Tertiary Minerals plc (the “Company”) practises responsible exploration as reflected in our Environmental, Social and Governance (“ESG”) Policy and our activities. By doing so we reduce project risk, avoid adverse environmental and social impacts, optimising benefits for all stakeholders while adding value to our projects.
Our business associates, consultants and contractors perform much of our primary activities at our projects. We encourage input from those with local knowledge and we review the ESG Policy on a regular basis.
Our ESG Policy is guided by the Prospectors & Developers Association of Canada’s (“PDAC”) Driving Responsible Exploration (“DRE”), formally known as e3 Plus. This provides a framework for responsible exploration built on eight key principles. DRE is flexible rather than prescriptive and encourages explorers to go beyond the local legal requirements in the jurisdiction of operations and apply leading “best practices”. The eight underlying principles are:
1. Adopting Responsible Governance and Management
Tertiary is committed to environmentally and socially responsible mineral exploration and has developed and implemented policies and procedures for corporate governance and ethics. We ensure that all staff and key associates are familiar with these and have appropriate levels of knowledge of these policies and procedures.
The Company employs persons and engages contractors with the required experience and qualifications relevant to their specific tasks and, where necessary, seeks the advice of specialists to improve understanding and management of social, environmental, human rights and security, and health and safety.
Tertiary’s Corporate Governance Statement, its Bribery & Anti-Corruption Policy and its Bribery & Anti-Corruption Code of Conduct can be viewed on our website here: www.tertiaryminerals.com/corporate-governance-statement.
2. Applying Ethical Business Practices
As well as our shareholders and staff, our stakeholders include local communities and local leadership, government and regulatory authorities, suppliers, contractors and consultants, our local business partners and other interested parties. Our corporate culture and policies require honesty, integrity, transparency and accountability in all aspects of our work and when interacting with all stakeholders.
We ensure that our contractors, consultants and local partners are aware of and adhere to our Bribery & Anti-Corruption Policy and the Company’s Bribery & Anti-Corruption Code of Conduct.
The Company takes all necessary steps to ensure that activities in the field minimise or mitigate any adverse impacts on both the environment and on local communities.
3. Respect Human Rights
The Company’s exploration activities are carried out in line with applicable laws on human rights and the Company does not engage in activities that have adverse human rights impacts.
4. Commitment to Project Due Diligence and Risk Assessment
We make sure we are informed of the laws, regulations, treaties and standards that are applicable with respect to our activities. We ensure that relevant stakeholders and interested parties are informed and prepared before going into the field in order to minimise the risk of miscommunication, unnecessary costs and conflict, and to understand the potential for creating opportunities with local communities where possible.
5. Engaging Host Communities and Other Affected and Interested Parties
The Company is committed to interact and engage positively with local communities, individuals and organisations in the areas that is operates. The Company understands the importance of this as part of its “Social Licence to Operate” and undertakes assessments to understand the social, political and cultural environment of the areas it is working in, and uses local experts and consultants, where needed. The Company engages with local stakeholders regularly to get their feedback and identify any potential areas of concern.
6. Contributing to Community Development and Social Wellbeing
The Company is committed to engaging positively with local communities, regulatory authorities, suppliers and other stakeholders in its project locations, and encourages feedback through this engagement. Through this process the Company develops and fosters the relationships on which our business relies for success.
For example, in Zambia, we work together with our local partner, Mwashia Resources Limited, to ensure that the appropriate tribal and local government organisations are consulted before initiating any exploration work, and for our Mukai and Mupala Projects we have entered into Memorandums of Understanding to govern our interaction with the affected Chiefdoms and to provide support for local community projects.
7. Protecting the Environment
We are committed to ensuring that environmental standards are met or exceeded in the course of our exploration activities. Applicable laws and local guidelines in all project jurisdictions are followed diligently and exploration programmes are only carried out once relevant permits and approvals have been secured from the appropriate regulatory bodies.
In Zambia, we work with the Zambian Environmental Management Agency (“ZEMA”) and are required to submit Environmental Project Briefs (“EPBs”) for approval by ZEMA before commencing exploration. We also work closely with the Department of Forestry where our projects occur within National Forests to minimise the impact of our activities and ensure appropriate reclamation.
In Nevada, USA, most of our exploration is carried out on Federally owned land administered by the Bureau of Land Management (“BLM”) which requires the submission of financial bonds for reclamation of exploration activities and which holds the Company to account. Provisions are made in the financial statements for reclamation costs in accordance with calculations set by the BLM. When operating on private lands, the Company applies the same rigorous standards for reclamation.
The Company is committed to good practices of environmental management and rehabilitation and repair during its mineral exploration activities. The Company follows the DRE’s Environmental Stewardship Toolkit and, where possible, chooses less impactful exploration methods to limit disturbance.
8. Safeguarding the Health and Safety of Workers and the Local Population
The Company’s activities are carried out in accordance with its Health and Safety Policy, which adheres to all applicable laws in the UK. We also take advice from local experts and consultants regarding the jurisdictions we operate in to make sure we comply with all local legislature for both contractors and local populations.
Last reviewed: 4 February 2026
