Supplier Code of Business Conduct
Health, Safety, and Well-being The physical and psychological health, safety, and well-being of everyone engaged in our business are paramount. Therefore, we expect Suppliers to share our commitment to achieving zero harm and our target to eliminate all fatalities and serious injuries at our operations.
We partner with Suppliers who understand the risks that may arise in their work and have the right systems, processes, and people in place to manage those risks, underpinned by a safety focused culture. Beyond complying with GG Refinery Ltd.’s site or office rules and safety requirements and applicable laws, we expect Suppliers to consult with GG Refinery Ltd. on matters relating to health, safety, and well-being, cooperate in implementing initiatives, and coordinate their activities with GG Refinery Ltd.
Underpinning this, our Suppliers must work with us to promote a working environment where everyone feels safe and empowered to speak up on health, safety, and well-being matters.
Environmental Stewardship GG Refinery Ltd. is committed to sound environmental stewardship. We aim to use the natural resources our business depends on responsibly, care for the environment in our operational and surrounding areas, and limit the impact of our operations on our host communities.
Our commitment requires avoiding, and where that is not possible, mitigating any adverse environmental impacts of our operations on our stakeholders – we expect our Suppliers to operate to this standard. Suppliers must comply with all applicable in-country laws, environmental management and reporting rules, codes, and standards, and GG Refinery Ltd.’s contractual and site requirements, particularly concerning cultural heritage management, water discharges, air emissions, pollutants, waste, and chemicals management. We expect Suppliers to strive to minimize their environmental impacts, including (but not limited to): greenhouse gas emissions, short-lived climate pollutants, and commodity-driven deforestation, with the aim of continuous improvement over time.
Human Rights
GG Refinery Ltd.’s commitment to upholding and respecting the human rights of different stakeholders is described more fully in our Human Rights Policy Statement (https://www.geitarefinery.com) which is also embedded in our Code of Conduct and applies to our workforce as well as our Suppliers. The Human Rights Policy Statement is informed by and supports various international standards, including the UN Guiding Principles on Business and Human Rights, the conventions of the International Labour Organization, the UN Universal Declaration on Human Rights, the Voluntary Principles on Security and Human Rights, and the ICMM Mining Principles and Position Statements.
We expect our Suppliers to respect and uphold all internationally proclaimed human rights within their operations, affiliates, and supply chains. With respect to labor rights, in particular, workers must not be subject to forced or compulsory labor; must be offered lawful and fair terms of employment; have freedom of association, collective bargaining, and equal remuneration; and where accommodation is provided, it must be safe, healthy, and sanitary while respecting workers’ dignity and right to privacy. Suppliers are expected to proactively identify, address and – where legislation requires – report on risks of modern slavery practices in their operations and supply chains.
These practices may include servitude, debt bondage, the use of involuntary prison labor, deceptive labor recruiting, trafficking of persons, physical and psychological abuse, and forced marriage. Suppliers must not engage (either directly or indirectly) in child labor and must comply with all laws relating to minimum employment age.
Diversity & Inclusion We expect Suppliers to support and share GG Refinery Ltd.’s commitment to ensuring safe and respectful workplaces for its people and stakeholders, regardless of gender, ethnicity, age, religion, marital status, sexual orientation, pregnancy, disability, political affiliation, union membership, or any other classification that may give rise to discrimination under the law. All harassment, bullying, assault, or discrimination complaints must be taken seriously, handled confidentially, and promptly, thoroughly, and fairly investigated, with all persons involved treated respectfully.
Communities GG Refinery Ltd. seeks to develop mutually beneficial and lasting relationships with our host communities based on mutual respect and trust through open and constructive engagement. We respect customary laws, local traditions, rights, interests, cultures, perspectives, and special connections to the lands and waters on which we operate. Where practical, GG Refinery Ltd. strives to source materials from local in-country and host community suppliers, thereby maximizing the value generated in the country of operation. Our Suppliers are encouraged to cooperate and coordinate with our teams to:
- Develop and implement strategies to incorporate host community businesses in procurement and contracting activities.
- Identify employment opportunities.
- Promote supplier diversity and equity in the market by engaging minority or under represented business.
Preventing and Eliminating Bribery & Corruption ….. ………. GG Refinery Ltd.’s contract terms are consistent with the requirements of the US Foreign Corrupt Practices Act, UK Bribery Act, and defined statutory obligations in the jurisdictions where GG Refinery Ltd. has a presence. In addition, Suppliers must comply with all applicable laws prohibiting bribery and corruption.
Suppliers are not permitted to solicit, offer, or promise a bribe, kick-back, or any other improper payment or benefit (including facilitation payments), whether acting on their own or on behalf of GG Refinery Ltd., and must have processes in place to ensure that no such payments or inducements are requested, accepted, offered, or given.
Suppliers are encouraged to maintain a confidential hotline or other mechanisms for reporting violations. Any political activity engaged in by a supplier must indicate that it does not represent GG Refinery Ltd., irrespective of the relationship with GG Refinery Ltd. or its operations.
Business Integrity
GG Refinery Ltd. contract terms require that Suppliers treat all information they receive through their dealings with GG Refinery Ltd. as confidential. This extends to making statements or posting material/images concerning GG Refinery Ltd. without GG Refinery Ltd.’s prior written consent.
Suppliers must avoid all conflicts of interest that may arise in the performance of work on behalf of GG Refinery Ltd. and their related business decisions. Accordingly, we expect suppliers to declare any situation or relationship that raises an actual, potential, or perceived conflict of interest concerning their dealings with GG Refinery Ltd.
Suppliers must not give gifts, hospitality, or other benefits (other than common business courtesy), which may be perceived to compromise the professionalism or impartiality of GG Refinery Ltd.’s personnel (who are required to declare and seek approval in respect of all such items).
Suppliers must record all information relating to their dealings with GG Refinery Ltd. honestly, accurately, and completely, including maintaining appropriate records (which may be required for auditing purposes).
Insider Trading Trading in shares or securities based on material non-public information, or supplying that information to others, is illegal.
Speaking Up Suppliers can report violations of GG Refinery Ltd.’s Code of Conduct or Supplier Code of Business Conduct, or any other concerns to: Grievance mechanism form. Anonymity is guaranteed.
