Anti-Corruption Policy

1. Policy Scope

This policy applies globally and without exception to all KGML directors, employees, contractors, consultants, agents, and joint venture partners. Compliance is a condition of employment and of any commercial engagement with KGML.

2. High-Risk Areas

• Government interactions — licensing, permitting, customs, and export documentation
• Procurement of services in high-risk jurisdictions
• Use of agents, intermediaries, and local representatives
• Political donations and contributions
• Commodity sourcing in jurisdictions with elevated corruption indices

3. Management Responsibilities

Senior management is responsible for ensuring anti-corruption controls are embedded within their areas of responsibility. All significant third-party engagements in high-risk markets require Compliance sign-off.

4. Conflicts of Interest

All potential conflicts of interest must be disclosed to and approved by the Compliance Officer. Undisclosed conflicts of interest are a disciplinary matter.

5. Consequences of Violation

Violations will result in disciplinary action up to and including termination. Where criminal conduct is identified, KGML will cooperate fully with relevant law enforcement authorities.