SUPPLIER & PARTNER CODE OF CONDUCT

THIS CODE OF CONDUCT SETS FORTH TEGAGOLD INC. INCLUDING EACH OF ITS DIVISION, BUSINESS UNITS, AFFILIATES AND SUBSIDIARIES OUR FUNDAMENTAL ETHICS AND BUSINESS CONDUCT REQUIRED FOR OUR SUPPLIERS

TegaGold Inc., including each of its divisions, business units, affiliates and subsidiaries((TGR) is firmly committed to and promotes the highest standards of ethics and business conduct wherever TegaGold and its affiliates operate. Our Supplier and partner code of conduct may be amended from time to time and outlines TegaGold Resources (TGR) expectations and guidelines with respect to responsible sourcing, including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain.

We require all Suppliers and Partners acting on TGR’s behalf and/or providing goods or services to TGR for compensation to comply with this Supplier and Partner Code of Conduct. This includes, but is not limited to, our direct and indirect Suppliers, External Manufacturing Partners and co-packers, labor providers, Miners, logistic providers, subsidiary or affiliate entities. Sub-Contractors of Suppliers are also expected to adhere to the Supplier and Partner Code of Conduct.

We expect our Suppliers and business partners to comply with and communicate these expectations throughout their supply chain – including their own suppliers and partners – by adopting efficient management systems, policies, procedures and training to uphold the standards and expectations set forth in this Supplier & Partner Code within their own business operations.

We require our Suppliers to abide by all applicable national, state and local laws/regulations in the markets where they operate; however, where local laws or standards differ from this Supplier & Partner Code of Conduct, we expect our Suppliers to comply with the most stringent standards and principles.

In the spirit of continuous improvement, TGR is committed to working with and supporting our Suppliers and Partners meet, and when possible, exceed, the requirements in this Code. By its acceptance of any purchase order from TGR, the Supplier or Partner acknowledges its acceptance of the Supplier & Partner Code of conduct and intention to comply with its requirements.

SCOPE

Our Supplier & Partner Code of Conduct, outlines  TegaGold’s expectations and guidelines with respect to responsible sourcing, including our commitments to human rights, the environment, health and safety, business ethics and the development of a diverse and sustainable supply chain.

WHY DO WE HAVE A SUPPLIER AND PARTNER CODE OF CONDUCT?

What makes TegaGold a trusted company is not only because we deliver and support our clients in the best way possible but also because of the trust we have built with our business partners and stakeholders. This trust is maintained by the integrity of our everyday actions, doing things the right way. Our suppliers and partners are an integral part of our ecosystem and success and help us build and maintain our reputation. Therefore, it is essential for us that all the Suppliers & Partners involved with TegaGold commit to and uphold the highest standards of ethics and integrity, values, and operating principles.

Our Supplier & Partner Code of Conduct contains several overarching principles to guide our suppliers and partners to operate and perform in the right way. We expect from our Suppliers and Partners that they use all these important principles to guide their decisions as they do business. They enable us to achieve mutual success in the right way.

OUR GUIDING PRINCIPLES

  1. Market Responsibly

  2. Treat People and Animals Fairly

  3. Make Food That is Safe to Eat

  4. Deal Honestly with the Government

  5. Keep Accurate Books and Business Records

  6. Embrace Social and Environmental Responsibility

  7. Compete Fairly and Conduct Business with Integrity 

  8. Protect and Respect Private and Proprietary Information

  9. Comply with applicable law, regulations, pledges and TegaGold’s Policies

  1. MARKET RESPONSIBLY

We expect our suppliers and partners to:

  • Not engage in misleading marketing

  • Have clear guardrails that their claims are substantiated

2. TREAT PEOPLE AND ANIMALS FAIRLY

We expect our suppliers and partners to :

  • Follow the TegaGold’s Human Rights Policy

  • Provide safe and healthy working conditions at all their operations

  • Meet or exceed all legal requirements for compensation and working conditions

  • Respect employees’ rights to organize and bargain collectively, as well as raise concerns without fear of retaliation

  • Never use or tolerate the use of human trafficking, forced labor, or child labor as defined by the International Labor Organization (ILO)

  • Foster an inclusive and ethical work environment that is free of harassment and discrimination and provides equal chances of success to all their employees

  • For Suppliers of ingredients that come from farm animals, be aware and comply with all applicable national laws on animal welfare and, where legislation does not exist, the guidelines of the World Organization for Animal Health (OIE).

3. MAKE HIGH QUALITY FOOD THAT IS SAFE TO EAT

We expect our suppliers and partners to:

  • Abide by the requirements listed in the recognized international standards, such as https://www.fairtrade.net/standard/fairtrade-standards

  • Meet or exceed the agreed specifications to grant committed quality to our customers.

  • Report to TegaGold in a complete, accurate and timely manner any concern about their product safety or quality

  • Follow the highest standard of food manufacturing, storage, packaging and transportation to guarantee our products and consumers’ safety.

  • Refer to the necessary accredited guidelines that ensure food safety as well as undergo the necessary inspections by approved and accredited agencies to ascertain and confirm conformity to the goods and products traded with TGR.

4. DEAL HONESTLY WITH THE GOVERNMENT

We expect our suppliers and partners to:

  • Prohibit all types of bribery, corruption, lies and money laundering

  • Forbid gifts to private or public officials that aim at influencing business decisions

  • Comply with all anti corruption laws and regulations that govern operations in the countries in which they do business.

5. KEEP ACCURATE BOOKS AND BUSINESS RECORDS

We expect our suppliers and partners to :

  • Disclose, on request, the location of facilities and known origins of materials to enable traceability

  • Maintain books and records that reflect all transactions in an accurate, honest, complete and timely way

  • Not engage in fraud, theft, or misuse of assets, obscure any record, or circumvent any policy or process for personal gain

  • Employ appropriate quality audit and compliance processes for matters such as product and food safety, worker health and safety, financial statements and labor and employment

6. EMBRACE SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

We expect our suppliers and partners to :

  • Make all possible efforts to include small and diverse suppliers (minority-owned, women-owned, veteran owned, disabled-owned, disadvantaged or HUB-certified businesses) in their active supplier base and partnerships.

  • Strive to reduce environmental impact through efficient use of resources and environmentally friendly technologies, as well as efforts such as ending deforestation, minimizing greenhouse gas emissions and waste, and using resources efficiently.

  • Work with TegaGold to implement sustainable processes and correct problems to drive continuous improvement and social value.

7. COMPLETE FAIRLY AND CONDUCT BUSINESS WITH INTEGRITY

We expect our suppliers and partners to:

  • Compete fairly and ethically with TegaGold’s business

  • Avoid any conflict of interest relating to financial interests or other arrangements with our employees that may be considered inappropriate.

  • Never offer or accept bribes, kickbacks, inappropriate gifts or hospitality, or other improper incentives in connection with TegaGold business

  • Avoid business practices such as arrangements that unlawfully restrain competition, improper exchange of information, spying, price fixing, etc.

8. PROTECT AND RESPECT PRIVATE AND PROPRIETARY INFORMATION

We expect our suppliers and partners to :

  • Safeguard any property belonging to TegaGold while under their control

  • Avoid any situations that may adversely affect our business interests or reputation

  • Protect any of TegaGold’ confidential information to which they have access, including its suppliers, employees or consumers’ information, intellectual property, trade secrets, patents, or financial information

  • Comply with insider trading laws and take steps to prevent their employees from trading our securities while in possession of material TegaGold nonpublic information.

9. COMPLY WITH APPLICABLE LAW, REGULATIONS, PLEDGES AND TEGAGOLD’S POLICIES

We expect our suppliers and partners to :

  • Know and follow global and local laws that apply to them and their business

  • Comply with or outperform all applicable regulations (business, environmental, social, quality & food safety, and health and safety) relative to their business.

  • Treat legal requirements as a minimum standard

  • Alert TegaGold to any material issue with goods and services they supply

  • Fulfill all TegaGold’s contractual commitments.

TRUST BASED RELATIONSHIP

At TegaGold, we aim at building trust-based relationships with ethical Supplier Partners who follow this Code of Conduct.

We expect our Suppliers and Partners to cooperate with our reasonable requests for information, certifications, and/or audit access. When there is a concern, our practice is to work with the Supplier or Partner. We may be able to help identify possible improvements. However, when an issue cannot be corrected or a Supplier or Partner is unwilling to engage, we reserve the right to end our relationship. By working closely with our Suppliers and Partners, we believe we can achieve mutual success while helping our consumers, communities and employees thrive.

TegaGold employees are prohibited from having personal interests that conflict with those of TegaGold or use their position with the company for any advantage or gain to themselves or their relatives and close friends. For the same reason, TegaGold employees may not accept gifts from any type of business partners, since it could affect their objectivity to pursue TegaGold best interest, and, finally, TegaGold employees will never accept a bribe or kickback or engage in any illegal practice with the suppliers and partners.

If you see or suspect any conduct or business practices that you think could violate this Supplier & Partner Code of Conduct, please contact TegaGold directly. You may raise a concern or get help through our secure contact us page.

PRECIOUS METALS

Recognizing the risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas and recognizing that we have the responsibility to respect human rights and not contribute to conflict. We commit to ensure that while sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:

  • any forms of torture, cruel, inhuman, and degrading treatment.

  • any forms of forced or compulsory labor, which means work or service

  • which is exacted from any person under the menace of penalty and for

  • which said the person has not offered himself voluntarily.

  • the worst forms of child labour.

  • other gross human rights violations and abuses such as widespread sexual violence.

  • war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses above. TegaGold will work with stakeholders to ascertain the circumstances of identified risks and violations, how they have handled these identified issues (through mitigation and remedy actions), and how these stakeholders have introduced appropriate control measures to prevent and better mitigate such risks now and in the future.

We require our suppliers to abide by the requirements and guidelines set out by the following International Regulators and Bodies:

RESPONSIBLE SUPPLY CHAIN

GOLD

SILVER

CHILD LABOUR