Ethics and integrity

Our Information Technology team has adopted a risk-based security approach using the Australian Government’s Australian Signals Directorate Top 37 security framework.

The measures we have in place to protect our business against cybersecurity risks include:

• A security plan which sets out the policies and operational guidelines for a proactive defensive security environment.
• Active monitoring and blocking of malicious external and internal attacks.
• Regular cybersecurity risk assessments to ensure new technology is appraised for security risks before implementation.
• Encryption of laptops and mobile devices to ensure that information is inaccessible when these devices are lost or stolen.
• Disaster recovery plans.
• Incident response plans and playbooks.

We are committed to ensuring that our supply chains are managed in accordance with all regulatory requirements and ethical responsibilities.

Key aspects of our sanctions framework include:

• Due diligence processes to identify and assess sanctions risk, with enhanced due diligence protocols applied in incidences where a higher sanctions risk is identified.
• Initial, ongoing, and ad hoc sanctions screening is conducted with all suppliers.
• Commitment to exercise due care in any transaction with an individual or entity that is owned or controlled by, or acting on behalf of, persons or entities that are ‘designated’ under sanctions laws.

We are committed to ensuring security management at all operations is conducted in line with the protection of human rights while protecting employees, contractors, equipment and facilities.

To decrease risk at all our operations, we contract private security providers and ensure they operate consistently with the Voluntary Principles on Security and Human Rights (VPSHR).

The VPSHR guides providers to uphold human rights, protect the safety and dignity of individuals, and maintain responsible security practices.

Our Code of Conduct and Business Integrity defines the way we do business, which is based on our values and represents our commitment to upholding the highest standards of ethics in our business practices.

This key business document outlines our expectation that all employees and contractors behave with fairness, honesty and respect towards others.

Prior to commencing employment with us, all employees are required to complete training on the Code, as well as undertake refresher training each year to ensure they understand their requirements.

The Code covers a range of aspects including our values, unacceptable behaviours, how we work with communities, consequences for breaching the Code and where employees can seek assistance.

We prohibit any form of punishment, disciplinary or retaliatory action against anyone for raising or helping to address a business conduct concern.

Failure to comply with the Code is a serious matter that may lead to disciplinary action, including dismissal and/or legal action. Information provided is de-identified and provides complainant type, detail, actions and resolutions.

Refer to our Code of Conduct and Business Integrity for further information.

Our stance is that any form of harassment, assault or bullying is completely unacceptable and has no place in any setting, including our workplace.

Our senior leadership team is focused on:

• Ensuring strong leadership, governance and education on safe and respectful workplace behaviour.
• Promoting positive workplace relationships that are built on respect.
• Creating a culture and work environment that supports people from all backgrounds and life experiences.
• Listening to and learning from the experiences of our people.

We expect all our people to:

• Treat each other with respect and ensure their behaviours are aligned with our values.
• Show up for their colleagues, stand up to unacceptable behaviour, speak up to address situations and, if required, listen to and learn from the experiences of others.

Our Whistleblower Policy and its supporting Whistleblower Procedure outlines various ways stakeholders can report matters they genuinely believe are in breach of the Code or are illegal.

To better ensure whistleblowers feel safe to come forward, individuals qualify for protection even if their disclosure turns out to be incorrect or if they make the disclosure anonymously.

Reportable conduct may include any conduct that involves:

• Actions that are dishonest, fraudulent or corrupt, including bribery or other activity in breach of the bribery and corruption provisions of the Code.
• Illegal activity such as theft, violence, harassment or intimidation, criminal damage to property or other breaches of State or Federal law.
• Unethical behaviour or behaviour in breach of our policies, such as dishonestly altering company records or data, adopting questionable accounting practices or willfully breaching the Code or other Company policies or procedures.
• Potential damage to stakeholders such as unsafe work practices, environmental damage, health risks or abuse of our property or resources.
• Abuse of authority or conflict of interest.
• Financial loss to us, damage to our reputation or any other issue that may be detrimental to our interests.
• Sexual harassment, harassment, coercion, discrimination, victimisation or bullying.
• Any other kind of misconduct, observation or perception of an issue that may impact us in any of the areas outlined above.
• Engaging in or threatening to engage in detrimental conduct against a whistleblower.

We ensure continued accessibility to our independent external whistleblowing service, MinRes Integrity Assist, which is widely communicated to employees and contractors.

We also maintain a secondary internal reporting mechanism, allowing employees to raise and seek resolution to disputes or grievances.

Through this mechanism, reports are subject to internal investigations, with the aim of achieving appropriate and fair resolutions.

Refer to our Whistleblower Policy and Whistleblower Procedure for further information.

Bribery and corruption adversely affect the business environment by undermining legitimate business activities.

As part of our commitment to operating ethically and with integrity in all business activities and stakeholder relationships, we have an Anti-Bribery and Corruption Policy.

This policy outlines our expectations in not tolerating bribery or corruption, or any actions that constitute fraud, and encourages employees to speak up and report any concerns internally and/or externally, including through our external whistleblower hotline, MinRes Integrity Assist.

Refer to our Anti-Bribery and Corruption Policy for more information.

We seek to build mutually beneficial relationships and respect the rights of our employees, contractors, members of our local communities and other stakeholders directly impacted by our operations.

We prohibit the use of forced labour which includes child labour, slave labour and human trafficking.

Our Human Rights Policy outlines our commitment and joint responsibility to ensure our business activities respect the rights and dignity of all people.

All employees, contractors, suppliers and other relevant stakeholders are required to comply with the principles outlined in this policy and are encouraged to report any breaches through our internal and external whistleblower mechanisms.

Refer to our Human Rights Policy for more information.