Ethics and integrity

The Code defines the way we do business underpinned by our company vision, values and purpose. All employees are required to complete training on the Code before commencing work and undertake an annual refresher course.

Failure to comply with the Code is a serious matter and may lead to disciplinary action, including dismissal and/or legal action. Material breaches are reported to the Ethics and Governance Committee, the People and Remuneration Committee and the board.

Our ‌‌‍​​Whistleblower Policy​​ and ‌‌‍​​Whistleblower Procedure ​‌‌​outline the reporting process for employees and other stakeholders to raise concerns, ensure those concerns are addressed and encourage bystanders to speak up.​​‌​‌‍‍​

Reports can be made through our confidential external reporting service, MinRes Integrity Assist, which is communicated to employees and contractors.‌​​

We also provide a secondary internal reporting mechanism through our ‌‌​​Speak Up Procedure‌‌​​‌​. This provides employees with the option to anonymously raise and seek resolution to personal grievances.‌‍

The process for investigating depends on the nature of the matter and seniority of the respondent.​​

MinRes aims to achieve appropriate and fair resolutions and ensure appropriate outcomes when breaches are substantiated.​‌​‌

We prohibit any form of punishment, disciplinary or retaliatory action against anyone for raising or addressing a business conduct concern.​​​‌​

Bribery and corruption adversely affect the business environment by undermining legitimate business activities and stakeholder trust.​

Our Anti-Bribery and Corruption Policy‌‍‍​​​​ outlines our zero tolerance to bribery, corruption or any actions that constitute fraud and encourages employees to speak up and report any concerns internally and/or externally.

MinRes iscommitted to ensuring that our security risk management practices are conducted with integrity and in alignment with our organisational culture, values and legislative requirements.‌‌​​​

In carrying out security management across all operations, MinRes prioritises the protection and promotion of human rights alongside ensuring the safety and security of our employees, contractors, facilities and equipment. Recognising both our ethical obligations and the potential societal impacts of our activities, MinRes has appropriately registered our security agent licence and implemented security measures, including the deployment of qualified security personnel, across all operational sites.‌‍‌

Our security structure and operational standards reflect responsible, ethical security practices and are fully aligned with and endorsed by compliance with the Security and Related Activities (Control) Act 1996(WA) and relevant legislative requirements.‌​​‌‌​‌

Directors and employees are encouraged to have a personal financial interest in MinRes and to hold securities on a long-term basis.‌‌​

Our ‌​​Securities Trading Policy ‌‌​‌governs the trading activities of directors, employees, contractors and consultants of the company (Personnel) in relation to their MinRes securities and any securities they hold in other companies.​‌‌​

The Policy mandates that Personnel in possession of inside information must not deal in MinRes securities or encourage, advise or procure anyone to do so, or share inside information (directly or indirectly) with anyone else.‌​​‌​​‍​‌

We operate a risk-based sanctions compliance framework, overseen by the Audit and Risk Committee and aligned with the regimes of Australia, the United Kingdom, the United Nations, Europe and the United States of America, as well as other international regulatory guidance. Comprehensive screening of all business partners, agents and suppliers is conducted against sanctions, watchlist and politically-exposed persons lists at onboarding and on a risk-adjusted, ongoing basis.

Supplier approvals follow a risk-based process, requiring enhanced due diligence and escalation for higher risk suppliers with guidance provided as needed. All actual or suspected breaches are escalated, managed and documented under our Risk Management Framework to support audit and continuous improvement.