Built Responsibly From the Start

Why this matters to us

Mining is one of the few industries that permanently alters the landscape it operates in. It moves earth, uses water, employs thousands of people in hazardous conditions, and generates revenue in places where that revenue matters enormously. Done badly, it damages environments, displaces communities and enriches very few. Done well, it builds skills, infrastructure, tax bases and livelihoods that outlast the mine itself.

The difference between the two is not luck or geology. It is a series of decisions, most of them taken early, most of them taken before anyone outside the company is watching. Aframax is at exactly that stage. We are designing our management systems, our operating standards and our community relationships now, which means we can build them properly rather than retrofit them under pressure later.

How sustainability is governed

Responsibility for health, safety, environmental and social performance sits with line management, not with a separate function. Site leadership is accountable for performance on their site; executive management is accountable to the Board. HSES performance is a standing item at senior management level and is reviewed by the Board. Serious incidents, significant environmental events and material community grievances are escalated without delay and without filtering.

Our policies apply to every Aframax employee and are extended contractually to contractors, subcontractors and suppliers working on our sites. Outsourcing a task does not outsource responsibility for how it is done.

Environmental assessment begins before ground is disturbed. Every project is subject to environmental and social impact assessment scoped to its host jurisdiction and to the IFC Performance Standards, with management plans built into engineering design rather than appended to it.

We apply the mitigation hierarchy in order: avoid, minimise, restore, and offset only what genuinely remains. Avoidance is the cheapest and most effective control available, and it is only available early.

Water

Water is the environmental issue most likely to bring a mine into conflict with the people around it. We treat water as a shared resource rather than an input, measuring what we take and discharge, maximising recycling within our processing circuits, protecting groundwater and surface water quality, monitoring upstream and downstream, and making the results available to authorities and communities. Acid rock drainage and metal leaching are assessed at the design stage, because the cost of managing drainage rises by orders of magnitude once it has begun.

Low-carbon hydro-electricity

Energy & emissions

The metals we produce are essential to reducing global emissions. That does not exempt us from reducing our own. We work to improve energy efficiency in comminution, materials handling and processing, and to increase the share of low-carbon electricity in our supply. Our region offers a real opportunity: hydroelectric generation accounts for the large majority of installed capacity in both the DRC and Zambia. Realising that advantage depends on contracted, verifiable supply rather than grid averages, and that is what we work towards and will report.

Biodiversity survey

Land, biodiversity & rehabilitation

We assess biodiversity value before disturbance, avoid critical habitat, and design footprints to be as small as the orebody allows. Rehabilitation is progressive: land is stabilised, contoured and revegetated with indigenous species as areas become available, rather than left to a single programme at closure, cheaper, more effective ecologically, and visible to communities while the mine is still operating.

Progressive rehabilitation

Waste, tailings & closure

Waste rock and tailings storage facilities are designed, constructed and monitored by qualified engineers, with independent review and clear accountability at named individual level. Where we operate tailings facilities, we manage them in line with the Global Industry Standard on Tailings Management. Every mine closes; we plan for it from the beginning, covering physical and chemical stability, post-closure water quality, future land use and, critically, the economic transition of the workforce and communities who depend on the operation. A mine that closes leaving a stable landform but a destitute community has not been closed responsibly.

Ethics & anti-corruption

We do not pay bribes. We do not make facilitation payments. We do not permit them to be made on our behalf by agents, intermediaries, contractors or joint venture partners. This is not a statement of ambition; it is an operating constraint, and it carries a cost: there are transactions we have not completed because they could not be conducted cleanly. We accept that cost. Our Code of Conduct applies to every employee and is extended contractually to our business partners; counterparties, agents and significant suppliers are subject to due diligence including beneficial ownership, sanctions and politically exposed person screening.

Transparency

We support transparency in the extractive sector. Both the DRC and Zambia implement the Extractive Industries Transparency Initiative, and we will participate in national EITI reporting in the jurisdictions where we operate. We pay the taxes, royalties, fees and levies due in the countries where we produce, and we pay them there. Revenue generated from a country's natural resources should be taxed in that country. This is not a concession; it is part of the basis on which mining is permitted at all.

Traceability controls

Responsible sourcing & supply chain due diligence

Our supply chain due diligence follows the five-step framework of the OECD Due Diligence Guidance: a documented management system, risk identification and assessment, a strategy to respond to identified risks, independent third-party audit at appropriate points, and public reporting. In practice this means material is traceable from extraction to sale, with mass-balance controls that prevent material of unknown origin entering our production, and that we sell to refiners operating their own recognised responsible-sourcing assurance.

Our position on artisanal mining

Artisanal and small-scale mining is a defining feature of the gold sector in our region. It supports hundreds of thousands of livelihoods and is associated with serious hazards, including child labour on some sites. Our position is precise, because imprecision here is worse than silence:

• Aframax production comes from our own industrial operations. We do not purchase third-party ore at the gate and we do not buy artisanally mined material.
• We maintain physical and administrative controls against unauthorised material entering our processing chain, and we verify them.
• We employ children nowhere, in no capacity. Age is verified at recruitment, and the same requirement is imposed contractually on every contractor and subcontractor.
• Where artisanal activity occurs near our license areas, we work with authorities and communities on formalisation and alternative livelihoods rather than displacement alone.

We will not claim that the entire mineral supply chain of our region is free of abuse. It is not, and no single company can guarantee otherwise. What we can state is what we control, how we control it, and how that control is verified.