Kibi Goldfields

Anti Money Laundering Policy

Introduction

The most important means by which Kibi Goldfields can avoid criminal exposure to third parties (service providers, suppliers, business partners, companies in consortium, representatives, temporary advisors or any other person or company that act on behalf of Kibi Goldfields, directly or indirectly) who use the resources of the company for illicit purposes is to have a clear and concise understanding of the third parties’s practices. The adoption of an effective “Know Your Customer” policy will enhance the company’s ability to detect suspicious activities by customers in a timely manner. It will also facilitate compliance with relevant regulatory requirements.

In formulating an effective KYC policy, it is important to note that appearances can be deceptive. Potential business partners of Kibi Goldfields may appear legitimate but in reality be conducting illicit activities through the company, while legitimate business partners may be turned away from the company because their activities are perceived to have a criminal tone. The policy must therefore, at a minimum, contain a clear statement of management’s overall objectives, expectations and establish specific line responsibilities.

Objectives

The objectives of Kibi Goldfields’s KYC policy are as follows:
• Ensure that Kibi Goldfields is in full compliance with all statutes and regulations and adheres to sound and recognized practices.
• Ensure that Kibi Goldfields will not become a victim of illegal activities perpetrated by its clients.
• Ensure an effective policy that protects the good name and reputation of Kibi Goldfields in accordance with the best corporate governance and Compliance practices, ensuring the complete and effective awareness of its clients and their activities, and establishing criteria of ethical, professional and good faith conduct.
• Ensure that the policy does not undermine the cordial relationship between Kibi Goldfields and its credible customers.

Scope

This policy is applicable to Kibi Goldfields Company Ltd as well as Third Parties, who act for and/or represent Kibi Goldfields in its activities.

Content of the Policy

The following principles will be incorporated into the business practices of Kibi Goldfields:
• Kibi Goldfields will make a reasonable effort to determine the true identity of all third parties requesting the company’s services.
• Kibi Goldfields will take particular care to identify the ownership of all contract agreement. Kibi Goldfields will put in place a process for the identification of unusual transactions and activities that are inconsistent with the third party’s known business. In this regard, the company will establish a set of procedures that facilitates the collation of sufficient information for each customer. The primary objective of such procedures is to enable Kibi Goldfields predict with relative certainty the types of transactions in which a customer is likely to engage.
• Once identified, Kibi Goldfields will report suspicious transactions to appropriate personnel as directed by their businesses’ policies and procedures.
• Establish internal training programs.
• Kibi Goldfields shall not deal with ‘shell companies, i.e. companies incorporated in a jurisdiction in which it has no physical presence and is not affiliated with regulated sectors.

Staff Training

Every employee (interns, staff of all operational and managerial levels, advisors, directors and officers) of the company, shall be trained on AML at a minimum of once a year.

Anti-money Laundering Policies, Procedures and Regulatory Requirements

Definition of money laundering and terrorist financing
Money laundering is a process in which assets obtained or generated by criminal activity are moved or concealed to obscure their link with the crime. Perpetrators of the crime find ways to launder the funds in order to use them without drawing the attention of authorities.
Money laundering empowers corruption and organized crime where corrupt public officials and criminals are able to launder proceeds from crimes, bribes, kick-backs, public funds and on some occasion, even development loans from international financial institutions. Organized criminal groups want to be able to launder the proceeds of drug trafficking and commodity smuggling through the financial systems without a trace. In the modern day definition, money laundering now covers various offences including child trafficking, prostitution, etc. Generally, money laundering has three stages;

Placement

The physical disposal of cash/property derived from criminal activity. The purpose of this stage is to introduce proceeds into the traditional or non–traditional financial system without attracting attention e.g. purchase of artwork, cash deposits, casinos etc.

Layering

This involves separating source of proceeds from ownership by changing the form. It is designed to hamper audit trail e.g. complex wire transfers, resell of assets/properties, purchase of multiple investment-linked life policies to disguise origin of funds etc.

Integration

Re–channeling the laundered funds back to the financial system as legitimate funds.
The degree of sophistication and complexity in the money laundering scheme is infinite and is limited only by the creative imagination and expertise of criminals. Terrorist activities are sometimes funded from the proceeds of illegal activities.
Although often linked in legislation and regulation, terrorist financing and money laundering are conceptual opposites. Money laundering is the process where cash raised from criminal activities is made to look legitimate for re-integration into the financial system, whereas terrorist financing cares little about the source of the funds, but it is what the funds are to be used for that defines its scope.
In recent years, the international community has become more aware of the dangers that money laundering and terrorist financing poses in all these areas, and many governments and jurisdictions have committed themselves to taking action. The United Nations and other international organizations like Financial Action Task Force (FATF) are committed to helping governments in any way they can.

The Implication and Impact of Money Laundering on Kibi Goldfields

Where Anti-Money Laundering rules apply, compliance by the stakeholders of Kibi Goldfields Company is mandatory. Four key principles apply:
• Staff and key stakeholders of Kibi Goldfields should not engage in money laundering activities knowingly.
• Staff and key stakeholders of Kibi Goldfields Company should not assist others in engaging in money laundering activities.
• Kibi Goldfields and their personnel should not interfere with an authorized official investigation of money laundering.
• Personnel of Kibi Goldfields must implement appropriate processes, systems and controls to ensure compliance with local AML laws and regulations.

Failure of Kibi Goldfields and its staff to observe these principles damages the reputation, brand and goodwill of both Kibi Goldfields and the network of Kibi Goldfields Company, and risk exposure to criminal prosecution and or regulatory action.

The Importance of Money Laundering To the Individual Employee and Kibi Goldfields Company Ltd

In adhering to this Policy, as with every aspect of its business, Kibi Goldfields expects that its employees will conduct themselves in accordance with the highest ethical standards. Kibi Goldfields also expects its employees to conduct business in accordance with applicable money laundering laws. Kibi Goldfields employees shall not knowingly provide assistance to individuals who attempts to violate or avoid money laundering laws or this Policy.
Money Laundering laws apply not only to criminals who try to launder their ill-gotten gains, but also to institutions and their employees who participate in those transactions, if the employees know that the property is criminally derived.
“Knowledge” includes the concepts of “willful blindness” and “conscious avoidance of knowledge”. Thus, employees whose suspicions are aroused, but who then deliberately fail to make further inquiries, wishing to remain ignorant, may be considered under the law to have the requisite “knowledge”.

Kibi Goldfields employees who suspect money laundering activities should refer the matter to appropriate personnel as directed by their businesses’ policies and procedures.
Failure to adhere to this Policy may subject Kibi Goldfields employees to disciplinary action up to and including termination of employment. Violations of money laundering laws also may subject Kibi Goldfields employees to imprisonment and, together with Kibi Goldfields, to fines, forfeiture of assets, and other serious punishment.

As a company, the under-listed policies are put in place to guard against signing on persons and organizations involved in money laundering activities:

Principle of “Know Your Customer” (KYC)
• Customers are required to complete forms that captures information that will enable the Company to access the money laundering risk of the customer or the transaction.
• Relationship with the customer should not be established until we are convinced that the customer is not involved in money laundering activities.
• For all high risk businesses, site visitation of client’s address shall be carried out.
• The form shall capture enough KYC details to ensure that organizations or persons involved in money laundering activity are not signed on as customers.
• The company’s relationship managers and other officers of the company should be trained to be able to recognize suspicious transactions, such that timely return could be rendered to the regulatory authorities.
• Money laundering training should also be part of courses conducted for new staff members of the company.
• Suspicious transactions shall be reported to regulatory authorities as soon as such are detected.
• Appropriate measures shall be put in place to ensure that blacklisted terrorist organizations circularized by the FIC are not signed on as customers.

Regulatory Framework

Companies in Ghana are monitored for money laundering under the provisions of various regulations which are highlighted below:
List of Regulations
• AML Act 2008 – Act 749
• AML (Amendment) Act, 2014, Act 874
• AML Regulations 2011 L.I. 1987
• Anti-Terrorism Amendment Act, 2012 Act 842
• Anti-Terrorism Regulations L.I. 2181
• Criminal and Other Offences Act, 1960, Act 29
• Criminal Offences Amendment Act, 2012 – Act 849
• Economic and Organized Crime Act, 804
• Economic and Organized Crime Regulations, LI2183
• Gazette Notice with Regard to Terrorist Individuals Immigration Amendment Act 2012 (criminalized migrant smuggling in line with FATF standards)

Standard Principle of “Customer Identification” (KYC)

Kibi Goldfields shall have policies and procedures to determine and document at the time of the establishment of the business relationship, information that is commensurate with the assessment of the money laundering risks posed by the customer’s expected use services as shown below:
• The customer’s Name
• The customer’s form of ID
• The customer’s Proof or residence
• The customer’s source of funds
• The customer’s source of income and assets

Kibi Goldfields businesses shall have policies and procedures for obtaining and updating customers’ information obtained at the time of the establishment of a relationship i.e. “customer’s profile”. To achieve this, customers’ information shall be obtained and updated the on-boarding stage.

Information on customers of Kibi Goldfields Limited

Kibi Goldfields shall establish policies and procedures under which the company can rely upon for information on the identification of a customer who maintains mutual relationship.

Watch list Check

Kibi Goldfields shall have policies and procedures that will ensure compliance with standard AML global requirement for maintenance of a data base for individuals/entities subject to sanction by the United Nations in its database.
The implication of this is that all processing units are required to check every single transaction for any individual/entity against this database and report any matching details to the MLRO and appropriate regulatory authority. The list will include Politically Exposed Person (PEP) List, Specially Designated Nationals (SDN) List, Office of Foreign Assets Control (OFAC) List, United Nations (UN) List, European Union (EU) List etc.

Compliance with Legislation

Kibi Goldfields will observe high ethical standards within the confines of the laws and regulations guiding its operations.

Cooperation with Law Enforcement Authorities

Kibi Goldfields will give full cooperation to law enforcement authorities within the limits of the rule governing confidentiality. For instance, where a company is aware of the facts that certain funds used in financing businesses was derived from criminal activity or intention, the company is expected to observe the stipulated procedures for disclosure of suspicious transactions by reporting to the Financial Intelligence Center (FIC) immediately.

Kyc Documentation Requirement

The Company is obliged to confirm and verify the identity of each person who enters into a business relationship with them. Hence, as part of the Company’s obligations to comply with applicable Anti-money laundering & Know Your Customer legislation, the Company requests its Clients and business partners to provide certain Verification Documents.

However, it is important that the Firm’s customers conform to the Firm’s principles and standards. Among other things, the following principles are considered as a part of the Know Your Customer procedure:
• The Company will not accept as Clients persons engaged in unethical behavior or in illegal activities;
• The Company will not accept as Clients or associates, parties that they cannot make a well informed and reasonable judgment as to the activities in which they are engaged;
• The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information.
• The Company will accept only those new Clients who complete the appropriate risk assessment forms and provide the Company with all necessary Verification Documents and information to the satisfaction of the Kibi Goldfields.
• The Company will accept a prospective or potential Client only when it becomes fully satisfied that the Client complies with Know Your Customer and due diligence procedures to ensure that a new relationship with the potential Client does not negatively affect the reputation of the Firm.

For the proper identification of the client and performing due diligence procedures, Kibi Goldfields will use the KYC Checklist as a tool being an integral part of the client/ third party acceptance or continuance procedures. The KYC Checklist is attached as Appendix I.
The information in the KYC form shall be maintained and constantly updated whenever relevant new information about the business partner surfaces.

If, during the business relationship, a Client or vendor fails or refuses to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested by the Firm; the Company is entitled to terminate the business relationship. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If the Client or vendor denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship The Client or vendor warrants that at all times all the information provided to the Company shall be true, accurate, up to date and complete and that the Client shall update the Company in writing via e-mail (send to the Company from the Client’s registered e-mail address) or letter upon any changes in regard to the information provided.

Client or vendors hereby agrees that the information collected and obtained from them may be used by the Company, and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Client or vendor hereby authorizes the above entities to conduct the said checks.

Risk Based Anti-money Laundering Programs

In order to make the company’s Anti-Money Laundering program more focused, a risk-based approach will be pursued. Controls will be put in place based on the risk posed by customers served and geographic jurisdiction as follows:

High-risk customers

Certain kinds of business will require enhanced customer due diligence and ongoing transactions review. The reviews will include their anti-money laundering systems, potential for being abused by money launderers, their level of risk and the company’s ability to control this risk. The high-risk entities include:
• Non- Bank financial institutions like Money lenders and Forex Bureau
• Non-Government Organizations like Nontraditional Churches
• Offshore Corporations
• Cash Intensive business like distributorship business

High-risk geographical Locations
Identifying high-risk geographic locations is essential to the Kibi Goldfields’s anti-money laundering program. Management will therefore gather information regarding high-risk geographic locations from several sources. Identifying customers and transactions from high-risk geographic locations will help develop, modify policies procedures and controls addressing the risks associated with those locations.
This document will be amended from time to time to meet with the changes put in place by government institutions to curb this AML/CFT.

Key Stakeholders Responsibilities

Board of Directors

• The Company’s Board of Directors has overall responsibility for ensuring this policy complies with the legal and ethical obligations, and that all those under the Company’s control comply with it.
• The Board shall approve AML/CFT policies that promote a culture of compliance.

Senior Management

The Senior Management of the company shall be responsible for managing the business effectively, in relation to AML/CFT systems. The senior management should;
• Be satisfied that the company’s AML/CFT systems are capable of addressing the ML/TF risks identified
• Appoint a director or senior manager as a compliance officer who has overall responsibility for the establishment and maintenance of the company’s AML/CFT systems
• Appoint a senior member of staff as the Money Laundering Reporting Officer (MLRO) who will be the central reference point for suspicious transaction reporting

Compliance Officer and Money Laundering Reporting Officer

The function of the Compliance Officer (CO) is to act as the focal point within the company for the oversight of all activities relating to the prevention and detection of ML/TF and providing support and guidance to the senior management to ensure that ML/TF risks are adequately managed. In particular, the CO assumes responsibility for:
• Developing and/or continuously review the company’s AML/CFT systems to ensure they remain up-to-date and meet current statutory and regulatory requirements.
• The oversight of all aspects of the AML/CFT systems, which include monitoring effectiveness and enhancing the controls and procedures where necessary.

Compliance and Audit Function

The independent compliance and audit function will have a direct line of communication to the senior management. The audit function either internal or outsourced shall;
• Regularly review the AML/CFT system to ensure effectiveness.
• Ensure important matters are escalated.
• Ensure proper compliance and implementation of AML/CFT policies.
• Shall have direct reporting line to the BOD.

Money Laundering Reporting Officer (MLRO)

The MLRO should play an active role in the identification and reporting of suspicious transactions. Principal functions performed are expected to include:
• Review all internal disclosures and exception reports and, in light of all available relevant information, determining whether or not it is necessary to make a report;
• Maintenance of all records related to such internal reviews;
• Act as the main point of contact with the fic, law enforcement, and any other competent authorities in relation to ml/tf prevention and detection, investigation or compliance.

Third Parties
Third Parties must ensure provision of timely, accurate and adequate information to enhance the due diligence checks performed.

Record Keeping

Employees are encouraged and mandated to immediately report all suspicious transactions to the MLRO for further investigation and report to the FIC. STRs must be filed when Customer:
• Presents fake documentation; or
• Is found to have been suspect in news publications egg. Wanted Persons etc.; or
• Is involved in identity theft, that is, presents fake Identity card to impersonate someone else in order to have access to a transaction; or
• Fails to complete the required Customer Relationship Form within the stipulated time.

Continuous Monitoring

Effective ongoing monitoring is vital for understanding of customers’ activities and an integral part of effective AML/CFT systems. It helps companies to know their customers and to detect unusual or suspicious activities.

Kibi Goldfields will continuously monitor its business relationship with customers by:
• Reviewing from time to time documents, data and information relating to the customer and obtained to ensure that they are up-to-date and relevant4;
• Monitoring the activities (including cash and non-cash transactions) of the customer to ensure that they are consistent with the nature of business, the risk profile and source of funds. An unusual transaction may be in the form of activity that is inconsistent with the expected pattern for that customer, or with the normal business activities for the type of product or service that is being delivered; and
• Identifying transactions that are complex, large or unusual or patterns of transactions that have no apparent economic or lawful purpose and which may indicate ML/TF.
Failure to conduct ongoing monitoring could expose Kibi Goldfields to potential abuse by criminals, and may call into question the adequacy of systems and controls, or the prudence and integrity or fitness and properness of Kibi Goldfields’s management.

How to Raise a Concern

• Employees, directors and all stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage via designated whistle blowing channels.
• To guarantee the anonymity of employees and other persons who may want to report suspicious malpractices, management will from time to time deploy the services of an independent whistle blowing platform/firm.

Anti-Bribery and Corruption Policy

Introduction

Kibi Goldfields Company Ltd (herein “Kibi Goldfields”) adopts a zero tolerance approach to bribery and corruption. The Company conducts business affairs in a manner that shuns the use of corrupt practices or acts of bribery to obtain unfair advantage in our dealings within the markets and communities we operate.

This policy sets out the general rules and principles we adhere to, and also communicate to all employees, directors, agents, consultants, business associates as well as relevant partners, suppliers, and other stakeholders the need to maintain high ethical and professional conduct in the course of doing the Company’s business.

What is Bribery and Corruption?

Bribery and corruption can be regarded as but not limited to the following:
• The offer, promise, payment, transfer, request, agreement, to receive or the receipt of anything of value, whether directly or indirectly, to or from any person (whether a private person, corporate entity, or public official), in order to induce that person (or any other person through the aid of the recipient) to perform their roles improperly or, in the case of a public official, in order to influence them with the intention of obtaining or retaining business or an advantage in the conduct of business.
• The abuse or misuse of entrusted power or public officer for private gain.
• An inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage through “improper performance”.
• An “improper performance” happens when a person fails to act (1) in good faith, (2) impartially or (3) in accordance with a position of trust. Corruption is often associated with organized crime, money laundering and in some occasions the financing of terrorism. In addition, it affects the efficacy of investment and financing in the industrial and financial services sectors, particularly within economically disadvantaged societies. However, the mentioned categories of corrupt practices above are not closed but also include diverse acts amounting to bribery and breach of ethical rules and standards.

Scope of the Policy

This Anti-Bribery and Corruption Policy is designed to comply with, The 1992 Constitution of Ghana, The Criminal and Other Offence Act, 1960 (Act 29), Office of the Special Prosecutor Act, 2017 (959), The Government Contract Act 1979, Economic and Organised Crime Act 2010, United Nations Convention Against Corruption Treaty, The Africa Union Convention on Preventing and Combating Corruption, UK Bribery Act 2010, the US Legislation (Foreign Corrupt Practices Act), as well as compliance with all applicable anti-bribery laws covering both international and local jurisdictions.

Kibi Goldfields Company Ltd.’s Anti-Bribery and Corruption Policy requires that employees, directors and business associates of Kibi Goldfields are:

• Prohibited from offering, promising, giving, requesting, accepting or agreeing to receive a bribe of any kind in any form, directly or indirectly.
• Prohibited from making facilitation or gratification payments, even if this represents local practice or custom.
• Prohibited from offering, promising or transferring anything of value to a public official in order to influence the public official and obtain or retain business or an advantage for the benefit of Kibi Goldfields (or to obtain or retain an advantage for any employee, any other entity or person). This includes offers, promises or transfers made to any third party (such as a public official’s family members or business associates) in order to influence a public official.
• To carry out appropriate due diligence on parties when Kibi Goldfields proposes to engage them to perform services for, or on behalf of the Company, and to include appropriate anti-bribery and anti-corruption clauses in contractual arrangements with such parties.
• Prohibited from offering/giving/accepting gifts from third parties.
• To undertake appropriate anti-bribery and anti-corruption training and awareness programs at least once every year.
• To audit donations and sponsorships from time to time and ensure that such donations/sponsorships are not disguised to obtain undue favours for the company.

The policy also contains procedures for employees, directors and business associates of RCCL on how to manage the risks of facilitation payments and contains provisions on charitable donations, sponsorship and record keeping.
Failure by any employee, director, agents or associates to comply with the policy requirements may lead to disciplinary action up to and including dismissal or termination of employment or appointment.

Purpose

The purpose of this policy is to:

• Set out Kibi Goldfields’s responsibilities and that of all staff, directors, or business associates, in observing and upholding the firm’s principles on bribery and corruption;
• Provide information and guidance to staff, directors, and business associates on how to recognize and deal with bribery and corruption issues.

Stakeholders

This policy will apply in Kibi Goldfields Company Limited. It is important that it be read and adhered to at all time. The policy applies to all individuals working at all levels and grades, including managers, officers, directors, employees, consultants, contractors, or any other person associated with the Company or its employees, wherever located (collectively referred to as employees in this policy).

Risk Assessment

Effective risk assessment lies at the very core of the success or failure of this policy. Risk identification pinpoints the specific areas which the Company faces bribery and corruption risks and allows the Company to better evaluate and mitigate these risks and thereby protect the brand.

Business practices around the world can be deeply rooted in attitude, cultures and models which Management needs to assess the vulnerability of the Company to bribery and corruption risks. The risk assessment shall include assessment of external risks (country, sector, transactions, business opportunities, and business partner’s risks).

PERIODIC REVIEW AND MONITORING

Kibi Goldfields Company Limited shall conduct assessment of the Anti-bribery and Corruption Policy on an annual basis and report this to the Board to provide reasonable assurance that the program has continued to function effectively.

Statement of Policy

It is an offence to:

• Bribe another person
• Be bribed
• Bribe a public official
• Fail to prevent bribery and corruption
• Fail to report any suspected infraction or wrongdoing relating to bribery and corruption
• Kibi Goldfields employees, directors, business associates and stakeholders must never offer, promise, or give financial or other advantage to any person (including a foreign public official) with the intention of rewarding improper performance by them in the course of duty. • Kibi Goldfields employees, directors, business associates, and other stakeholders must never directly or indirectly accept or agree to receive financial or other advantage as reward for the improper performance of their duties. It makes no difference whether the advantage is for them or a third party or the Company.
• In this policy “third party” means any individual or organization we come into contact with during the course of doing business and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, including their advisors, representatives, and officials, politicians and political parties.

This Policy should be read in conjunction with other related policies and regulations such as:

• Government Contracts (Protection) Act. 1979
• Office of the Special Prosecutor Act (Act 959)
• Economic and Organised Crime Act, 2010
• Criminal Code Act, 1960 (Act 29)
• Criminal Offences Act (Amendment), 2012
• Whistleblower Act, 2006 (Act 720)
• United Nations Convention Against Corruption
• African Union Convention on Preventing and Combating Corruption
• The US Foreign Corrupt Practices Act (FCPA)
• UK Anti-Bribery Act
• Our Principles
• It is Kibi Goldfields Company Ltd.’s policy to conduct all its business in an honest and ethical manner. The Company adopts a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships wherever it operates.
• It is the Company’s requirement that those it does business with takes a similar zero tolerance approach to bribery and corruption. • The Company is bound by the laws of Ghana, and all other international and local laws relevant to countering bribery and corruption in the jurisdictions in which it operates.
• Bribery and corruption are criminal offences and are punishable for individuals by up to ten years’ imprisonment and an unlimited fine which can also apply to the institution. The Company therefore takes its legal responsibilities in this regard seriously and expects all the stakeholders to do the same.

Kyc Documentation Requirement

The Company is obliged to confirm and verify the identity of each person who enters into a business relationship with them. Hence, as part of the Company’s obligations to comply with applicable Anti-money laundering & Know Your Customer legislation, the Company requests its Clients and business partners to provide certain Verification Documents.

However, it is important that the Firm’s customers conform to the Firm’s principles and standards. Among other things, the following principles are considered as a part of the Know Your Customer procedure:
• The Company will not accept as Clients persons engaged in unethical behavior or in illegal activities;
• The Company will not accept as Clients or associates, parties that they cannot make a well informed and reasonable judgment as to the activities in which they are engaged;
• The Company will not accept as Clients, persons unwilling to provide sufficient documents/data and information.
• The Company will accept only those new Clients who complete the appropriate risk assessment forms and provide the Company with all necessary Verification Documents and information to the satisfaction of the Kibi Goldfields.
• The Company will accept a prospective or potential Client only when it becomes fully satisfied that the Client complies with Know Your Customer and due diligence procedures to ensure that a new relationship with the potential Client does not negatively affect the reputation of the Firm.

For the proper identification of the client and performing due diligence procedures, Kibi Goldfields will use the KYC Checklist as a tool being an integral part of the client/ third party acceptance or continuance procedures. The KYC Checklist is attached as Appendix I.
The information in the KYC form shall be maintained and constantly updated whenever relevant new information about the business partner surfaces.

If, during the business relationship, a Client or vendor fails or refuses to submit, within a reasonable timeframe set by the Company, the required documents, data and information requested by the Firm; the Company is entitled to terminate the business relationship. Moreover, during the business relationship additional documents may be requested by the Company and/or an update of the existing documents. If the Client or vendor denies providing these documents without any legitimate reason, the Company is entitled to terminate the business relationship.
The Client or vendor warrants that at all times all the information provided to the Company shall be true, accurate, up to date and complete and that the Client shall update the Company in writing via e-mail (send to the Company from the Client’s registered e-mail address) or letter upon any changes in regard to the information provided.

Client or vendors hereby agrees that the information collected and obtained from them may be used by the Company, and regulatory bodies to conduct identity, fraud, AML, credit and other checks and the Client or vendor hereby authorizes the above entities to conduct the said checks.

Responsibility for the Policy

The Company’s Board of Directors has overall responsibility for ensuring this policy complies with the legal and ethical obligations, and that all those under the Company’s control comply with it.
• Management and senior staff at all levels are responsible for ensuring that staff reporting to them are made aware of and understand the policy.
• Responsibility of Key Officers
• Anti-bribery and Corruption Compliance Officer (ABCCO).

The firm shall appoint an ABCC officer who occupies senior management position or at least middle management role. The responsibilities of the ABCCO include:
• Develop and implement the Company’s Anti-bribery and Corruption Program.
• Conduct an annual risk assessment which identifies and assesses the internal and external risk of the Company relating to bribery and corruption practices.
• Ensure that all employees are required to confirm understanding and compliance with Anti-bribery and corruption policy of the Company on an annual basis.
• Ensure delivery of relevant training and awareness to employees throughout Kibi Goldfields to support them in meeting their responsibilities.
• Providing guidance and ongoing training opportunities for vendors, suppliers and business partners on anti-bribery and corruption.
• Establish and implement an effective Anti-bribery and Corruption monitoring program across all risk areas in the Company.
• Ensure that there are appropriate means to investigate and record instances or allegations of bribery/corruption in the Company.
• Chief Compliance Officer (CCO)
Either internal or outsourced, shall oversee the activity of the ABCCO and provide second level advise to management on the compliance posture of Kibi Goldfields to the firm’s ABC policy at all times. The compliance officer shall examine any form of non-compliance to the attention of senior management and the board.

Chief Internal Auditor

The Chief Internal Auditor audits the Anti-Bribery and Corruption programme periodically and the donations made during the period to ascertain the adequacy and adherence to internal controls.

Gifts and Hospitality

In consideration of services rendered, being rendered or to be rendered, employees shall not ask for, receive, consent or agree to receive, any gift, commission, employment, service, gratuity, money, property or anything of value for their personal benefit or advantage or for that of their spouses and dependents from a customer of, or a supplier to the Company.

A gift and hospitality register shall be maintained to record details of gifts received or given. All gifts and donations whose values exceed the cedi equivalent of $25.00 will have to be declared for approval by management.

• While it is recognized that exchange of gift is customary in festive seasons of Christmas/New Year, Id-el Fitri and Id-el-Kabir, as well as Easter, employees shall not during these seasons accept gift with excess value of $25.00 of any kind from any customer or supplier without declaration and approval
• Where the employees are in doubt as to the value of the gift, the affected employee should declare such gift to Management through the Head, Human Resources.
• If in any circumstance, the refusal of any gift referred to herein would adversely affect the relationship of the giver with the Company, the affected employee shall make a report of and deliver such gift to Management. • In every case and regardless of time or season, employees shall make every effort to discern whether any gift is truly a gift or an inducement and in the case of the latter, employees shall reject the gift regardless of the value, in its entirety.

The giving or receipt of gifts and hospitality is not prohibited, if the following requirements are met:
• Disclosure to the management in advance (where it is possible to do, or as soon as possible afterwards);
• It is not made with the intention of influencing, inducing or rewarding a third party in order to gain any advantage through improper performance, or in explicit or implicit exchange for favours or benefits.
• It complies with local laws
• It is given in the Company’s name
• It is appropriate in the circumstances
• Taking into account the reason for the gift, if it is an appropriate type and value and given at an appropriate time provided the Company is not participating in any tendering process with the recipient.
• It is given openly, not secretly
• Gifts and/or hospitality are not offered to, or accepted from, government officials or representatives or politicians or political parties, without the prior approval of management.

NOTE: Gifts in hampers and related form received by staff of the Company at any time will be submitted/disclosed to the head, Human Resources.

Facilitation Payments

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
• Kickbacks are typically payments made in return for a business favour or advantage. All employees, directors, and business associates must avoid any activity that might lead to, or suggest that a facilitation payment or kickback will be made or accepted by the Company.
• If an employee or director or subcontractor is asked to make a payment on behalf of the Company, the purpose should be known and the amount should be proportionate to the goods or services provided.
• Whilst the law prohibits facilitation payments or kickbacks, no employee or director or business associate is required to place his/her professional integrity at risk.

Donations

Kibi Goldfields Company Ltd will not make contributions to political parties for the pursuit of their objectives. The Company only makes charitable donations that are legal and ethical under local laws and practices. Requests for sponsorship and donations should be forwarded to the head of legal and compliance for advice.

Record-keeping

The Company shall keep financial records and have appropriate internal controls in place, which will evidence the business reason for making and/or receiving payments in respect of donations, hospitality, gifts, etc. to and from third parties.
• The Company shall ensure that all expense payments relating to donations, hospitality, gifts to third parties are submitted in accordance with the Expense Policy and specifically record the reason for the expenditure.
• All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Communication and Training

All employees and directors of the Company shall undertake appropriate Anti-bribery and Corruption training at least once a year. All Kibi Goldfields internal and external communication shall emphasize the Company’s commitment to anti-bribery and corruption practices.

What Is Not Acceptable?

In addition to the above, it is not acceptable for employees or directors or business associates to:
• Give, promise to give or offer, a payment, gift or hospitality with the intention of influencing, inducing or rewarding improper performance
• Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate or expedite a routine procedure (where the payment is not a legitimate payment pursuant to local written law)
• Accept from a third party, payment that you know or suspect is offered with the expectation that it will obtain a business advantage for them which will be obtained through improper performance by the employee or directors
• Accept a gift or hospitality from a third party if it is known or suspected that it is offered or provided with the intention of influencing improper performance
• Threaten or retaliate against another employee/director who has refused to commit a bribery offence or who has raised concerns under this policy
• Engage in any activity that might lead to a breach of this policy in any respect.

How to Raise a Concern

• Employees, directors and all stakeholders are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage via designated whistle blowing channels
• To guarantee the anonymity of employees and other persons who may want to report suspicious malpractices, management will from time to time deploy the services of an independent whistle blowing platform/firm.

Protection

Employees, directors and all stakeholders that refuse to accept or offer a bribe or those who raise concerns or report another’s wrongdoing, are free from repercussions as they have acted in good faith.

Potential Risk Scenarios

Bribery and Corruption Indicators

The following is a list of possible scenarios that may arise during the course of an employee or director working for the Company and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only to help you in your compliance with this policy.

If an employee or director encounters any of these scenarios in the course of his/her work. He/she must report them promptly to management:
• He/she becomes aware that a third party engages in, or has been accused of engaging in, improper business practices
• He/she learns that a third party has a reputation for paying bribes, or requiring that bribes are paid to them or has a reputation for having a “special relationship” with foreign government officials
• A third party insists on receiving a commission or fee payment before committing to sign up to a contract with the Company or carrying out a government function or process for the Company.
• A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business
• A third party requests an unexpected additional fee or commission to “facilitate” a service
• A third party demands entertainment or gifts before commencing or continuing contractual negotiations or provision of services
• A third party requests that a payment is made to “overlook” potential legal violations
• An invoice from a third party that appears to be non-standard or customized
• A third party refuses to put contractual terms agreed in writing
• He/she is offered an unusually generous gift or offered a lavish hospitality by a third party
• He/she is asked to give hospitality to persons who are not associated with the organization (for example family members) or is offered hospitality which extends to persons beyond the Company’s business (for example family members).

Environmental Health and Safety Policy

Introduction

Policy

The personal safety and health of each employee of this company is of primary importance. Kibi Goldfields recognizes the paramount importance of ensuring a healthy, safe and accident free workplace for all our employees and visitors, and to comply with Occupational Safety and Health Administration (OSHA) regulations, Association of Building and Civil Engineering Contractors of Ghana (ABCECG) regulations, the Labour Law and Trade Union regulations as well as local safety requirements of where the business operates.

The prevention of occupationally induced injuries and illnesses is a management priority and will be given precedence in all operational matters. Kibi Goldfields will not knowingly allow unsafe conditions to exist, or permit employees to participate in unsafe activities.

Purpose of Document

To provide methods for the evaluation and maintenance of a safe working environment and to outline procedures for handling injuries and subsequent reporting requirements.

Scope

This Policy/Procedure applies to all employees, visitors’ contractors and projects of the company.

Definitions

Material Safety Data Sheet (MSDS) is a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures.

Worksite Safety Analysis

A safe work environment must be everyone's goal. Accordingly, all employees are encouraged to evaluate their work methods and areas for potential safety hazards and/or ideas for improving safety in their work environment. Employees with ideas for accident prevention should complete a Safety Suggestion Sheet and review with their project/line manager and forward to the company's Health and Safety Coordinator for follow-up.

The Occupational Safety and Health Administration (OSHA) Job Safety & Health Protection poster will be displayed at designated locations within the firm as a reminder to all employees, guest and contractors of the importance of workplace safety.

Within thirty days after the end of each calendar year, the Safety Coordinator should work in conjunction with each line/project manager to conduct a thorough self-inspection in order to identify any potential safety hazards. The Safety Coordinator, in conjunction with each line/project manager, should complete the Safety Self-Inspection Checklist.

In addition to the checklist, the Safety Coordinator and each project manager should review OSHA's General Industry Standards for additional items or areas that may not be addressed by the checklist.

• Any safety concerns or hazards discovered should be documented using Worksite Safety Action Plan and forwarded to the Safety Coordinator.
• The Safety Coordinator is responsible for overseeing completion of all action plans, and must also review and evaluate the company's safety programs, and complete the annual summary of occupational injuries and illnesses (See 6.0 OSHA Reporting and Record Keeping).
• The Safety Coordinator should arrange individual Project Safety Committee Meetings, at least monthly, that are attended by subcontractor, supervisors, foremen and other designated workers. The meetings should discuss safety issues among workers and supervisors. Any safety concerns or hazards discovered should be documented using Worksite Safety Action Plan

Agenda discussions should include but not limited to the following;

• Safety performance over the past month.
• Review of all accidents and incidents.
• Work planned for the coming month and any special concerns regarding the work.
• Resolution of outstanding Worksite Safety Action Plans.
• Policies and procedures should be updated to reflect changes and corrections that were made throughout the year.

Hazard Prevention and Control

Project managers should be responsible for creating and maintaining safe work procedures necessary to prevent and control hazards that have been identified through the worksite analysis.

Safe Work Procedures
Control procedures are the basic means for preventing accidents. Each manager should tailor their project’s safe work procedures to the job tasks being performed and the worksite environment. Further, these safe work procedures must include the company's worksite safety rules (WORKSITE SAFETY RULES).

NOTE: OSHA standards should be used to develop safe work procedures since they address controls in order of effectiveness and preference. Where no standard exists, creative problem solving by employees and managers should help create effective controls. The basic formula OSHA follows is, in order of preference:
• Eliminating the hazard from the machine, the method, the material or the plant structure.
• Abating the hazard by limiting exposure or controlling it at its source.
• Training personnel to be aware of the hazard and to follow safe work procedures to avoid it.
• Prescribing personal protective equipment for protecting employees against the hazard.
• Protective Equipment.

Employees are required to wear protective clothing and equipment as indicated by their project’s safe work procedures. These procedures should specifically indicate when, where and what types of equipment are to be worn. Evaluation of types of equipment and clothing should include protection against damage to eyesight or hearing, dust or chemical inhalation or ingestion, skin or bodily exposure to caustic or toxic chemicals, falling objects, cuts, burns, electrical shock, etc.

For example, a safe work procedure indicating hard hat protective headgear equipment in a worksite could read as follows: "The entire project worksite is deemed a potential hazard area. This area will be well defined and marked with prominent warning signs. All personnel entering or working in the project worksite during operations will be required to wear ANSI certified hard hat protective headgear to protect against falling debris from above. A sufficient number of hard hat protective headgear devices will be available for all personnel working in these areas and for those who must occasionally enter these areas."
Protective equipment and/or clothing shall be periodically inspected at regular intervals for wear, defects, and cleanliness and replaced as necessary. Contaminated equipment that cannot be decontaminated should be disposed of in a manner that protects employees from exposure to additional hazards.
Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specifications contained in the ANSI Z98.1-1969 Standard. Helmets for the head protection of employees exposed to high voltage electrical shock and bums shall meet the specifications contained in the ANSI Z89.2-1971 Standards.

Safety shoes and boots should meet the ANSI Z41-1991 Standard to provide both impact and compression protection. Where necessary, safety shoes should be obtained that provide puncture protection also. In some work situations, metatarsal protection should be provided, and in other special situations electrical conductive or insulating safety shoes would be appropriate.

Fire Prevention

All employees are instructed to be continuously aware of fire prevention even though the Company does not engage in activities that present a high fire danger. Smoking by employees will be restricted to designated break areas only.
All flammable liquids will be stored in a storage cabinet that is specifically designed for these products. Flammable liquids should not be used for cleaning if a nonflammable product can be substituted. A sufficient number of fire extinguishers will be available throughout the facility, and will be clearly marked.
Fire extinguishers, exit paths, exit signs, passageways and other means of emergency exit shall be inspected periodically by the Safety Coordinator to insure that they are working properly and unobstructed.

Safety Violations

Violation of safety rules is a serious offense that puts the employee committing the offense in danger, as well as jeopardizing others and the success of the project. Kibi Goldfields will issue a written notice to the employee for violating safety rules. The gravity of the violation will bear heavily on the disciplinary action that is taken. Termination may result from the first offense if it is severe and places the well-being of others in peril; however, the second warning notice will include an automatic suspension from duties pending possible discharge.

Hazard Communication Program

In compliance with OSHA's Hazard Communication Standard, the Safety Coordinator will work in conjunction with project managers to implement and maintain a Hazard Communication Program for all work operations in The Company where employees may be exposed to hazardous substances under normal working conditions or during an emergency. The Hazard Communication Program should consist of compiling a hazardous chemicals list, using MSDS's, ensuring containers are properly labeled and providing employees with training (see 5.0 WORKSITE SAFETY TRAINING), training section below).

MSDS's will be filed in the corresponding part file in the master inventory parts file. The Safety Coordinator should ensure that an MSDS is available on every substance on the list of hazardous chemicals and should be open to review by employees at all times. The purchasing agent should be responsible for obtaining and updating MSDS's.

The Safety Coordinator should make a List of Hazardous Chemicals (see Index of Hazardous Chemicals & MSDS) with the operational areas they are used and the corresponding MSDS for each chemical. The Safety Coordinator will maintain and update the list as necessary and will post a separate list in each work area. The Safety Coordinator will work with each project manager to incorporate protective measures for hazardous chemicals used in their area into their safe work procedures.

The Safety Coordinator will ensure that all hazardous chemicals in the facility are properly labeled and updated, as necessary. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or responsible party.

If there are a number of stationary containers within a worksite that have similar contents and hazards, signs will be posted on them to convey the hazard information. If chemicals are transferred from a labeled container to a portable container that is intended for immediate use, no labels are required on the portable container.

Medical Emergencies

A comprehensive first aid kit should be kept at the entrance of the production area. The purchasing agent should be responsible for replenishing supplies in the kit. Eyewash stations are located within the immediate vicinity of all operational areas that utilize hazardous or caustic chemical substances.

Emergencies or injuries that require medical care but are not life threatening and can be safely transported by automobile should be treated at the local health care facility. The local emergency rescue service should be called for any serious life-threatening injuries, and for transporting injured employees that cannot be safely transported by automobile.

A listing of all emergency phone numbers and the address of the local health care facility should be posted next to the OSHA safety poster in accordance with Federal Posting Requirements.

Worksite Safety Training

Each person must know and understand their job related activities, duties and responsibilities prior to commencement of work. If any worker is in doubt concerning their safety rules or responsibilities, they should contact their respective first line supervisor for clarification before commencing or continuing any work-related activities.

Safety orientation will be conducted for every new and transferred employee. Orientation will consist of written material, a series of videos and a comprehension quiz.

Safety Orientation Checklist will be utilized to ensure a complete training session. Orientation will be done before employees are sent out on site. Subcontractors will be required to provide safety orientation training for their new and transferred employees and provide the Company with documentation proving this has been completed.

Training should include review of this worksite safety policy and procedures. Further, each person should be informed that no employee is expected to undertake a job until he or she has received job instructions on how to do it properly and has been authorized to perform that job and no employee should undertake a job that appears unsafe.

The training plan should also include the Hazard Communication Program, which will emphasize:

• Summary of the Hazard Communication Standard.
• Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods that can be used to detect the presence or release of chemicals.
• Physical hazards of chemicals (e.g., potential for fire, explosion, etc.). • Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
• Procedures to protect against hazards (e.g., personal protective equipment required, proper use, and maintenance; work practices or methods to assure proper use and handling of chemicals; and procedures for emergency response).
• Work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks.
• Where MSDS's are located, how to read and interpret the information on both labels and MSDS's, and how employees may obtain additional hazard information.
• The Safety Coordinator should arrange periodic employee safety meetings with the project managers, as necessary, but no less than once a year. These meetings should include review of any additions, changes or corrections to the worksite safety program and procedures and the hazard communication program. Specific topic only items may also be held (e.g. Fire or natural disaster drills, proper use of fire extinguishers, administering first-aid, etc.) and may include use of outside consultants, speakers, audiovisual aids, etc.

Reporting and Record Keeping

Tall injuries, illnesses and non-injury accidents that require medical attention other than first-aid and is the result of a work accident or from an exposure in the work environment must be reported to the project manager and the Safety Coordinator.

Further, any incident including fire, explosion, water damage, spill, collapse and any similar event that results or could result in significant personal injury or damage to the building and equipment will be reported as above.

For every injury or illness entered on the above log, it is necessary to record additional information on the supplementary record, OSHA Form 301 - Injury and Illness Incident Report - within seven (7) days of a reported incident. As an alternate, if a worker's compensation claim is prepared, this form can be used as a substitute for OSHA Form 301.

Every calendar year, OSHA Form 300A - Summary of Work-Related Injuries and Illnesses - should be prepared by the Safety Coordinator and certified by the President, CFO or a Company Officer before being posted next to the OSHA worksite poster no later than February 1, and will remain posted until March 1 of that year.

The Safety Coordinator should be responsible for maintaining a designated area for filing all of the above records, reports and documentation of the company's worksite safety program. All records and documentation unless otherwise required will be retained for a period of not less than five years.

Confidentiality - Information relating to employee health must be used in a manner that protects the confidentiality of employees as much as possible while the information is being used for OSHA purposes in accordance with Federal and State requirements.

Health and Safety Responsibilities of Key Stakeholders

Chief Executive Officer

The Chief Executive Officer is committed to developing and implementing the Environmental Management System. Resources requirements are reviewed to ensure that adequate resources are provided to plan, do, check and act for continually improving its effectiveness General Manager is responsible for:
• endorsing the health and safety policy
• ensuring appropriate resource allocation to enable the effective operation and continual improvement of the company’s health and safety system

Enterprise Risk Management
The Enterprise Risk Management will have the responsibility and authority for:
• Ensuring that Health and Safety requirements are established, implemented and maintained in accordance with the Labour Act, 2003 and the Factories, Offices and Shops Act, 1970 including the following tasks;
• Ensuring that sufficient resources are allocated for the proper implementation of the health and safety policy
• Regularly reviewing the policy and ensuring that the necessary changes are made.
• Coordinating internal Health and Safety audits to ensure the Health and Safety Systems are being properly implemented and maintained;
• Handling and investigating nonconformity and ensuring corrective and preventive action are taken to mitigate any impacts caused;
• Reporting on the performance of the Health and Safety System implemented to the General Manager for review and as a basis for improvement of the system.

Health and Safety Committee (HS Committee)

This committee is responsible for:
• the establishment and implementation of the Health and Safety Systems;
• the establishment and review of objectives, targets, and programs;
• ensuring the effective implementation of health and safety related operational controls and programs;
• the internal communication of health matters between management and employees;
• the review of complaint records, nonconformity, corrective action and preventive action reports and the adoption of preventive actions as necessary;
• providing leadership in the pursuit of health issues;
• any other EMS activities that are assigned by the Enterprise Risk Management
• The Committee comprises of the Environmental Health and Safety Officer, compliance Officer and selected members from the Technical Office

Management Review Committee

The Committee systematically examines the Health and Safety System implemented to ensure the suitability, adequacy and effectiveness. The Committee comprises of the Chief Executive Officer, Enterprise Risk Manager, Human Resource Manager and Chief Finance Officer.

Human Resource Manager (HRM)
The Human Resource Manager shall consolidate the training needs and prepare an annual training plan for all employees. The HRM shall also arrange or coordinate training and keep training records accordingly.

All Employees

All employees are responsible for:
• Working in accordance with the documented health and safety procedures and instructions, and with specific responsibilities as defined in individual procedures and instructions;
• Reporting problems or deviations associated with health and safety issues to the HR Committee.

Health and Safety Responsibilities of Key Stakeholders

Board of Directors

Senior Management

Compliance Officer and Money Laundering Reporting Officer

Compliance and Audit Function

Money Laundering Reporting Officer (MLRO)

Record Keeping

Continuous Monitoring

How to Raise a Concern

Environmental Sustainability Policy

Introduction

Purpose of this Policy

This Policy defines the Environmental Management System (EMS) of Kibi Goldfields Company Limited’s activities and contains:
• The Environmental Policy;
• Statements of responsibility and authority;
• An overview of the company’s environmental procedures and controls;
• The identification of the resources and training allocated to management, performance of work and verification activities including internal audit;
• The appointment of the Environmental Management Representative (EMR);
• The arrangement for periodic management reviews.

The purpose of this Manual is to demonstrate that this EMS meets all ISO14001:2015 requirements and provides guidance and direction for the implementation and operation of the EMS to all personnel including all relevant documents.
• Scope of Environmental Management Systems (EMS)
The scope of the EMS applies to the Design, Construction and Management of all Civil Engineering Projects related to all operations by Kibi Goldfields Company Limited.

Terms and Definitions

“Auditor”: Person with the competence to conduct an audit.
“Continual improvement”: Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with the organization’s environmental policy.
“Corrective action”: Action to eliminate the cause of a detected nonconformity.
“Document”: Information and its supporting media.
“Environment”: Surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation.
“Environmental aspect (EA)”: Elements of an organization’s activities or products or services that can interact with the environment.
“Environmental impact”: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s environmental aspects.
“Environmental management system (EMS)”: Part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects.
“Environmental objective”: Overall environmental goal, consistent with the environmental policy, which an organization sets itself to achieve.
“Environmental performance”: Measurable results of an organization’s management of its environmental aspects.
“Environmental policy”: Overall intentions and directions of an organization related to its environmental performance as formally expressed by top management.
“Environmental target”: Detailed performance requirement applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.
“Interested party”: Person or group concerned with or affected by the environmental performance of an organization.
“Internal audit”: Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organization are fulfilled.
“Nonconformity”: Non-fulfilment of a requirement.
“Organization”: Kibi Goldfields Company Limited (Kibi Goldfields).
“Preventive action”: Action to eliminate the cause of a potential nonconformity.
Prevention of Use of processes, practices, techniques, materials, products, pollution services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutants or waste, in order to reduce adverse environmental impacts.
“Procedure”: Specified way to carry out an activity or a process.
“Record”: Document stating results achieved or providing evidence of activities performed.

Policy

Kibi Goldfields Limited (Kibi Goldfields) undertakes the design, construction, and management of civil engineering works in both public and private sectors.
Protecting the environment is the responsibility of everyone in the organization. Kibi Goldfields is committed to sustainable construction and minimize any adverse impact on the environment resulting from our business activities.

Kibi Goldfields is committed to applying the principles of sustainability to strategic decision making and work activities.

To achieve our goal Kibi Goldfields is committed to:

• The integration of environmental management and sustainability into all our activities through ISO 14001:2015 accredited Environmental Management System
• Providing adequate resources to implement and maintain this policy
• Developing, implementing and maintaining a practical Construction Environmental Management Plan for each project;
• Ensuring the prevention of pollution and the protection of sensitive environments, fauna and flora;
• Developing a shared sense of responsibility for sustainability and environmental management from top management through to employees, suppliers and sub-contractors;
• Promoting awareness and commitment to environmental management and sustainability amongst employees, suppliers and sub-contractors;
• Identifying alternative, financially viable and sustainable courses of action to minimize environmental impacts from our activities
• Minimizing construction related impacts on the surrounding environment and community, including those related to: dust, fire, hazardous materials, noise and vibration, surface and groundwater quality, land contamination and the preservation of Aboriginal heritage;
• Minimizing waste and the appropriate management of waste materials
• Implementing and reviewing environmental objectives and targets to ensure compliance with our environmental commitments and achieve continuous improvement in our environmental performance. Focus on prevention of pollution, waste minimization and resource conservation as critical considerations within our core management processes.
• Compliance with applicable legal requirements and other requirements to which the Company subscribes which relate to its environmental aspects.
• Continual improvement.

All staff will follow the requirements of the Environmental Management System in the performance of their tasks and will ensure this policy is supported and maintained. This policy will be communicated to our clients, suppliers, and subcontractors. It will also be made available to the public whenever requested.

Environmental Sustainability

Responsibility of Key Stakeholders

Chief Executive Officer

The Enterprise Risk Manager is the appointed EMR and has the responsibility and authority for:

• Ensuring that EMS requirements are established, implemented and maintained in accordance with the ISO 14001 standard, including the following tasks;
• to control and issue all EMS documentation;
• to ensure the promotion of awareness of customer requirement and environmental awareness throughout Kibi Goldfields;
• to receive staff suggestions for improvements or additions to the EMS and taking the necessary action to implement them where they are beneficial;
• to keep staff informed of developments in the EMS.
• Ensuring that sufficient resources are allocated for the proper implementation of the environmental policy and the EMS.
• Regularly reviewing the policy and the effectiveness of the EMS and ensuring that the necessary changes are made.

EMR is also the Chairman of the EMS Committee and has the responsibility and authority for:

• Leading the EMS Committee to establish and implement the EMS according to ISO 14001 standard, and monitoring the performance of the EMS; • Coordinating internal EMS audits to ensure the EMS has been properly implemented and maintained;
• Handling and investigating nonconformity and ensuring corrective and preventive action has been taken to mitigate any impacts caused; • Reporting on the performance of the EMS to the top management for review and as a basis for improvement of the EMS.

The EMR, the EMS Committee and Chief Executive shall undertake the EMS management review annually to ensure top management’s commitment and integration of the EMS with business strategies for its implementation and continual improvement.

• Environmental Management System Committee (EMS Committee)
This committee is responsible for:
• The establishment and implementation of the EMS;
• The establishment and review of objectives, targets, and programs;
• Ensuring the effective implementation of environmentally-related operational controls and programs;
• The internal communication of environmental matters between management and employees; and promoting environmental awareness among company staff;
• The review of complaint records, nonconformity, corrective action and preventive action. Reports and the adoption of preventive actions as necessary;
• Providing leadership in the pursuit of environmental issues;
• Any other EMS activities that are assigned by the EMR;
• Holding regular meeting (every 3 months).
• The Committee comprises of the Environmental Health and Safety Officer, compliance Officer and selected members from the Technical Office.

Management Review Committee

The Committee systematically examines the EMS to ensure the suitability, adequacy and effectiveness of the EMS. The Committee comprises of the Chief Executive Officer, Enterprise Risk Manager, Human Resource Manager and Chief Finance Officer.

Project Manager

Project Manager is responsible to plan, organize, co-ordinate and control individual project activities, the responsibilities related to EMS include:
• Assisting the Environmental Health and Safety Manager in the pre-contract review;
• Reviewing the project and formulates the detailed contract program;
• Implementing contracts through the co-ordination and instruction of site and office based staff;
• Resolving problems encountered during the contract (e.g. Any environmental issue) and refer to the Environmental Health and Safety Manager if necessary;
• Liaising with all other managers in order that the contract can be completed in accordance with the specified requirements and within the program;
• To be accountable for the Technical Services and environmental management;
• Controlling overall cost of the projects;
• To foster good client relationships;
• Promoting and develop the company image at all times;
• To keep up to date with all-new business related developments, new statutory requirements and implements them accordingly.
• To evaluate the performance of the suppliers and sub-contractors.
• To handle client complaints (e.g. Any environmental issue).

Human Resource Manager

The Human Resource Manager shall consolidate the training needs and prepare an annual training plan for all employees. The HRM shall also arrange or coordinate training and keep training records accordingly.

All Employees

All employees are responsible for:
• Working in accordance with the documented environmental procedures and instructions, and specific responsibilities are defined in individual procedures and instructions;
• Reporting problems or deviations associated with environmental issues and the EMS to the EMS Committee.

Environmental Management System Requirements

The EMS of Kibi Goldfields is developed to manage significant environmental aspects so as to limit their impacts on the environment. The EMS is established in accordance with ISO 14001 requirements and is described in this section. Procedures for each component is given in the relevant Environmental Procedures (EPs) listed in Appendix A.

Environmental Management System Documents
The purposes of these EMS documents are as follows:

Environmental Policy

Describes the intention and principles to be adopted in relation to environmental performance, including but not limited to legal compliance, continual improvements and pollution prevention.

Environmental Systems

Describes the environmental management system and Management System outlines how the requirements of the International Manual (EMS Manual) Standard (ISO 14001) are achieved. A cross-reference of the ISO 14001 clauses to the sections of this Manual is listed in Appendix A.

Objective(s) *

The overall environmental goals that Kibi Goldfields set to achieve.
Target(s) *
The set of measurable performance requirements that Kibi Goldfields establishes to achieve the objectives.

Program(s) *

The program and schedule which Kibi Goldfields implements to achieve the objectives and targets.

Environmental Procedures (EPs)
Define the roles, responsibilities, and actions to be taken to ensure that activities are performed and the EMS implemented in accordance with the environmental policy and the requirements of ISO 14001. A cross-reference of the ISO 14001 clauses to the EPs is listed in Appendix A.

Register of Environmental Aspects

Compiles the environmental aspects that are derived from the activities and services of Kibi Goldfields. The register also denotes the significance of the environmental aspects and the respective operational controls for significant environmental aspects.

Register of Legal and Other requirements
Compiles the legal and other requirements, which include legislation, codes of practice, regulatory and non-regulatory guidelines that are applicable to Kibi Goldfields.

Environmental

Instructions (EIs)
Describe which and how activities should be performed to manage significant environmental aspects and to achieve the EMS ISO 14001 requirements.

Environmental Forms/Records
Record information for the audit trail and the assessment of environmental conditions and performance.
* Objectives and Targets, and associated Programs are provided as a single document.

Environmental Policy

(ISO 14001 Standard Clause 4.2)
The environmental policy of Kibi Goldfields is included in Section 2 of this document. It outlines the environmental commitments of Kibi Goldfields with respect to its operations, activities, and overall environmental performance. During the development of this policy, the appropriateness to the nature, scale and environmental impacts of Kibi Goldfields’s activities, products and services has been considered. The policy is endorsed by the General Manager and the policy shall be reviewed during the management review meeting.
The policy shall stipulate the commitments of Kibi Goldfields to continually improve its environmental management and prevention of pollution. Kibi Goldfields is also committed to comply with applicable legal requirements and other requirements to which Kibi Goldfields subscribes which relate to its environmental aspects. The environmental policy shall provide a framework for setting and reviewing objectives and targets, and must be maintained, implemented and communicated to all employees of Kibi Goldfields and its contractors. This policy shall be available to the public.

Planning

Kibi Goldfields shall follow a “plan-do-check-act” process to facilitate continual environmental performance improvements. The planning process includes the identification and updating of Kibi Goldfields’s Register of Environmental Aspects, and the Register of Legal and Other Requirements. Together with Kibi Goldfields’s environmental policy, Kibi Goldfields’s objectives and targets are established, and appropriate programs are formulated to achieve the objectives and targets.

Environmental Aspects

(ISO 14001 Standard Clause 4.3.1) The planning process commences with the identification and updating of environmental aspects. In order to evaluate the impacts of its activities to the environment, Kibi Goldfields shall establish, implement and maintain a procedure to identify the environmental aspects of its activities, products or services that it can control and those it can influence taking into account planned or new developments, or new or modified activities, products and services. These aspects, inclusive of those arising from works carried out by contractors, are registered in the "Register of Environmental Aspects".

Kibi Goldfields shall ensure that all environmental aspects that may pose significant impacts to the environment are under control and prioritized for improvements.

Kibi Goldfields shall keep this information up-to-date.
Relevant procedure: EP-01 Identification of Environmental Aspects and Significance Evaluation.

Legal and Other Requirements

(ISO 14001 Standard Clause 4.3.2)
Kibi Goldfields shall establish, implement and maintain a procedure to identify and maintain access to legal requirements that are relevant to the company, as well as other requirements that the company subscribes to which relates to the company’s environmental aspects. Kibi Goldfields shall identify all relevant regulations, codes of practice and guidelines that are applicable to the environmental aspects of its activities, products and services, and record this information in the Register of Legal and Other Requirements. Kibi Goldfields shall keep this information up-to-date. Relevant procedure: EP-02 Review of Legal and Other Requirements.

Objectives, Targets and Program(s)

(ISO 14001 Standard Clause 4.3.3)
Based on the environmental policy and significant environmental aspects, environmental objectives and targets shall be established, implemented and maintained at each function and level within Kibi Goldfields. Programs are established, implemented and maintained for achieving its objectives and targets.

When establishing and reviewing its objectives, Kibi Goldfields shall take into consideration the legal and other requirements, significant environmental aspects, technological options, financial/operational/business requirements, and views of interested parties, and ensure that the objectives and targets are consistent with the environmental policy, including commitment to pollution prevention, to compliance with applicable legal requirements and other requirements, and to continual improvement.
The programs designate the responsibility for achieving objectives and targets at each function and level of the company, together with the means and time frame by which they are to be achieved.
The General Manager shall approve the objectives, targets and programs proposed by the EMS Committee before implementation. The EMR shall ensure that the objectives
and targets are measurable if possible, and that the progress towards achieving the objectives and targets is continually monitored and reviewed. The achievement of objectives, targets and programs shall be reviewed by the EMS Committee every 3 months. The EMR shall lead the EMS Committee in revising the objectives, targets and programs as necessary.
Kibi Goldfields shall ensure that the programs are amended as appropriate for new projects and new or modified activities, products or services in order to ensure that environmental management applies to such projects and activities.
In the event that objectives and targets in the programs are not met, the EMR shall revise the program as necessary and maintain documented evidence / records for the actions taken to mitigate the problems.

The EMR shall also maintain obsolete objectives, targets and programs as an EMS record for three years.

Implementation and Operation

The implementation of the EMS requires Kibi Goldfields to clearly define roles, responsibilities and authorities of key personnel, commit to staff training, maintain effective communication channels, adopt effective document and operational controls, and maintain sufficient awareness on emergency preparedness among the staff.

Resources, Roles, Responsibility and Authority
(ISO 14001 Standard Clause 4.4.1)
Top management of Kibi Goldfields shall commit to provide resources (including human resources and specialized skills, organizational infrastructure, technological and financial resources) essential to the implementation and control of the EMS. The roles, responsibilities and authorities of key personnel shall be defined, documented, and communicated in order to facilitate effective environmental management. Kibi Goldfields has appointed the Environmental Manager as the Environmental Management Representative (EMR), and the Finance & Administration Manager as the Deputy Environmental Management Representative (DEMR) for the implementation and maintenance of the EMS. Their EMS responsibilities are described in section 3 of this manual.

Competence, Training and Awareness

(ISO 14001 Standard Clause 4.4.2)
Kibi Goldfields shall ensure all persons performing tasks for it or on its behalf, whose work may have a significant impact on the environment, are competent on the basis of appropriate education, training and/or experience, and shall retain associated records.
Kibi Goldfields will ensure that all people performing tasks for or on behalf of the organization, which includes contractors, sub-contractors, temporary staff and remote workers, have had an appropriate assessment for their potential to cause a significant environmental impact and the associated competence required.

Kibi Goldfields shall establish, implement and maintain procedures to identify the training needs associated with its environmental aspects and its EMS, and develop programs to ensure awareness and competence, at each relevant function and level, by addressing:
• The roles and responsibilities in achieving conformity with the environmental management system;
• The importance of conformity with the environmental policy, the procedures and the requirements of the structured ems;
• The significant environmental aspects and related actual or potential impacts associated from their work activities and the environmental benefits of improved personal performance;
• The potential consequences of departure from specified operating procedures; relevant procedure : ep-03 training.

Communication

(ISO 14001 Standard Clause 4.4.3)
For internal communication, the EMR shall ensure information regarding the EMS (such as the policy, objectives, targets and programs) and environmental performance is readily available to employees on notice board, or is published on the intranet or newsletters. Employees with enquiries / complaints regarding to the EMS and/or environmental issues of Kibi Goldfields shall inform their Project Manager / Function / Departmental Manager. The designated member of EMS Committee representing each division shall maintain a log for the relevant enquiries / complaints. Depending on the nature and scope of the enquiry / complaint, the EMR shall determine the corresponding action and maintain relevant records to demonstrate the response / corrective actions taken.
For external communication, the environmental policy is available at the office. All internal and external enquiries / complaints / communications shall be discussed and reviewed during the EMS Committee meeting and the decision shall be recorded on meeting minutes.
The EMS Committee may discuss and decide whether to communicate externally about its significant environmental aspects, the decision shall be documented in the meeting minutes. If the decision is to communicate, the EMS Committee shall establish and implement a method(s) for this external communication, e.g. publish environmental report.
Relevant procedure: EP-07 Enquiry / Complaint / Nonconformity Handling.

Documentation

(ISO 14001 Standard Clause 4.4.4)
The Environmental Management System documentation encompasses four levels as described below: The first level is the Environmental Management System Manual (this document) which includes Kibi Goldfields’s environmental policy (specifying the principal objectives and environmental commitments of Kibi Goldfields), and a broad description of how Kibi Goldfields addresses the ISO 14001 requirements. The EMS Manual serves as an interface to interpret the relationship between Kibi Goldfields’s EMS and the ISO 14001 Standard. An individual document of Objectives, Targets and Programs is developed based on the company’s environmental policy. It demonstrates the company’s commitment on continual improvement in environmental performance.

The second level is the Environmental Procedures (EPs), which include all procedures that Kibi Goldfields shall follow as specified in the ISO 14001 Standard. These procedures provide a detailed description of the EMS elements and define who should do what, how and when. Appendix A shows the relationship between various environmental procedures and the ISO 14001 Standard clauses. Register of Environmental Aspects, and Register of Legal and Other Requirements are derived from the procedures and act as the foundation of the EMS which the company subscribed to.

The third level is the Environmental Instructions (EIs), which are operational control procedures or instructions, with defined responsibilities, to control the identified significant environmental aspects associated with Kibi Goldfields’s operations and activities.

The fourth level is Environmental Records which arise from the implementation of the Environmental Management System Manual, Environmental Procedures and Environmental Instructions. Environmental Records include various checklists, reports and meeting records, etc., as defined in each Environmental Procedure and Environmental Instruction.

Control of Documents

(ISO 14001 Standard Clause 4.4.5)
The essences of EMS documentation controls are:
• They shall be reviewed, revised as necessary and approved for adequacy by authorized personnel; • That current version of relevant documents shall be available at all locations where operations essential to the effective functioning of the environmental management system are performed;
• That documents of external origin determined by the organization to be necessary for the planning and operation of the ems are identified and their distribution controlled;
• Obsolete documents shall be promptly removed from all points of issue and use, or are otherwise assured against unintended use; and • Any obsolete documents retained for legal and / or knowledge preservation purposes shall be suitably identified.

Kibi Goldfields shall ensure that documentation is legible, dated (with dates of revision) and readily identifiable, maintained in an orderly manner, and retained for a specified period. Kibi Goldfields shall establish, implement and maintain a procedure for the creation and modification of the various types of documents and the respective responsibilities for such creation and modifications.
Relevant procedure: EP-04 Control of Documents.

Operational Control

(ISO 14001 Standard Clause 4.4.6)
Kibi Goldfields shall establish, implement and maintain operation control procedures to manage its significant environmental aspects. Kibi Goldfields shall ensure that all operations and activities, carried out by Kibi Goldfields’s employee or contractors that are associated with the significant aspects are properly controlled, and that appropriate operational control procedures, in terms of Environmental Procedures (EPs) and Environmental Instructions (EIs), are communicated to personnel whose tasks may result in significant environmental aspects. Kibi Goldfields shall influence its staff and contractors by communicating its environmental policy and other relevant EPs and/or EIs to them. Relevant procedure: EI-01 to 08

Emergency Preparedness and Response

(ISO 14001 Standard Clause 4.4.7)
Kibi Goldfields shall establish, implement and maintain a procedure to identify potential emergency situations and responses to such situations in order to prevent and/or mitigate environmental impacts that may associate with them.
Kibi Goldfields shall review and revise its emergency preparedness and response procedures, in particular after the occurrence of accidents or emergency situations.
Kibi Goldfields shall also periodically test the procedure and the preparedness where practicable.
Relevant procedure: EP-05 Environmental Emergency Preparedness and Response

Checking

While implementing the EMS, Kibi Goldfields shall monitor and measure the key characteristics of its operations and activities on a regular basis. These results shall be recorded together with nonconformity and the corrective action and preventive action. As part of the checking process, a periodic audit on the EMS shall provide a basis for management review.

Monitoring and Measurement

(ISO 14001 Standard Clause 4.5.1)
Kibi Goldfields shall establish, implement and maintain procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that have significant impacts on the environment. This shall include procedures for tracking of performance, applicable operational controls and conformity with the company’s objectives and targets, as well as the calibration and maintenance of monitoring equipment. The information of environmental monitoring shall be documenting. Relevant procedure: EP-06 Environmental Monitoring and Evaluation of Compliance

Evaluation of Compliance

(ISO 14001 Standard Clause 4.5.2)
To meet the company’s commitment to compliance, Kibi Goldfields shall regularly monitor and evaluate the compliance status of the applicable environmental legal requirements (section 4.5.2.1) and other requirements (section 4.5.2.2) that the company subscribes to. The records of the results of the periodic evaluations shall be retained. Relevant procedure: EP-06 Environmental Monitoring and Evaluation of Compliance

Nonconformity, Corrective Action and Preventive Action

(ISO 14001 Standard Clause 4.5.3)

Continual improvement of the EMS can be achieved by identifying nonconformity, correcting nonconformity and preventing nonconformity from occurring again. Regarding non-conformity and its subsequent corrective / preventive action, Kibi Goldfields shall establish, implement and maintain a procedure which defines the responsibilities and authorities to:
• Handle and investigate nonconformity;
• Take action to mitigate the impacts caused;
• Initiate and complete corrective and preventive actions;
• Ensure that the corrective or preventive actions taken to eliminate the causes of actual and potential nonconformity are appropriate to the magnitude of problems and commensurate with the environmental impacts encountered;
• record the results of corrective and prevention actions taken;
• Review the effectiveness of corrective action and preventive action taken;
• Implement and record any changes in the documented procedures resulting from corrective and preventive action.
Kibi Goldfields shall also ensure that any necessary changes are made to environmental management documentation.
Relevant procedure: EP-07 Enquiry / Complaint / Nonconformity Handling

Controls of Records

(ISO 14001 Standard Clause 4.5.4)
Records shall be maintained to keep track of Kibi Goldfields’s environmental performance, to demonstrate conformity to the requirements of the EMS, legal compliance, and to maintain audit trails in accordance with the requirements of ISO 14001 Standard, and the results achieved.
Kibi Goldfields shall establish, implement and maintain a procedure to denote the identification, storage, protection, retrieval, retention and disposition of environmental records, to ensure that such records are legible, identifiable, and traceable to the activity, product or service involved, and that they are stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration or loss. The retention period of each type of environmental records shall be specified. Relevant procedure: EP-08 Control of Records

Internal Audit

(ISO 14001 Standard Clause 4.5.5)
Kibi Goldfields shall plan, establish, implement and maintain a program and procedures to carry out periodic environmental management system audits to:
• Determine whether or not the environmental management system:
• conforms to planned arrangements for environmental management including the requirements of ISO 14001;
• has been properly implemented and maintained;
• Provide audit results and information for management review for environmental improvement.

The audit program, including the schedule, shall be based on the environmental importance of the activities concerned and results from previous audits. The audit procedures cover the audit criteria, scope, frequency and methods, as well as responsibilities and requirements for conducting audits and reporting results and retaining associated records.

Kibi Goldfields shall conduct EMS audits on a regular basis. Timely site environmental audits are required to ensure appropriate preventive actions being taken as planned, and corrective actions being carried out on a timely basis. Relevant procedure: EP-09 Internal Audit

Management Review

(ISO 14001 Standard Clause 4.6)
The “plan-do-check-act” cycle shall require the top management of Kibi Goldfields to act and review the environmental management system periodically to ensure its suitability, adequacy and effectiveness.

Before the Review, the EMR shall schedule for the management review and inform all the participants, and gather all relevant records/requirements (such as change in legal requirements) and prepare a summary report (if necessary) for discussion. The General Manager, EMR and DEMR together with the EMS Committee shall take part in the annual management review. They shall assess the work done in the past year in environmental management and evaluate the existing EMS with respect to changes in legislation, concerns of interested parties, business activities, technology and product requirements, and lessons gained from previous experience, etc. Topics to be discussed in the management review shall include but not be limited to:
• Review of the environmental policy, objectives, targets, and programs;
• Review of legal compliance and compliance with other requirements (including contractor compliance on Kibi Goldfields’s activities);
• Environmental aspects of activities and their disclosure to public;
• Findings of the internal audits;
• Review of nonconformities and the status of corrective/preventive actions;
• Areas for improvement with respect to environmental performance;
• adequacy of emergency preparedness and response;
• changing circumstances, including developments in legal and other requirements related to its environmental aspects, • identify the need for modification of the existing EMS in light of the above items,
• follow-up action from previous management reviews.

The review shall initiate a new “plan-do-check-act” cycle with improvements in Kibi Goldfields’s environmental performance and further enhancement of the EMS.

The review shall initiate a new “plan-do-check-act” cycle with improvements in Kibi Goldfields’s environmental performance and further enhancement of the EMS.

Findings from the management review shall be recorded in the meeting minutes and the EMR shall retain it as an EMS record. Maintenance of the records shall be in accordance with EP-08.