Code of Business Conduct

This Code sets out the standards of conduct expected of everyone who works for or on behalf of A-flow Mining Supply Solutions, for its operations in the Democratic Republic of the Congo ("A-flow"), including employees, directors, agents, carriers, suppliers, and other business partners.

It applies wherever we operate and is governed by the laws of the Democratic Republic of the Congo, including the applicable OHADA Uniform Acts. Where local law sets a higher standard, the higher standard applies.

• We compete fairly and win business on the merits of our services.
• We keep accurate books and records and never create false or misleading documents, including delivery notes, invoices, and customs declarations.
• We avoid conflicts of interest and disclose any personal interest that could influence a business decision.

We do not offer, pay, request, or accept bribes, kickbacks, or facilitation payments, directly or through third parties. All business is conducted in compliance with the anti-corruption provisions of Congolese law, including the Penal Code, and, because A-flow is a U.S.-based company, the U.S. Foreign Corrupt Practices Act (FCPA).

We comply with applicable international sanctions, including U.S. sanctions administered by the Office of Foreign Assets Control (OFAC) and do not deal with sanctioned persons or territories.

• Safety comes before speed, cost, or convenience. Anyone may stop work they believe is unsafe.
• We respect human rights, prohibit child and forced labour, and provide fair working conditions.
• We prevent spills and pollution and comply with the requirements of the Ministry of Hydrocarbons, the Directorate General of Customs and Excise (DGDA), the Congolese Control Office (OCC), and the other competent Congolese authorities.

We protect confidential business information and personal data, and process personal data in accordance with the applicable data protection provisions of Congolese law, including the Digital Code.

Carriers, suppliers, and contractors must follow this Code or equivalent standards. A-flow carries out due diligence before engaging partners and may suspend or end the relationship with anyone who breaches it.

Concerns can be raised in confidence with A-flow management or by email to compliance@aflowsolutions.com. A-flow does not tolerate retaliation against anyone who raises a concern in good faith.