controls & Mitigation	KPIs / Monitoring
Labour Practices	Child/forced labour; excessive hours; lack of contracts	Age verification; written contracts; labour audits; HSE standards; training	% workforce with verified IDs & contracts; # HSE incidents; training completion rate
Discrimination & Harassment	Gender/ethnic/religious discrimination; harassment	Equal opportunity policy; anti-harassment training; confidential grievance channels	Diversity ratios; # grievances raised/resolved; time to resolution; employee survey results
Community Impacts	Land rights disputes; inadequate consultation; livelihood impacts	Stakeholder mapping; FPIC-aligned consultation; community liaison; grievance redress	# community meetings; grievance resolution time; % local hires
Health & Safety	Accidents; occupational diseases	Mandatory PPE; drills; incident investigation; medical surveillance; insurance	LTIFR; TRIR; % workforce HSE-trained; corrective action closure rate
Supply Chain	Conflict minerals; child labour; illegal mining; sanctions risk	Supplier KYC; risk screening; contract clauses; site/desk audits; escalation process	% suppliers risk-screened; # red flags remediated; audit coverage %
Security & Human Rights	Excessive use of force; abuses by security personnel	Alignment with Voluntary Principles on Security & Human Rights; training; incident reporting	# incidents; % security staff trained; corrective actions closed

Annex B — Implementation & Reporting Framework

1. Annual Human Rights Risk Assessment covering operations and key suppliers.
2. Quarterly KPI Monitoring (HR, HSE, community, supply chain) reviewed by Management.
3. Biennial Internal Audit of HRDD, labour practices, and responsible sourcing controls.
4. Independent Third-Party Review at least once every three (3) years or as requested by offtakers/lenders.
5. Board Oversight: Annual summary of findings, remediation status, and improvement plan presented to the Board.
6. Disclosure: Relevant ESG metrics and progress reported in sustainability or annual reports; key policies published.

Our Policies