North Georgia Telecom aims to operate its business by responding to requests from customers and broader community faithfully, fulfilling its responsibilities as a sensible business group based on the NGT’s Compliance. This represents the management philosophy and code of conduct of NGT’s Group of Companies.

We established a management system in compliance with the guidance of LBMA*1, LPPM*2 to avoid human rights violations in high-risk settings, such as conflict zones, money laundering schemes, fraudulent transactions and financing terrorists, as well as to fulfill our responsibilities for the environment and sustainability in the precious metals supply chain, we will promote responsible precious metals management along the policies set out below.

1. Establishment of management system
We will set up an organization and appoint officers for the promotion of responsible precious metals management and will establish a satisfactory management system.

2. Identification and assessment of risk
We will recognize the procurement of materials from high-risk areas including conflict zones where human rights violations are rampant. We will not engage any activities that may lead to money laundering, fraudulent transactions and financing terrorists. We will conduct due diligence, identify and assess risks in the precious metals supply chain.

3. Monitoring of transactions and maintaining of records
We will periodically carry out monitoring to ensure that responsible precious metals management is executed in an appropriate manner. Also, all transaction records will be maintained appropriately.

4. Implementation of educational training
We will periodically provide necessary education and training to all employees engaged in responsible management of precious metals.

5. Implementation of third‐party audit
We will periodically perform auditing on responsible precious metals management by an independent outside third‐party organization.

*1 London Bullion Market Association
*2 London Platinum and Palladium Market

Established on October 1, 2021
Brittany Gold
NGT – North Georgia Telecom

Code of Conduct for Responsible Supply Chains in accordance with OECD Guidance

Recognizing potential risks that could have significant adverse impacts which could be associated with extracting, trading, handling, and exporting minerals from conflict‐affected and high‐risk areas and understanding that we have the responsibility to respect human rights and not contribute to conflict. We commit to adopt, widely disseminate, and incorporate in contracts and/or agreements with suppliers. For the responsible sourcing of minerals from conflict‐ affected and high‐risk areas, conflict‐sensitive sourcing practices and suppliers’ risk awareness will be implemented from the point of extraction until the end user. We commit to refraining from any action which contributes to the financing of conflict, and we commit to comply with relevant United Nations sanctions resolutions or, where applicable, domestic laws implementing such resolutions.

Regarding serious abuses associated with the extraction, transport or trade of minerals:

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:
i) any forms of torture, cruel, inhuman and degrading treatment;
ii) any forms of forced or compulsory labour, which means work or service which is exacted from any person under the menace of penalty, and for which said person has not offered himself voluntarily;
iii) the worst forms of child labour;
iv) other gross human rights violations and abuses such as widespread sexual violence;
v) war crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.

Regarding risk management of serious abuses:

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 as defined in paragraph 1.

Regarding direct or indirect support to non‐state armed groups:

We will not tolerate any direct or indirect support to non‐state armed groups through the extraction, transport, trade, handling or export of minerals. This includes, but is not limited to, procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to non‐state armed groups or their affiliates who:
illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain; and/or illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or illegally tax or extort intermediaries, export companies or international traders.

Regarding risk management of direct or indirect support to non‐state armed groups:

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 providing direct or indirect support to non‐ state armed groups as defined in paragraph 3.

Regarding public or private security forces:

We agree to eliminate, in accordance with paragraph 10, direct or indirect support to public or private security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders.

We recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.

Where we or any company in our supply chain contract public or private security forces, we commit to or we will require that such security forces will be engaged in accordance with the Voluntary Principles on Security and Human Rights. In particular, we will support or take steps, to adopt screening policies to ensure that individuals or units of security forces that are known to have been responsible for gross human rights abuses will not be hired. We will support efforts, or take steps, to engage with central or local authorities, international organizations, and civil society organizations to contribute to workable solutions that will heighten transparency, proportionality and accountability in payments made to public security forces for the provision of security We will also avoid or minimize the exposure of vulnerable groups, in particular, artisanal miners.

Regarding risk management of public or private security forces:

In accordance with the specific position of the company in the supply chain, we will immediately devise, adopt, and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces. This is identified in paragraph 5, where we identify that such a reasonable risk exists. In such cases, we will suspend or discontinue engagement with upstream suppliers, after failed attempts at mitigation within six months from the adoption of the risk management plan. Where we identify a reasonable risk of activities inconsistent with paragraphs 8 and 9, we will respond in the same vein.

Regarding bribery and fraudulent misrepresentation of the origin of minerals:

We will not offer, promise, give or demand any bribes. We will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport, and export.

Regarding money laundering:

We will support efforts, or take steps, to contribute to the effective elimination of money laundering, where we identify a reasonable risk of money‐laundering resulting from, or connected to, the extraction, trade, handling, transport or export of minerals. Derivations include illegal taxation or extortion of minerals at points of access to mine sites, along transportation routes or at points where minerals are traded by upstream suppliers.

Regarding the payment of taxes, fees and royalties due to governments:

We will ensure that all taxes, fees, and royalties related to mineral extraction, trade, and export from conflict‐ affected and high‐risk areas are paid to governments. In accordance with the company’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI).

Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money‐laundering and payment of taxes, fees and royalties to governments:

In accordance with the specific position of the company in the supply chain, we commit to engage with suppliers, central or local governmental authorities, international organizations, civil society and affected third parties, as appropriate, to improve and track performance, with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.