B2Gold : Grievance Procedure - February 23, 2021 (2 14 Grievance Procedure)

Published: 2025-06-18 13:35:06 ET BTO.TO

Published on 06/18/2025 at 13:35

GRIEVANCE PROCEDURE

Effective Date: February 23, 2021

(as updated June 18, 2025)

B2Gold Corp. (the "Company", and together with its subsidiaries, the "B2Gold Group") promotes fairness, respect, transparency and accountability as central values to the way it conducts its business and therefore also how it treats every director, officer, employee, consultant and contractor of the B2Gold Group (collectively, the "B2Gold Personnel").

This Grievance Procedure (the "Procedure") provides all B2Gold Personnel with a mechanism to raise workplace complaints and grievances potentially requiring the attention and intervention of the Human Resources department. These include but are not limited to:

Disputes between co-workers and/or supervisors that do not necessarily characterize harassment, bullying, discrimination, or other violation of Company's policies.

Potential violations of Company's policies through inappropriate behavior such as harassment, bullying, sexual harassment, discrimination, workplace violence, disrespectful behavior or retaliation.

Please note that respectfully expressing differences of opinion, offering constructive feedback and the exercising of supervisory authority (e.g., assigning work, conducting performance evaluation, imposing reasonable deadlines, placing someone on a performance improvement plan, etc.) are considered normal interactions during the course of employment and, typically, do not characterize violations of Company policies.

This Procedure is to be read in conjunction with the Company's Code of Ethics and Business Conduct, People Management Policy, Diversity Policy, Equitable, Diverse and Inclusive Workplaces Policy, Non-Discrimination and Harassment Policy and Supplier Code of Conduct.

This Procedure applies to all B2Gold Personnel and covers interactions within B2Gold's workplace which is defined as any B2Gold property, including mine and project sites, administration buildings, corporate offices, cafeterias, recreational facilities and camps. It also includes any location or worksite where B2Gold Personnel have been assigned or may access during work, any work-related social event (whether or not sponsored by the Company), conference, travel, and electronic communication (e.g., email, internal messaging systems, social media, etc.).

These are the responsibilities of the key stakeholders under this Procedure:

The Company:

B2Gold has the responsibility to address, investigate and respond to all complaints and grievances raised to its attention or made known to management by a member of B2Gold's Personnel.

B2Gold will (where appropriate) take corrective action necessary to address and remediate the issue, up to and including termination of employment or contract.

B2Gold Personnel should

Familiarize themselves with this Procedure.

Report, in a timely manner, inappropriate behavior such as harassment, bullying, sexual harassment, discrimination, workplace violence, disrespectful behavior or retaliation, even if the conduct is not directed towards them and they are only a witness to incidents of inappropriate behavior.

Report complaints and grievances in good faith. B2Gold Personnel may lodge valid, authentic grievances without any prejudice whatsoever to their employment. Grievances should, however, not be of a malicious nature and should be raised to improve workplace relations and not to cause unnecessary disruptions. Raising a complaint that is malicious, false or frivolous is considered a violation of company policies and may result in disciplinary action against the person who reported the complaint.

Follow the requirements defined in our Code of Ethics and Business Conduct and not retaliate in any way against those who raise concerns and grievances.

Respect and value individual differences, act respectfully towards each other and not engage in inappropriate behavior such as harassment, bullying, sexual harassment, discrimination, workplace violence, disrespectful behavior or retaliation.

Participate honestly and to the best of their abilities in any investigation and maintain confidentiality over the proceedings.

B2Gold Personnel in a supervisory role (e.g., supervisor, manager, director, executive) have a heightened duty and, therefore, they should:

Lead by example and provide support and guidance.

Refuse to condone misconduct and inappropriate behavior.

Identify, prevent and report situations of inappropriate behavior.

Take all complaints seriously and consult with Human Resources, Legal and Ethics & Compliance as needed to resolve complaints and grievance.

Human Resources department must:

Ensure that this Procedure is accessible to and understood by B2Gold Personnel,

Ensure grievances reported are documented, followed up, and (if needed) reported to the applicable members of senior management and the Board of Directors.

Ethics & Compliance department must:

Manage the Company's Ethics Helpline and ensure all issues of potential or real violations of the Company's policies and/or the law are duly investigated.

Collaborate with Human Resources to ensure all matters are followed up and investigated in an objective and independent manner.

This Procedure is intended to provide a mechanism to resolve complaints and grievances, preferably before they escalate into serious issues. The preference is to resolve issues in an informal and timely manner. As a result, the

Aggrieved individual(s) are encouraged to attempt to resolve disputes by communicating their concerns to the other party/parties involved in the grievance as, in some instances, the other party/parties may not be aware of the issue. In an attempt to resolve the grievance, the Aggrieved individual(s) may seek guidance and support from members of management, who are expected to, informally and in confidence, support the resolution of the issues in a prompt manner. Nonetheless, Aggrieved individual(s) are not required to confront the other party/parties involved in the grievance and may choose to formally report the issue and request support from Human Resources. This Procedure is also intended to explain the process that will be followed to assess and resolve grievances and complaints once they are formally raised to the Company.

In circumstances where informal resolution is not desired, appropriate, or has been unsuccessful, a formal grievance or complaint should be raised.

Who can raise a formal grievance or complaint:

The Aggrieved individual(s)

A direct witness to the issue

A member of management made aware of the issue

Please note that, in cases where the Aggrieved individual is an employee of a contractor, the issue must first be reported to their employer, who must in turn formally inform the Company.

How can formal grievance or complaint be raised:

Directly contacting the applicable Human Resources department

Directly contacting the Corporate Ethics & Compliance Department

Using the Ethics Helpline

Please note that reports through the Ethics Helpline may be done anonymously. However, following-up on the matter will require for those potentially involved (Aggrieved individual(s), alleged Offender(s)/Respondent, Witnesses, etc.) to be contacted. All reports will be managed on a need-to-know basis and all those involved in resolving the issue are required to maintain confidentiality. It is also worth noting that reports anonymously submitted through the Ethics Helpline, as well as reports submitted by a direct witness or member of management, will trigger a formal follow-up on the matter without the incident needing to be reported by the Aggrieved individual.

What should be included in the report:

The name of the Aggrieved individual.

The name of the alleged Offender/Respondent.

Date(s) and location(s) of the incident(s).

Description of the incident(s).

Name of witness(es), if any.

Any other relevant information, including documentary evidence (e.g., photos, emails, text messages, videos, etc.).

Please note that, regardless of how the issue is reported and the information provided, to ensure a fair and thorough follow-up, the alleged Offender/Respondent will need to be informed of the complaint and provided with an opportunity to provide a response.

Upon the receipt of a report, the Human Resources department may seek to resolve the situation by way of mediation between the Aggrieved individual and the Respondent. This is not compulsory and will only occur if the Aggrieved individual is willing to do so. The Aggrieved individual may have another B2Gold Personnel attend the mediation meeting for emotional support; the support person will play no part in the mediation. If mediation is unsuccessful or not acceptable to the Aggrieved individual, the complaint will be formally investigated.

The investigation will be conducted by the applicable Human Resources department with guidance and support from Management and the Legal department (if needed). If the nature of the complaint is such that it would be inappropriate for Human Resources to investigate, the Company may arrange for an alternative investigator such as the Ethics & Compliance and/or Legal departments. Where appropriate, the Company will engage an external party to conduct the investigation. Depending on the location and the terms of applicable collective agreement, where present, associated unions may participate in the investigation.

The timelines (indicated as working days) below are indicative and will depend on factors such as the nature of the grievance and the availability of individuals involved (e.g., considering work-rotations). Exceptions to the timeline may apply where either the Aggrieved or the alleged Offender is implicated or involved in another ongoing disciplinary or grievance process.

Stage

Duration

Actions

Assessment of report

5 days

Prompt review of report to assess whether it appears to have been made in good faith, whether there are sufficient reasons to warrant a formal fact-finding investigation and determine who will be responsible for the investigation (e.g., HR, external counsel, etc.)

The Company may take immediate measures to ensure the protection of its employee(s) and the integrity of the investigation through actions such as setting up working from home arrangements, re-assignment, suspension, etc. If the nature of the allegation warrants the removal of an employee from the

Stage

Duration

Actions

workplace during the investigation, paid leave may be provided.

Initiate Investigation

10 days

The investigation will be initiated in alignment with applicable regulations and best practices to ensure a timely, unbiased, thorough and fair investigation.

Alleged Offender/Respondent will be formally notified about the nature of the allegations(s) reported. To preserve the integrity of the process, information that may undermine the investigation results or result in intimidation or retaliation (e.g., name of witnesses, details about the incident, etc.) must not be disclosed to the alleged Offender/Respondent.

Schedule and execute interviews with relevant parties (aggrieved, witnesses, alleged Offender). All interviewees shall provide formal written statements and maintain confidentiality.

Investigation Report

5 days

A draft investigation report giving a full account of the facts that have been ascertained will be provided to appropriate management for review. The report must include documentary evidence such as written statements from those involved or any other documents or records relevant to the alleged offence.

The report will provide a conclusion (substantiated allegation vs. unsubstantiated allegations) to the investigation. The conclusion will be based on facts and will be drawn from a balance of probabilities (i.e., more likely than not to have occurred). If applicable, the investigation report will include recommendations to remediate the issues, including disciplinary action.

Possible investigation outcomes may include actions such as: issue of an apology, coaching & training, counseling, policy reviews and updates, reassignment, disciplinary action (e.g., written warning, unpaid suspension, termination, etc.). Cases where there are indications of threats, attempts or actual incidents of physical or sexual assault may be reported to the applicable authorities.

Management Review and Findings

5 days

Management will review the investigation report to ensure the investigation was done with due professional care, in an unbiased, fair and thorough manner.

Management will advise if further actions are required.

Disclaimer

B2Gold Corp. published this content on June 18, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on June 18, 2025 at 17:34 UTC.