​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​Approved by the Board of Directors of A4J Explorations SARL on the 15 January 2026

Modern Slavery Prevention Policy

Ethic Minerals

1. Policy statement

1.1 

Modern slavery is a crime and a serious violation of fundamental human rights. It can take various forms, including slavery, servitude, forced or compulsory labour and human trafficking. All such practices share the common element of depriving a person of their liberty by another for the purpose of exploitation for personal or economic gain.

Ethic Minerals adopts a zero-tolerance approach to all forms of modern slavery and human trafficking. We are firmly committed to acting ethically, responsibly and with integrity in all our activities, business relationships and supply chains, and to implementing and enforcing effective systems and controls to ensure that such practices do not occur in any part of our organisation or supply chains.

1.2

Ethic Minerals is also committed to ensuring transparency in its operations and in its approach to preventing and addressing modern slavery throughout its value chain. We expect the same high standards from all our suppliers, contractors and business partners.

As part of our contracting processes, we expressly prohibit the use of forced, compulsory or trafficked labour, as well as any form of slavery or servitude, whether involving adults or children. We also expect our suppliers to adopt these same principles and apply them throughout their own supply chains.

2. About this policy

2.1

The purpose of this policy is to:

a) Set out the responsibilities of Ethic Minerals and of all persons working for or on behalf of the Company in relation to the prevention of modern slavery and human trafficking; and

b) Provide guidance on how to identify, prevent and report potential risks or situations related to modern slavery within our operations and supply chains.

2.2

This policy applies to all persons working for Ethic Minerals or on its behalf in any capacity, including employees, directors, officers, temporary workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

2.3

This policy does not form part of any employee’s contract of employment, and Ethic Minerals reserves the right to amend it at any time.

3. Responsibilities

3.1

The governing body of Ethic Minerals has ultimate responsibility for ensuring that this policy complies with applicable legal and ethical obligations and for overseeing its effective implementation.

3.2

Management is responsible for the day-to-day implementation of this policy, monitoring its effectiveness, responding to related queries, and ensuring that internal control systems are adequate to prevent and detect modern slavery risks.

3.3

Managers and supervisors at all levels are responsible for ensuring that individuals reporting to them are aware of, understand and comply with this policy, and receive appropriate and regular training, particularly in relation to risks associated with mining operations and supply chains.

3.4

Ethic Minerals actively encourages feedback and suggestions for improving this policy. Any comments or queries may be addressed to Management or through the appropriate internal channels.

4. Individual responsibilities and raising concerns

4.1

All persons subject to this policy must read, understand and comply with it.

4.2

The prevention, detection and reporting of modern slavery in our operations or supply chains is a shared responsibility of all persons working for Ethic Minerals or under its control.

4.3

Any activity that could directly or indirectly result in a breach of this policy must be avoided.

4.4

Any person who believes or suspects that a breach of this policy has occurred or may occur must report it to their line manager or through the established reporting channels as soon as possible.

4.5

Ethic Minerals encourages the early reporting of any concerns related to modern slavery, regardless of the level of the supplier or the tier of the supply chain involved.

4.6

Reports may be made in accordance with the Company’s Whistleblowing Policy. Where appropriate, and always prioritising the safety and well-being of workers, Ethic Minerals may work with its suppliers to address and remediate coercive or abusive labour practices identified within their operations or supply chains.

4.7

If there is any uncertainty as to whether a particular situation, the treatment of workers or their working conditions may constitute a form of modern slavery, the matter should be discussed with the appropriate manager.

5. Protection of whistleblowers

5.1

Ethic Minerals promotes a culture of openness and transparency. Any person who raises a genuine concern in good faith will be supported, even if it is later determined that the concern was unfounded.

5.2

No form of retaliation will be tolerated against anyone who reports, in good faith, a suspicion of modern slavery. Retaliation includes, but is not limited to, dismissal, disciplinary action, threats or any other unfavourable treatment.

5.3

Any person who believes they have suffered retaliation should report this immediately to Management or through the whistleblowing channel.

6. Training and communication

6.1

Training on this policy and on the risks of modern slavery in the mining sector and supply chains forms part of the induction process and is reinforced through periodic training activities.

6.2

Ethic Minerals’ zero-tolerance approach to modern slavery is communicated to suppliers, contractors and business partners at the outset of the business relationship and reinforced on an ongoing basis where appropriate.

7. Breaches of this policy

7.1

Any employee who breaches this policy may be subject to disciplinary action, which may include dismissal, in accordance with applicable law.

7.2

Ethic Minerals reserves the right to terminate its contractual relationship with any individual or organisation acting on its behalf that breaches this policy.