COMPANY POLICY
Atlas G Enterprise is committed to conducting all operations in a responsible, ethical, and safe manner in full alignment with international due diligence standards, specifically the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including OECD Annex II (Model Supply Chain Policy). This policy is explicitly based on OECD Annex II requirements, and all suppliers, contractors, and employees must comply without exception.
1. Purpose
The purpose of this policy is to:
Ensure responsible sourcing of minerals and materialsPrevent involvement in conflict, human rights abuses, and illegal practices Protect health, safety, and wellbeing of all workers and affected communitiesAlign company operations with OECD Annex II and occupational safety standards
2. Scope This policy applies to: All employees of Atlas G EnterpriseAll suppliers, transporters, subcontractors, and business partnersAll mineral sourcing, handling, trading, and export activities 3. Operating Principles All operations must follow: Legal and licensed mineral trading proceduresFull traceability of all minerals received and soldZero tolerance for fraud, smuggling, or undocumented mineralsCompliance with OECD Annex II responsible sourcing standards
4. Mineral Reception Procedures All minerals must be received with valid documentation (delivery note, ID of supplier, mining site declaration)Each consignment must be weighed, recorded, and verified immediatelyMinerals must be entered into the official register/system without delayAny discrepancy must be reported to management immediately
5. OECD Annex II – Explicit Zero-Tolerance Risks Atlas G Enterprise adopts zero tolerance toward any involvement, direct or indirect, in the following OECD Annex II risks: 5.1 Serious Human Rights Abuses Torture or cruel, inhuman, and degrading treatmentForced or compulsory laborWorst forms of child laborGross human rights violations, including sexual violence
5.2 Armed Conflict Financing Direct or indirect support to non-state armed groupsProvision of minerals, money, logistics, or assistance to armed groups
5.3 Illegal Security Force Activity Illegal control of mines, transport routes, or trade points by public or private security forcesExtortion, illegal taxation, or abuse by security personnelHuman rights abuses committed by security forces in mining areas
5.4 Fraud, Corruption, and Illicit Trade Bribery and corruptionFraudulent misrepresentation of mineral originMoney laundering and terrorism financingIllegal taxation avoidance or misreporting of mineral flows
6. Health and Safety (H&S) Management Atlas G Enterprise recognizes that OECD Annex II risks are directly connected to workplace health and safety risks. Therefore, this policy is integrated with the company’s Health and Safety system.
6.1 Safety Protection Principles The company ensures: Safe and secure working environments in all operationsRisk assessments before any mining, transport, or handling activity Provision and mandatory use of Personal Protective Equipment (PPE) Prevention of occupational injuries, fatalities, and exposure to hazards
6.2 Conflict-Affected Area Safety Risks Operations in high-risk areas are strictly controlled to prevent: Violence or armed conflict exposure affecting workersUnsafe mining conditions controlled by illegal actorsForced labor situations that compromise worker safetyUnsafe transport routes controlled by armed groups or corrupt forces
6.3 Integrated Risk Management Health & Safety and OECD Annex II compliance are managed together through: Joint risk assessments (security + occupational safety)Incident reporting systems covering both human rights and safety eventsRegular training on safety, ethics, and responsible sourcingImmediate suspension of operations if serious Annex II or safety risks are identified
7. Supplier and Partner Requirements All suppliers must: Fully comply with OECD Annex II standards Provide accurate and transparent mineral origin documentationMaintain safe working conditions consistent with H&S laws Report all safety incidents and ethical risks immediatelyAccept audits and inspections by Atlas G Enterprise
8. Cash Handling and Financial Control All payments must be recorded and approvedNo unofficial or cash-only undocumented transactions allowedDual verification required for large transactionsDaily reconciliation of cash and stock records
9. Record Keeping and Traceability The comptoir must maintain: Daily mineral intake and output registersSupplier identification recordsTransport documents and chain-of-custody formsAudit-ready records at all times
10. Staff Conduct All employees must: Act honestly and professionallyAvoid conflicts of interestReject bribery or facilitation paymentsReport any suspicious activity immediately
11. Monitoring and Enforcement Regular internal audits will be conducted External inspections may occur at any timeViolations may lead to disciplinary action, suspension, or terminationSerious breaches may be reported to regulatory authorities 12. Reporting and Enforcement Any suspected OECD Annex II violation or safety risk must be reported immediatelyConfidential reporting channels will be maintainedNon-compliance may result in suspension or permanent termination of contracts
12. Continuous Improvement Atlas G Enterprise commits to continuously improving its due diligence and safety systems in line with OECD updates, national mining laws, and international best practices. Signed:Managing Director
2. Scope This policy applies to: All employees of Atlas G EnterpriseAll suppliers, transporters, subcontractors, and business partnersAll mineral sourcing, handling, trading, and export activities 3. Operating Principles All operations must follow: Legal and licensed mineral trading proceduresFull traceability of all minerals received and soldZero tolerance for fraud, smuggling, or undocumented mineralsCompliance with OECD Annex II responsible sourcing standards
4. Mineral Reception Procedures All minerals must be received with valid documentation (delivery note, ID of supplier, mining site declaration)Each consignment must be weighed, recorded, and verified immediatelyMinerals must be entered into the official register/system without delayAny discrepancy must be reported to management immediately
5. OECD Annex II – Explicit Zero-Tolerance Risks Atlas G Enterprise adopts zero tolerance toward any involvement, direct or indirect, in the following OECD Annex II risks: 5.1 Serious Human Rights Abuses Torture or cruel, inhuman, and degrading treatmentForced or compulsory laborWorst forms of child laborGross human rights violations, including sexual violence
5.2 Armed Conflict Financing Direct or indirect support to non-state armed groupsProvision of minerals, money, logistics, or assistance to armed groups
5.3 Illegal Security Force Activity Illegal control of mines, transport routes, or trade points by public or private security forcesExtortion, illegal taxation, or abuse by security personnelHuman rights abuses committed by security forces in mining areas
5.4 Fraud, Corruption, and Illicit Trade Bribery and corruptionFraudulent misrepresentation of mineral originMoney laundering and terrorism financingIllegal taxation avoidance or misreporting of mineral flows
6. Health and Safety (H&S) Management Atlas G Enterprise recognizes that OECD Annex II risks are directly connected to workplace health and safety risks. Therefore, this policy is integrated with the company’s Health and Safety system.
6.1 Safety Protection Principles The company ensures: Safe and secure working environments in all operationsRisk assessments before any mining, transport, or handling activity Provision and mandatory use of Personal Protective Equipment (PPE) Prevention of occupational injuries, fatalities, and exposure to hazards
6.2 Conflict-Affected Area Safety Risks Operations in high-risk areas are strictly controlled to prevent: Violence or armed conflict exposure affecting workersUnsafe mining conditions controlled by illegal actorsForced labor situations that compromise worker safetyUnsafe transport routes controlled by armed groups or corrupt forces
6.3 Integrated Risk Management Health & Safety and OECD Annex II compliance are managed together through: Joint risk assessments (security + occupational safety)Incident reporting systems covering both human rights and safety eventsRegular training on safety, ethics, and responsible sourcingImmediate suspension of operations if serious Annex II or safety risks are identified
7. Supplier and Partner Requirements All suppliers must: Fully comply with OECD Annex II standards Provide accurate and transparent mineral origin documentationMaintain safe working conditions consistent with H&S laws Report all safety incidents and ethical risks immediatelyAccept audits and inspections by Atlas G Enterprise
8. Cash Handling and Financial Control All payments must be recorded and approvedNo unofficial or cash-only undocumented transactions allowedDual verification required for large transactionsDaily reconciliation of cash and stock records
9. Record Keeping and Traceability The comptoir must maintain: Daily mineral intake and output registersSupplier identification recordsTransport documents and chain-of-custody formsAudit-ready records at all times
10. Staff Conduct All employees must: Act honestly and professionallyAvoid conflicts of interestReject bribery or facilitation paymentsReport any suspicious activity immediately
11. Monitoring and Enforcement Regular internal audits will be conducted External inspections may occur at any timeViolations may lead to disciplinary action, suspension, or terminationSerious breaches may be reported to regulatory authorities 12. Reporting and Enforcement Any suspected OECD Annex II violation or safety risk must be reported immediatelyConfidential reporting channels will be maintainedNon-compliance may result in suspension or permanent termination of contracts
12. Continuous Improvement Atlas G Enterprise commits to continuously improving its due diligence and safety systems in line with OECD updates, national mining laws, and international best practices. Signed:Managing Director