Ethics and Integrity

MinRes’ recognises that risk is an inherent part of our business and manages that risk through our Risk Management Framework. Effective risk management has been, and will continue to be, essential to protecting business value and securing future growth

Based on ISO 31000 – Risk Management, our Risk Management Policy outlines our expectations for the formal management of risk and includes:

• an overarching Risk Appetite Statement outlining key dimensions to define acceptability and balances strategic ambition with responsible risk management
• identifying, assessing, monitoring and reporting risks to provide senior management and the Board with the assurance that risks are being effectively identified and managed
• consistently applying risk management processes across all stakeholder engagement
• fostering leadership and promoting a strong risk culture through continuous engagement, information sharing and training
• implementing processes for crisis management and business continuity planning, enabling us to effectively respond to material risk
• ensuring the effectiveness of our systems and controls through appropriate assurance mechanisms.

Cybersecurity continues to be a critical risk, with the 2024 Australian Cyber Security Centre’s Annual Threat Report and other intelligence sources highlighting a sustained rise in cyber threats globally. These threats are becoming more sophisticated and pervasive, targeting both informational technology and operational technology environments across industries.

MinRes has implemented a Cybersecurity Strategy focused on strengthening foundational controls and enhancing cyber resilience. This includes extending the coverage and effectiveness of controls across governance, risk management and security operations domains.

MinRes has developed a set of core policies, procedures and internal controls to assist in complying with legal and regulatory obligations, aiming to meet the highest standards of corporate conduct.

We encourage employees to report known or suspected breaches of the Code, and any other policies or directives, and to raise any concerns they may have regarding breaches of the Code of Conduct, via various reporting mechanisms.

MinRes is firmly committed 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.

We operate a risk-based sanctions compliance framework, overseen by the Audit and Risk Committee and aligned with Australian, UN and other international regulatory guidance. Comprehensive screening of all business partners, agents and suppliers is conducted against government and industry standard sanctions 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 residual risk 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.

The Code of Conduct defines the way we do business which is based on our values and represents our commitment to upholding the highest standards of ethics in our business practices. It also sets our expectation that all employees and contractors behaviour with fairness, honesty and respect towards others.

Prior to commencing work with us, all employees are required to complete training on the Code of Conduct and undertake annual refresher training.

Failure to comply with the Code of Conduct is a serious matter that may lead to disciplinary action, including dismissal and/or legal action. Material breaches of the Code of Conduct are reported to the Audit and Risk Committee and/or the Ethics and Governance Committee and Board, depending on the breach.

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

Where there has been suspected breaches of the Code of Conduct and any other policies or directives, MinRes has reporting channels that allow concerns to be raised.

Our Whistleblower Policy and Whistleblower Procedure outline the reporting process for employees and other stakeholders to raise concerns, ensure those concerns are address 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.

Reports are subject to internal or external investigation, depending 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.

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

As part of our commitment to operating ethically and with integrity in all business activities and stakeholder relationships, we have an Anti-Bribery and Corruption Policy.

This 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, including through our external whistleblower hotline, MinRes Integrity Assist.

We seek to build mutually beneficial relationships and respect the rights of our employees, contractors, members of our local communities and other stakeholders directly impacted by our operations.

We prohibit the use of forced labour which includes child labour, slave labour and human trafficking.

Our Human Rights Policy outlines our commitment and joint responsibility to ensure our business activities respect the rights and dignity of all people.

All employees, contractors, suppliers and other relevant stakeholders are required to comply with the principles outlined in this policy and are encouraged to report any breaches through our internal and external whistleblower mechanisms.

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.