Compliance to External Initiatives (Mandatory and Voluntary)

Ambatovy strives to maintain the highest ethical standards, to respect local culture and traditions, and to comply with the laws and regulations of Madagascar. We endeavor to meet and, when possible, exceed the mandatory compliance requirements of our agreements with the Government of Madagascar, our lenders and other stakeholders. We are also committed to several voluntary measures that go beyond our legal obligations.

These mandatory and voluntary initiatives include:

• Law on Large-Scale Mining Investments (LGIM);
• Decree on Rendering Investments Compatible with the Environment (MECIE);
• International Finance Corporation (IFC) Performance Standards;
• Equator Principles;
• Business and Biodiversity Offsets Program (BBOP);
• Voluntary Principles on Security and Human Rights (VPSHR);
• Extractive Industries Transparency Initiative (EITI);
• Towards Sustainable Mining (TSM);
• International Standard ISO 9001;
• International Council on Mining and Metals (ICMM)

Business Ethics

Ambatovy’s core values require that we conduct our business in a moral and ethical manner and that our employees comply with all applicable laws. To support this conduct and to provide clear guidance on what it means to act with integrity, Ambatovy has a Business Ethics Code, an Anti-Corruption Policy, a Code of Conduct, a Zero-Tolerance Policy and a policy against discrimination and harassment in the workplace.

Our contractors are also required to comply with these policies and codes. A requirement to comply with Business Ethics, Anti- Corruption, and Code of Conduct Policies, such as Ambatovy’s Environmental Code of Conduct, is included in all contracts awarded to new contractors to ensure they comply with our expectations in these areas; these policies and codes are regularly renewed and updated.

Human rights

Human rights issues are an inherent risk to all mining sites around the world. To manage this risk, we are aligning with international best practices and have adopted a formal Human Rights Policy that affirms the commitment of Ambatovy to operate in a way that respects human rights as set forth in the Universal Declaration of Human Rights. Human rights protection and awareness have been integrated into our operational and sustainability strategies. Both employees and external stakeholders have access to the Grievance Management System as well as to the Whistleblower System. They can file grievances on any subject, including unethical behavior and human rights violations. We are committed to investigating any violations and ultimately aim to prevent such violations before they take place by informing our employees and key stakeholders of our expectations with regards to respect, honesty and integrity.

Protection of Children’s Rights

Since risks to children were first identified during the construction phase, much work has been done to ensure that the rights of children are protected. Our Human Rights Policy, for example, articulates our commitment to the Convention on the Rights of the Child (CRC) and the entire workforce must sign our Zero-Tolerance Policy for child exploitation. All of our contractors are also required to adhere to our policies on child and forced labor and fundamental human rights.

For the past several years, Ambatovy has supported the work of the Child Protection Networks in Moramanga and Toamasina, comprised of local authorities, security officials, teachers, community leaders, and so on. In collaboration with a UN agency, Ambatovy has also supported the construction and renovation of ten youth kiosks in Moramanga and Toamasina and along the pipeline in between those two urban areas. These kiosks provide safe spaces for youth to meet, discuss issues pertaining to their health, exchange ideas and play games. Young peer educators have received training to be able to run the kiosks and to provide support to their fellow youth.

In order to be in line with best practice for industries around the world, to promote continuous improvement and to demonstrate our commitment to protecting children’s rights, Ambatovy has collaborated with partners to develop a series of training modules on the Children’s Rights and Business Principles (CRBPs) for our suppliers and contractors. The CRBPs are ten principles that UNICEF and the organization Save the Children developed to help companies identify pragmatic actions to support children’s rights in their activities and operations and to put a child rights lens on their work.

Voluntary Principles on Security and Human Rights (VPSHR)

Established in 2000, the VPSHR are a set of principles designed to guide companies in the extractive sector in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms. Companies such as Ambatovy have a unique opportunity to have a positive impact on peace and stability, and we are continuously engaging with local, national and international entities to educate and raise awareness for the promotion of human rights. The VPSHR are embedded in Ambatovy’s Security Policy, which outlines our commitment to foster a safe and secure business environment and to conduct security operations in compliance with local, national and international legal requirements, security standards and law enforcement principles. We have also incorporated VPSHR-related requirements into our agreements with both private and public security providers.

The Ambatovy Grievance Management System

At Ambatovy, remedies for complaints, up to and including potential human rights violations, are provided through our Grievance Management System. Since it was established in 2012, Ambatovy’s Grievance Management System has provided communities with a transparent, participatory channel through which anyone can raise an issue of concern and be assured of receiving fair and thorough consideration. The system has incorporated best practice guidance from a number of sources in order to ensure it is practical and credible.

Both employees and external stakeholders have access to the Grievance Management System as well as to the Whistleblower System. They can file grievances on any subject, including unethical behavior and human rights violations. We are committed to investigating any violations and ultimately aim to prevent such violations before they take place by informing our employees and key stakeholders of our expectations with regards to respect, honesty and integrity.

Responsible Sourcing

Ambatovy’s vision is to be recognized as a successful and responsible producer of high-quality nickel and cobalt that created lasting value for all stakeholders and that contributes to sustainable development in Madagascar.

This includes engaging stakeholders and benefiting communities, operating ethically and responsibly, striving to meet the highest standards, providing a safe and rewarding workplace, and demonstrating responsible environmental stewarship.

Responsible sourcing is one of Ambatovy’s critical commitments; it highlights important social, ethical and environmental considerations with regards to our products and our supply chain.