1 Company Information

    GG Refinery Limited was established on 28th March 2019. The company’s CID is CID004506. GG Refinery has one refining facility that is located at Bomba Mbili, Geita                District, Geita Township, Tanzania. The refining facility focuses on processing gold as a raw material.

2 RMAP Assessment Summary

   GG Refinery has undergone a Responsible Minerals Assurance Process (RMAP) assessment on 23 October 2023 for assessment period from 31 July 2023 to 1 October 2023. The      assessment was conducted by a Responsible Sourcing Audit Firm (Assigned by the Responsible Mineral Initiatives ( RMI) from 19 through 23 October 2023. Once completed,          the assessment summary report will be made public and available at: GG Refinery Official Website

3 Responsible Mineral Supply Chain Policy

    To avoid the use of conflict minerals, which directly or indirectly finance or benefit armed groups and/or involve other serious human right abuses in high-risk and conflict-              affected regions, GG Refinery has developed a supply chain policy. The supply chain policy follows the third edition of the Organisation for Economic Co-operation and                    Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs) (OECD Due Diligence              Guidance). Our supply chain policy covers all the risks identified in Annex II of the OECD Guidance and its geographic scope is global. GG Refinery is committed to addressing      any Annex II risks if identified. The supply chain policy was reviewed and approved by senior management and Head of Compliance, which are committed to support its                    implementation. The policy has been widely disseminated to relevant stakeholders (suppliers, customers, employees etc.) and is available on the company website at GG                    Refinery Official Website

4  Management System

4.1 Structure

      GG Refinery follows through on its commitments in the supply chain policy and has developed an internal procedure for due diligence with the following aspects:                               • GG Refinery’s Head of Compliance is responsible to oversee the due diligence program and risk management design and implementation.                                                                   • GG Refinery has assigned due diligence Compliance Assistants to coordinate the work of the relevant departments (including the Purchasing Department, Quality                                Department, Production Department, and Warehouse Management Department) to ensure each department follows up on their roles and responsibilities to implement the due            diligence program and report any red flags and potential risks identified.                                                                                                                                                                           • GG Refinery conducts due diligence management system training once a year for key staff from all relevant departments required in due diligence program. If there is an                    update of the program, the company conducts additional training as necessary.

4.2 Internal System of Control

       GG Refinery has established internal controls, processes and records that ensure the integrity of financial and accounting information is maintained and any fraudulent acts are           prevented. These internal controls have been categorized as follows:
        • Control of environment factors include the integrity, ethical values, and competence of the entity’s people; management’s philosophy and operating style; the way GG                        Refinery management assigns authority and responsibility and organizes and develops our people; and the attention and direction provided by the board of directors.
        • Control of all the activities occurring throughout the organization, at all levels and in all functions. They include a range of activities as diverse as approvals, authorizations,              verifications, reconciliations, reviews of operating performance, security of assets and segregation of duties.
        • Financial control system and reporting to control activities as required for external and internal audits.

4.3 Record Keeping and Traceability System

      GG Refinery requires that all records relating to the due diligence program are maintained at least for five years and that they be properly used and safely stored in our company        database. GG Refinery has adopted the OECD Due Diligence Guidance to create a system of controls and transparency over the mineral supply chain, including a chain of                custody or a traceability system, or that they identify upstream actors in their supply chain. Chain of custody refers to all steps in a supply chain that take possession of the                product, including miners, transporters, exporters, processors, and manufacturers. It provides record of the sequence of entities that have custody of minerals as they move                  through a supply chain that allows the ability to trace a material back to its origin. A credible chain-of-custody system supports the truthfulness of mineral origin claims. GG              Refinery has established the chain of custody that includes documentation such as mine origin certificate, transport documentation, export, and import records and production            records Traceability means the ability to follow the trail of minerals along the supply chain by monitoring and tracking chain of custody. GG Refinery is using the chain of                custody system, KYC procedures, and further necessary due diligence approach to trace material to the mine and country of origin

5 Risk Identification

    GG Refinery has a robust procedure to identify risks in the supply chain. In terms of any identified risks in the supply chain, GG Refinery has established a procedure to identify      CAHRAs The procedure includes the resources used, the criteria to define “CAHRAs” as well as the risk identification thresholds and frequency with which our                                  determination is reviewed. In terms of CAHRAS, GG Refinery assesses for the following criteria to determine whether the supply chain is of high-risk:
         1. Widespread human rights violations,
         2. Weak governance, and
         3. Armed conflicts.
     GG Refinery identifies CAHRAs as areas in its supply chain as those areas covering:
         1. “RMI’s Global Risk Map”, which GG Refinery uses as its sole resource to identify CAHRAs.
         2. The Democratic Republic of the Congo (DRC) and its nine adjoining countries as outlined in Section 1502 of the Dodd Frank Act (DFA 1502), namely: Angola, Burundi,                   Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (the  Covered Countries’).
         3. The indicative and non-exhaustive list of CAHRAs provided by the European Commission pursuant to Article 14.2 of the European Union Regulation 2017/821.
         4. Other areas GG Refinery determines to be high-risk are based on the following resources and thresholds. If two of the three resources result in a finding of high-risk,                           the area will be  considered as a CAHRA. If a country is listed as “High” or “Extreme” risk, GG Refinery also considers it as CAHRA.

•  Heidelberg Conflict Barometer (HCB): GG Refinery uses HCB (referencing Datasets – HIIK) to classify the criteria of “Conflicts, including violent crises, wars, and coup d’états) ”. This applies if a country attains a score of 4 or higher on the HCB.
• Fragile State Index (FSI): GG Refinery uses FSI (referencing Global Data | Fragile States Index) to classify the criteria of “P3: Human Rights”. This applies, if a country is classified by the most recent FSI as having a fragility score of greater than or equal to 7.
• Worldwide Governance Indicators (WGI): GG Refinery uses WGI (referencing Interactive Data Access | Worldwide Governance Indicators (govindicators.org)) to classify the criteria of “Governance”. If a country scores in the 20 percentile or lower in the WGI.

6 Risk Assessment

    GG Refinery has not encountered any material determined to be “high-risk” in its supply chain during this assessment period. However, GG Refinery conducts risk assessments         to cover the following areas:
           • Assessing the context of CAHRAs
           • Clarifying the chain of custody
           • Assessing the activities and relationships of upstream suppliers
           • Identifying locations and qualitative conditions of the extraction, trade, handling, and export of minerals; and,
           • conducting on-the-ground assessments at the mining sites
    GG Refinery reviews the areas in its supply chain in accordance with its established risk management plan at a minimum, annually and/or when there are any changes within our      supply chain sources or upon an update of each resource. In the case of any non-conformities in the supply chain, a risk assessment will be conducted, and the respective                    mitigation plan will be defined and implemented accordingly. For any further inconsistencies, errors or incomplete information, GG Refinery communicates the improvement            areas to its suppliers and where applicable a request for an updated form is conducted. If red flags are identified, GG Refinery would further engage in assessing the situation            with its suppliers to clarify and improve the documents as needed.
    Furthermore, GG Refinery annually conducts risk identification, assessment, and mitigation approach on any potential CAHRAs identified in its supply chain. This includes              establishing risk related reports (in the context of armed conflicts, governance, and human rights) of the mining sites in Tanzania. Amongst others, such reports specifically focus        on addressing potential human rights abuses in relation to undesired mining practices.

7 Grievance mechanism

    GG Refinery has established the Responsible Mineral Supply Chain Policy and the Complaints and Response Management Procedure under which the procedures facilitate ease         in voicing out concerns about any identified risks in the supply chain. Any such reports are strictly confidential and handled discreetly i.e., anonymously.
     GG Refinery also refers to RMI’s grievance mechanism (RMI Grievance Mechanism ) to collect information on grievances from interested parties. Complaints can be made               directly to our compliance department via the company website on the following link: GG Refinery Grievance Mechanism.