Code of Conduct

Introduction

This Code of Conduct is part of Sotkamo Silver's sustainable operations. Our corporate sustainability management is based on the company’s own responsibility policy, the TSM Finland mining responsibility system and the principles of the international ISO 9001, ISO 14001 and ISO 45001 standards for quality, environment and occupational safety.

This policy applies to the entire personnel and Board members. By adhering to this policy, we act ethically and fairly towards all stakeholders and uphold the good reputation of our company. The policy is based on the Ten Principles of the UN Global Compact.

The executive management of Sotkamo Silver is responsible for communicating, monitoring and updating this policy. It is the responsibility of the entire personnel to report any actual or suspected breaches of the Code of Conduct. Any reports are made either to the line manager or confidentially in the company's whistleblowing channel.

Mission and values

The purpose of our company is to produce precious metals sustainably and efficiently and to develop the company's operations profitably on a long-term basis. Our operations are guided by two core values: responsibility and respect for the local community. We strive for sustainability, transparency and integrity in everything we do.

Personnel

Our HR policy is based on accountability, transparency and a shared goal of creating a safe and comfortable workplace. We should all treat our co-workers equally and fairly. We do not tolerate harassment or other inappropriate conduct.

It is the employer's responsibility to ensure safe working conditions. It is everyone's responsibility to use appropriate protective equipment and follow safe working practices. Our company has a zero tolerance policy for working under the influence of intoxicants.

As a company, we are committed to equal opportunities, fairness and diversity and respect the right of employees to organise. We do not tolerate the use of forced or child labour either directly or indirectly through business partners. In all our activities, we respect the law and legally binding agreements.

We all commit to following the employer's instructions, such as those concerning moving around the site, bringing guests or taking care of the company's assets. More detailed instructions and regulations for personnel are set out in the personnel manual.

Environment

All our activities are based on the sustainable use of natural resources and respect for the environment. They are also a prerequisite for our long-term and profitable business. In the planning of operations, we take into account environmental aspects and apply life cycle thinking. It is important for our company that the environment is taken care of in our daily work.

Partners

We treat our suppliers and other partners with respect as experts in their respective fields. We strive for long-term partnerships and believe in the long-term development of cooperation. Similarly, we expect our partners to take an active role in developing the agreed tasks and activities. We select our business partners based on objective business criteria, with a preference for local partners.

Competition

We strictly comply with competition law. We do not enter into discussions or agreements with our competitors that would restrict competition.

Insider policy

We are committed to complying with the laws applicable to financial and market-related information and the principles of good business conduct. Our reporting is timely, accurate, transparent and reliable.

Sotkamo Silver's insider policy is based on Swedish and EU securities laws and regulations. Special guidelines apply to insider policy which all parties must follow. Inside information means any unpublished information the disclosure of which would be likely to have a material effect on Sotkamo Silver's share price or the prices of its financial instruments.
The obligation of confidentiality of inside information applies to all parties. It is prohibited to exploit insider information directly or indirectly by trading for one's own account or for the account of a third party.

Trading by persons holding inside information or designated managers is prohibited during the closed period.

Sotkamo Silver maintains insider lists and lists of managers who are required to disclose transactions in Sotkamo Silver's shares and other securities.

The CFO is responsible for insider management and, should a breach of insider regulations be suspected, the company will cooperate with the ensuing investigation.

Conflicts of interest

A conflict of interest arises when an individual's personal interest conflicts with that of the company. Avoiding conflicts of interest is important for the ethics and integrity of our business.

We strive to ensure that we conduct our business and make our decisions objectively and honestly, without personal gain or advantage. Each of us is obligated to report any potential conflicts of interest to their supervisor. We also assess potential conflicts of interest of our business partners before we start working with them.

Transparency and stakeholder communication

At Sotkamo Silver, we are committed to transparency within the company and towards our stakeholders. We believe that openness in our activities and communication help us build trust and strong relationships with our stakeholders. At the same time, we understand the importance of confidential information. In social and other media, the company's affairs are commented on only by the CEO or a person authorised by him.

We communicate openly with our customers in the event of quality deviations or other challenges. We want to ensure that our customers are aware of the situation and that we can find a solution to the problem together.

We actively collaborate with our stakeholders. We are ready to demonstrate our activities so that our stakeholders can better understand them and their impacts.
Bribery and corruption

We have zero tolerance for bribery, corruption, inappropriate payments and other financial misconduct in all our transactions. This policy applies not only to our own organisation but also to our business partners.

Our company's personnel or members of the Board may only offer and accept customary and reasonable gifts, benefits or hospitality.