We believe that the way we conduct our business and the way employees act in fulfilling their job responsibilities are fundamental to achieving our business objectives.
We have adopted practices and procedures to ensure that these governance practices are followed. We expect all directors, officers, and employees to conduct themselves in accordance with the highest ethical standards. These are detailed in three key policies:
a) Code of Ethics for officers and employees;
b) Code of Ethics for directors;
c) International Business Conduct Policy for all directors, officers and employees.
Kumtor also has a “whistle-blower” program, which provides directors, officers, and employees a means to anonymously file complaints or submissions in good faith regarding potential ethical obligations by other directors, officers, and employees. Directors, officers and employees are also encouraged to speak to in-house legal counsel, human resources, or their managers if they have any concerns or questions. We provide on-going training on these policies for all of our directors, officers, and employees.
The Code of Ethics for employees addresses, among other things, avoidance of conflicts of interest, protection of confidential information, compliance with applicable laws, rules and regulations, adherence to good disclosure practices, and procedures for employees and third parties to report concerns with respect to accounting and auditing matters.
Employees with such concerns may report these directly or confidentially or anonymously. In 2018, a total of 2 sessions were held (both for expatriates and Nationals in English and Russian) at Kumtor. Our objective is to conduct this training on an annual basis, and to ensure that all employees receive in-person training at least once every 3 years (if not more in high risk areas). In 2018, we also developed an on-line video to provide similar training which will be used in conjunction with in-person training.
The Code of Ethics for directors requires promptly report all actual, potential, or perceived conflicts of interest to the corporate secretary, who is in turn required to bring such conflicts to the attention of the Nominating and Corporate Governance Committee. Directors may not participate in discussions, deliberations, or decision-making for matters in which they have a conflict of interest. All new directors are required to review and accept the Code of Ethics for Directors.
The International Business Conduct Policy is our anti-corruption policy and is an important component of Kumtor’s commitment to conduct business in an ethical and lawful manner, wherever we work. The International Business Conduct Policy prohibits directors, officers, and employees from making, offering, or promising, “anything of value” to a “Government Official” for an improper purpose such as (without limitation) obtaining preferential treatment, obtaining business, or securing or amending mining permits, licenses and concessions.
In our policy and the accompanying training, we highlight the broad definitions of “anything of value,” which is not restricted to monetary payments, and of “Government Officials” which can include individuals which people do not consider to be Government workers, such as candidates for political parties, and directors on government-owned companies.
We take the International Business Conduct Policy very seriously, and as described above, in late 2012 we initiated additional training at Kumtor related to the International Business Conduct Policy, and introduced the phone “hot-line” to provide support to staff. In 2013, we strengthened our supplier background-check process and introduced anti-corruption clauses into our standard supplier contracts.
To understand, evaluate, and manage our environmental footprint, we take a systematic “plan-act-monitor-improve” approach, which is aligned with the International Organization for Standardization’s ISO 14001 and Occupational Health & Safety Advisory Services’ OHSAS 18000 models. This approach began with an environmental impact assessment at the early planning stage of the Kumtor Project, continues with the implementation of our environmental management program, and also incorporates mine closure planning for the future. We follow an Environmental Management Action Plan (EMAP)* designed to address the effects of operations on the environment and to monitor material compliance with permits and other requirements. The system provides for scheduled monitoring, engineering controls, performance requirements in line with good international mining practice and local regulations, and reporting. The system and its key elements are also subject to corporate and external audits and approval by relevant Kyrgyz authorities. We also maintain a corrective preventive action ledger tracking system. This allows the safety and environmental departments to enter corrective action items and responsibilities. It also allows responsible departments to address and close out required activities. The EMAP, originally developed as part of the multilateral project financing for the Kumtor Project, also defines reporting requirements to lenders such as the European Bank for Reconstruction and Development. These reporting requirements cover the following:
*Aspects Covered by the EnvironmentalManagement Action Plan (EMAP):
The Kumtor Gold Company recognizes the protection of the health and safety of its employees, contractors, the public, and the environment as among the highest corporate priorities at all stages of our activities including exploration, operations and decommissioning, and is and will be committed to the principles of the Work Safe | Home Safe safety leadership program, the motto that “no job is so important that we cannot take the time to do it safely” and to the following:
In support of these commitments, KGC will: