ESG & Sustainability

1. Introduction

Metals and Extraction Company of Nigeria Limited (the "Company" or "Mexcon") is committed to the sustainable discovery, development and production of minerals. As a responsible explorer the Company must identify, assess and report responses to environment, climate change and social challenges. The Company acknowledges that it has a role to play in protecting the natural environment, reducing global greenhouse gas emissions and to improving people's lives now and for generations to come. This Environmental, Social and Governance Policy (ESG Policy) regulates and provides guidance for the Company's management of activities to minimise adverse workforce, community or environmental impacts.

2. Purpose and Applicability

A strong environmental, social and governance performance is essential for the success and growth of the Company's business. This Policy is applicable to Mexcon and its related affiliates including but not limited to Metcon Limited and Nubia Resources, its employees, contractors, suppliers, and business partners, including operations involved in exploration, mining, extraction, processing, transportation, storage, and trading of minerals and metals. It covers all business functions, including management, operations, procurement, logistics, finance, human resources, and legal and corporate governance. The Company will manage its activities in a sustainable manner with respect to our workforce, our communities and the environment.

2.1. Specific Objectives

To ensure compliance with environmental and social regulations, while promoting continuous improvement.
To align operational and trading practices with global sustainability standards.
To minimize environmental footprint and optimize resource efficiency.
To foster inclusive, safe, and equitable workplaces.
To uphold transparency, ethical conduct, and accountability.
To create enduring value for stakeholders through responsible community engagement.

3. Governing Principles — General

The Company shall achieve its ESG aims by:

Implementing a systematic approach to ESG risk management.
Complying with and exceeding all relevant laws and regulations and applying responsible industry standards where laws do not exist.
Setting, measuring and reviewing objectives and targets that will drive continuous improvement in ESG performance.
Embedding ESG considerations in the Company's business planning and decision making processes.
Integrating ESG requirements when designing, purchasing, constructing and modifying equipment and facilities.
Reviewing the ESG contingency planning process to ensure high-risk activities have appropriate contingency plans in place.
Maintaining a culture in which stakeholders are aware of their ESG obligations and are empowered to intervene on ESG issues.
Providing continued education to all stakeholders to identify and act upon opportunities to improve ESG performance.
Undertaking and supporting research and using a scientific approach to support impact assessments and evidence-based decision making.
Taking a collaborative and pro-active approach with our stakeholders.
Requiring directors, contractors and employees to comply with our ESG expectations in a mutually beneficial manner.

3. Governing Principles — Environment

In relation to the environment, the Company shall ensure that, as a minimum, all policies and procedures comply with all applicable environmental laws, assessment and approval requirements, licences and conditions, and shall commit to operate all business units sustainably by:

Identifying, mitigating, managing and reporting on material environmental risks and impacts associated with the business unit's activities.
Planning and implementing strategies to manage and reduce key environmental risks such as greenhouse gas emissions, water management and waste reduction.
Where relevant, protecting and respecting natural systems and associated biodiversity in areas where the Company operates.
Efficiently using water and energy and maximising the value of existing resources.
Integrating mine closure and progressive rehabilitation into the life-cycle of the Company's operations to minimise its environmental legacies.
Encouraging environmentally responsible actions including supporting the use of materials that are safe, recycled or reused.
Informing employees, customers and suppliers about this Policy and considering the environmental performance of potential suppliers in decision-making.
Reporting openly, honestly and in a timely manner to stakeholders on environmental and sustainability performance.

3.1.1. Mining and Extraction Activities

For our mining and extraction operations, the relevant companies shall:

Ensure safe blasting, excavation, and waste-rock management in compliance with statutory and international safety requirements.
Rehabilitate mined-out areas progressively, integrating land restoration into every stage of the mining lifecycle.
Engage host communities and regulators transparently during mine closure planning to ensure sustainable post-operation use of land and resources.

3.1.2. Metals Trading Activities

For our metals trading operations, the Company shall:

Commit to responsible sourcing, ensuring that only metals from verified, conflict-free, and ethical suppliers are traded.
Maintain robust traceability systems throughout the metals supply chain to enable verification of origin and integrity.
Conduct due diligence to prevent involvement in the trade of minerals associated with human rights abuses, environmental degradation, or illegal extraction.
Align with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and applicable international conventions.

3. Governing Principles — Climate Change

The Company shall take action to appropriately identify and manage climate change risks and opportunities, including to:

Seek opportunities to better understand the life-cycle of greenhouse gas (GHG) emissions for the uranium and lithium value chains.
Increase the transparency of the Company's climate change reporting of performance metrics and targets to meet the needs of shareholders, governments, lenders, insurers, customers and communities.
Report the Company's energy use, Scope 1 and Scope 2 GHG emissions against the Company's annual targets.
Ensure that measuring, reporting and verification processes are robust across all operating sites.
Pro-actively assess options to increase the use of renewable power and lower emission energy technologies to reduce GHG emissions intensity.
Focus on opportunities to improve energy efficiency to reduce energy used and reduce direct mining costs.
Identify and pursue best practices and partner with technology developers to explore new opportunities for uranium and lithium extraction and processing in the transition to a low carbon future.
Continue to assess climate change scenarios and projected future energy prices so that the cost of carbon informs business decisions.
Partner with experts and research organisations to identify potential physical threats of climate change at current and planned sites and invest in appropriate adaptation responses to build resilience.

3. Governing Principles — Social

The Company shall provide a safe workplace; identify and manage risks, impacts and opportunities within our operations and host communities; be responsible stewards of the commodities extracted; create shared value with stakeholders; respect and promote human rights, refusing to engage in or condone forced or compulsory labour or modern slavery; recognise and honour the cultural heritage, customs and traditions of indigenous peoples; and uphold ethical business practices and comply with all legal requirements in all jurisdictions in which the Company operates.

Social — Workplace Health and Safety

Employee well-being is central to sustainable business. The Company will:

Maintain ISO 45001-compliant occupational health and safety systems through its third-partied recruitment vendor.
Conduct hazard identification and risk assessments regularly.
Promote a "zero-harm" safety culture through training and supervision.

Social — Human Rights and Labour Practices

Respect for human dignity underpins all operations. The Company will:

Uphold the UN Guiding Principles on Business and Human Rights.
Prohibit discrimination, harassment, forced labour, and child labour.
Promote diversity, inclusion, and equal opportunity.

Social — Community Engagement and Development

Positive community relationships strengthen operational success. The Company will:

Engage communities through open, participatory consultations.
Support socio-economic projects in education, healthcare, and enterprise development.
Foster local employment and capacity building.

Social — Resettlement, Land & Cultural Heritage

Where land acquisition or displacement is necessary, the Company will adhere to IFC Performance Standard 5 and Nigerian laws, provide fair compensation and livelihood restoration programs, and maintain grievance mechanisms accessible to affected parties. The Company will also identify and protect cultural and historical sites and obtain Free, Prior, and Informed Consent (FPIC) from traditional custodians.

Governance Commitments (G)

This section defines Mexcon Group's oversight and compliance framework:

Ethics and Anti-Corruption: Enforce zero tolerance for bribery and corruption, ensure transparency in procurement and contracting, and require declaration and management of conflicts of interest.
ESG Oversight and Accountability: ESG oversight rests with the Board of Directors through its Committee. The Company has a designated ESG Lead responsible for coordination and monitoring, with departments integrating ESG KPIs into performance metrics.
Supply Chain Due Diligence: Conduct due diligence consistent with the OECD Due Diligence Guidance, avoid sourcing from suppliers linked to human rights violations, and promote transparency and traceability in metals trading.
Transparency and Reporting: Communicate ESG risks, performance, and progress openly.
Whistleblowing and Grievance Mechanisms: Maintain secure, confidential channels for reporting misconduct and protect against retaliation against whistleblowers.

4. Application

Responsibility for the application of this Policy rests with, but is not limited to, all Company employees and contractors engaged in activities under the Company's operational control. Each department is responsible for developing its own internal policies to implement the objectives set out above, and the Company's managers are responsible for promotion of the ESG and various Department Policies.

5. Monitoring and Review

Material breaches of this ESG Policy will be reported to the Company's Board of Directors or the established responsible committee of the Board. The Board will monitor the content, effectiveness and implementation of this ESG Policy on a regular basis, supplemented by independent reviews from time to time. This Policy shall be reviewed every two (2) years or as required by significant regulatory, operational, or environmental changes, with updates approved by the Board and communicated across all business units and external partners.

Appendix A — Sustainability Policy

This Sustainability Policy translates Mexcon's ESG Policy and aspirations into actionable sustainability practices tailored to our mining, exploration, and trading operations. As a growing player in Nigeria's natural resources sector, Mexcon recognizes its responsibility to operate in a manner that safeguards the environment, supports inclusive growth, and strengthens governance systems. Our sustainability journey is iterative; as a company less than five years old, our practices are evolving, but our intent to embed sustainability into every operational decision is unwavering.

Appendix A — Core Principles

Sustainable Resource Utilization: Extract and trade mineral resources efficiently, promote responsible land use, water management and energy conservation, and commit to mine rehabilitation and site restoration post-extraction.
Responsible Value Chain Governance: Uphold due diligence in sourcing and trading minerals free from conflict or human rights abuses, enforce supplier screening, and support transparency in contracts, licensing, and payments.
Continuous Innovation for Efficiency: Leverage emerging technologies to improve exploration accuracy and safety, and invest in research that drives circular economy outcomes such as reusing waste rock or recovering metals from by-products.
Transparent Stakeholder Communication: Maintain open communication with regulators, host communities, investors and employees, disclose performance metrics in annual reports, and establish grievance mechanisms.
Social Investment for Shared Prosperity: Invest in education, health and infrastructure in host communities, prioritize local employment and capacity-building, and promote gender inclusion and equitable access to opportunities.

Appendix A — Implementation & Monitoring

The Board and Executive Management oversee the sustainability strategy, while each operational unit (Mining, Trading, HSE, Legal & Compliance, Community Relations) embeds sustainability in day-to-day decisions, supported by regular training and stakeholder collaboration. Sustainability performance is monitored using measurable indicators such as energy consumption, emissions, water use, waste volumes, community investments, and safety statistics. The ESG & Sustainability Team conducts an annual review, with findings integrated into the Company's annual ESG Report made available to investors, regulators, and other stakeholders. This Policy is reviewed every two (2) years or as required by significant changes.

Appendix B — ESG Commitments Summary

Environmental: Protect biodiversity, manage waste, and reduce emissions. Social: Promote human rights, safety, and community development. Governance: Uphold ethics, transparency, and accountability. Our Pledge: Sustainability is not a project — it is the way we do business.