Governance and Standards

We believe that the way we conduct our business, and the way employees act in fulfilling their job responsibilities are fundamental to achieving our business objectives.

We have adopted Company practices and procedures to ensure that these governance practices are followed. We expect all directors, officers, and employees to conduct themselves in accordance with the highest ethical standards. These are detailed in Code of Ethics of Kumtor Gold Company CJSC:

Code of Ethics of Kumtor Gold Company CJSC

The Code of Ethics contains such requirements as preventing conflicts of interest; protecting confidential information from unauthorized access in accordance with all applicable legal and statutory requirements; ensuring equal opportunity, objectivity and transparency, excluding protectionism in personnel decisions regarding hiring, promotion or employment benefits at KGC; promoting integrity and professionalism and encouraging career development based on personal relationships with the Company’s employees; ensuring that the Code of Ethics is based on the best interests of the Company; and ensuring that the Code of Ethics does not discriminate against any individual or organization. 

MEASURES TO PREVENT CORRUPT PRACTICES

Our main principles for the prevention of corruption are: – Intolerance to any corruption manifestations, expressed in the complete rejection of corrupt practices in any form or manifestation in the performance of its activities, strict restrictions for officials working under an employment contract and employees acting on behalf of KGC or in its interests, to participate directly or indirectly in corrupt practices; legality, expressed in KGC’s compliance with anti-corruption legislation; due diligence, expressed in the KGC’s obligation to check applicants for employment before making decisions on the conclusion of labour and other contracts for their impeccable reputation, rejection of corruption, nepotism and conflict of interest; cooperation and coordination, expressed in cooperation with authorised state bodies in the field of anti-corruption activities and coordination of actions in the process of combating corruption; assistance to the KGC in the inevitability of punishment, regardless of the position they hold length of service, previous merits and other conditions when KGC employees commit corrupt acts.

An employee shall notify in writing his/her immediate supervisor and an authorised employee of the KGC Security Service of all cases when he/she is approached by any persons in order to induce him/her to commit corruption offences, and in case of failure to take appropriate measures by his/her immediate supervisor and an employee of the KGC Security Service, to the Management Board of KGC. 

An employee shall notify his/her immediate superior in writing of any conflict of interest or the possibility of its occurrence as soon as he/she becomes aware of it.

COMPLIANCE WITH LAWS, RULES AND REGULATIONS 

We are committed to complying with all laws, rules and regulations applicable to each specific territory in which we operate. All employees are required to comply with the standards and restrictions imposed by existing laws, rules and regulations. Employees are responsible for knowing the laws, rules and regulations pertaining to their activities and, if necessary, seeking assistance from their immediate supervisor, Human Resources or KGC’s Legal Department. 

Environmental management systems

To understand, evaluate, and manage our environmental footprint, we take a systematic “plan-act-monitor-improve” approach, which is aligned with the International Organization for Standardization’s ISO 14001 and Occupational Health & Safety Advisory Services’ OHSAS 18000 models. This approach began with an environmental impact assessment at the early planning stage of the Kumtor Project, continues with the implementation of our environmental management program, and also incorporates mine closure planning for the future. We follow an Environmental Management Action Plan (EMAP)* designed to address the effects of operations on the environment and to monitor material compliance with permits and other requirements. The system provides for scheduled monitoring, engineering controls, performance requirements in line with good international mining practice and local regulations, and reporting. The system and its key elements are also subject to corporate and external audits and approval by relevant Kyrgyz authorities. We also maintain a corrective preventive action ledger tracking system. This allows the safety and environmental departments to enter corrective action items and responsibilities. It also allows responsible departments to address and close out required activities. The EMAP, originally developed as part of the multilateral project financing for the Kumtor Project, also defines reporting requirements to lenders such as the European Bank for Reconstruction and Development. These reporting requirements cover the following:

• Monitoring results as a monthly average on a station-by-station basis
• Material exceedances and non-compliance with an explanation of corrective action
• Details of reportable spills and corrective actions
• Changes to monitoring protocols or stations
• Status of the closure plan and costs
• Update on data related to acid-rock drainage, waste rock piles, and glaciers
• Yearly estimates of fresh-water usage, tailings storage, and discharges
• Studies related to the site’s environmental affairs
• Outline of the activities, studies and surveys planned for the next reporting period
• Worker health protection and safety initiatives

*Aspects Covered by the EnvironmentalManagement Action Plan (EMAP):

• Handling of hazardous materials and emergency response
• Environment protection, including wildlife conservation
• Containment, control and elimination of seepage and spills
• Policies, programs, training, regulating documents, and reporting procedures
• Mine closure requirements

Summary of Kumtor’s Health, Safety, and Environmental Policy

The Kumtor Gold Company recognizes the protection of the health and safety of its employees, contractors, the public, and the environment as among the highest corporate priorities at all stages of our activities including exploration, operations and decommissioning, and is and will be committed to the principles of the Work Safe | Home Safe safety leadership program, the motto that “no job is so important that we cannot take the time to do it safely” and to the following:

• compliance with applicable laws and regulations of the jurisdictions in which we operate, and generally accepted international industry practices;
• providing employees and contractors with a working environment free of uncontrolled hazards;
• identifying and eliminating or controlling potential risks to health and safety of employees, contractors and the public to levels as low as reasonably achievable, social and economic factors being taken into account;
• controlling the potential impacts of our activities on the environment to levels as low as reasonably achievable;
• achieving continual awareness of and improvement to our overall safety, health and environmental
• Compliance with the Work Safe | Home Safe principles, a safety leadership program where individuals are responsible to take ownership of their personal safety and the safety of those working around them to ensure that everyone returns home safely.

In support of these commitments, KGC will:

• implement and maintain a formal health, safety and environmental management system;
• identify the significant health and safety hazards and risks associated with our activities;
• set objectives and targets so as to improve continually our health, safety and environmental management and performance;
• identify the potential for incidents, and emergency situations and develop, maintain and test emergency response plans which provide for the protection of the environment, the health and safety of our employees, the public, and the communities adjacent to our operations;
• undertake constructive dialogue with the communities located near our operations regarding safety and environmental issues;
• handle and dispose of our wastes responsibly to avoid, reduce or control pollution;
• decommission and reclaim our sites in a planned and timely manner;
• conduct regular audits to assess and ensure conformance to this Policy;
• engage in constructive communication of this Policy with all employees and relevant contractors and suppliers so they are aware of, and able to comply with their health, safety and environmental responsibilities in a manner appropriate to their role in the organization, and to encourage them to make contributions to KGC’s health, safety and environmental management;
• provide employees at all levels with appropriate training so as to allow them to carry out their health, safety and environmental duties and responsibilities;
• ensure the participation of employees in the development and implementation of health, safety and environmental programs and procedures associated with their work places;
• provide adequate and appropriate resources to implement this Policy; and
• make this Policy available to the public.