AFRICAN COMPASS INTERNATIONAL

(“ACI/the company”)

HUMAN RIGHTS POLICY

Statement of Intent

ACI recognizes its responsibility for the impact of our activities on our employees, on consumers of our products and on the communities in which we operate.

We recognize our broad responsibility embodied in the expectations of civilized society, South African Constitution by way of the Human Rights Commission Act and in the Universal Declaration of Human Rights to use our influence to promote and protect human rights and freedoms by establishing clear ethical standards for ourselves and foster similar standards in all third parties who act with us or on our behalf.

Our Code of Business Conduct and Ethics articulates the principles and standards by which we operate in support of our commitment to good business practice. Inherent in the Code is our belief that countries and communities in which we operate should benefit from our presence and our behavior, specifically our compliance with laws. The Code, however, does not articulate fully our position on human rights and this policy seeks to articulate those elements.

As a minimum, ACI will strive to ensure that its operations are consistent with the legal principles applicable in all countries in which we operate. This policy sets global minimum standards and will apply in all countries including those where the requirements of local legislation are less stringent.

Scope

The ACI Human Rights policy applies to all ACI employees and employees of subsidiaries and joint ventures where ACI has a controlling interest. In joint ventures where ACI does not have overall control, the leaders and managers of those businesses are strongly encouraged to adopt the same or similar standards. If any human rights issues arise in joint ventures we will work actively with the business leaders to address them.

Management

This policy is fully endorsed by the ACI Executive Management and the Advisory Board is the sponsor of this policy. Members of the ACI Executive Management will be responsible for implementing the human rights policy and are accountable for its outcome.

Monitoring

Any breach of the human rights policy is also a breach of the ACI Code of Business Conduct and Ethics. As such, all breaches will be reported through the breach reporting process and reported to the Audit & Risk Committee. The Committee will monitor breaches. The Committee will also receive reports on compliance with this policy. Breaches of this policy will be dealt with in accordance with the ACI internal investigation procedures and disciplinary policies.

Equal Opportunity

At ACI we encourage the uniqueness of individual contribution within a team environment. All our employees have the right to expect that their basic human identity and dignity are fully respected in the workplace and we reject any form of unfair discrimination. We celebrate cultural and individual diversity and embrace the differences across our many world-wide operations. We believe our diversity gives us a competitive advantage.

ACI does not discriminate against any employee or applicant for employment because of race, color, religion, ethnic or national origin, gender, sexual orientation, age, disability or veteran status. This applies to recruitment, hiring, training, promotion, disciplinary practices and other terms and conditions of employment. Discrimination against any employee or applicant for employment is a serious violation of equal employment opportunity laws and of ACI’s Code of Business Conduct and Ethics. It is the responsibility of every supervisory employee to ensure that discrimination does not occur and for every employee to report violations of this policy, our Code of Business Conduct and Ethics or the law.

Health, Environment and Safety

ACI is committed to ensuring the health, safety and well being of our employees and people living and working in communities abutting our facilities. Our employees are expected to comply fully with company policies and to adhere, at a minimum, to the applicable health, environmental and safety legal requirements of their host country.

Harassment and Violence

ACI is committed to providing our employees with a nondiscriminatory work environment free of any type of harassment per company policy and the law. Supervisory employees must investigate all complaints of harassment and employees are advised on their responsibility to report violations. The company will take appropriate disciplinary actions for violation of policy or law.

All verbal and physical threats of violent behavior are unacceptable and should be reported. Every report of violence or threat of violence will be investigated. Employees who engage in violence or threats of violence will be subject to disciplinary action and may be subject to criminal prosecution.

Rights of Employees

ACI does not make use of any form of forced or compulsory labor. We respect the right of employees to leave the company giving reasonable notice. We will not employ children under the age of 17. Where young people under the age of 18 work for ACI, a special responsibility devolves to the company to protect and promote their interests to ensure that they are only employed under circumstances that protect them from physical risks. For any ACI employee under the age of 18 we will pay particular attention to their vocational training and development needs. We expect our suppliers and contractors with whom we do business to uphold the same standards.

We recognize the skills and contributions of all our employees and will ensure that they are justly and fairly remunerated to account for their contributions to the company. We will take all reasonable steps to recognize contributions individual employees make to the company. ACI will pay wages that exceed the legally required wages or, where no wage law exists, the local industry standard. ACI will comply with applicable local, state, national, supranational laws and industry practices on working hours.

ACI recognizes and respects employees rights and freedom to join organizations of their own choosing or to refrain from joining organizations. Employees who have chosen unions in accordance with applicable laws and regulations are entitled to bargain collectively through representatives of their own choosing. The company shall facilitate open communication and direct engagement between employees and management in those situations in which the right to freedom of association and collective bargaining are restricted under law. No associate shall be subject to dismissal, discrimination, harassment, intimidation, or retaliation due to his/her membership in a lawful workers association or union.

INITIAL ADOPTION: November 2008

AMENDED: May 2011

REVISED: August 2014

READOPTED: January 2017