Ivanhoe Mines : Fighting Against Forced Labour and Child Labour in Supply Chains, December 31, 2024
IVN.TO
Published on 05/30/2025 at 18:03
Table of Contents
About this report 1
About our business 3
About our policies and due diligence processes 5
About potential risks 9
About our remediation measures for lost income of vulnerable families 10
About our training 10
Assessing our effectiveness 11
Looking forward in 2025 11
Approval and attestation 12
Ivanhoe Mines Ltd. ("Ivanhoe Mines", "Ivanhoe", or the "Company") has prepared this Fighting Against Forced Labour and Child Labour in Supply Chains Report (this "Report") in accordance with Section 11 of Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Canadian Act") for the financial year ended December 31, 2024.
For purposes of the Canadian Act, this is a single report made under Section 11(2)(a) of the Canadian Act on behalf of Ivanhoe Mines, which includes information related to its associated material projects over which it exercises Control as defined in Section 10(1) of the Canadian Act.
This Report is also made by Ivanhoe and its relevant subsidiaries,1 further to Section 54 of the UK Modern Slavery Act 2015 (the "UK Act") for the financial year ended December 31, 2024. The Ivanhoe entities that have been assessed as being subject to section 54 of the UK Act are: Ivanhoe Mines UK Limited, RKR Mining Limited and Gardner & Barnard Mining UK Limited. The board of directors of each of these entities has approved this Report.
For the purposes of this Report, we have reviewed the definitions of modern slavery as outlined in both the Canadian Act and the UK Act. These definitions encompass a range of exploitative practices, including:
slavery, servitude, and forced or compulsory labour;
human trafficking;
sexual exploitation and forced marriage;
deceptive recruitment tactics;
debt bondage; and
child labour.
This is Ivanhoe Mines' first report in compliance with the UK Act, and our second under the Canadian Act. It outlines the measures we have taken to enhance our processes and improve our understanding of, and response to, the risks associated with modern slavery, child labour, and other human rights concerns in both our operations and supply chains during the financial year ended December 31, 2024. Table 1 details the sections of this Report that address the reporting requirements of the UK Act as well as the obligations under the Canadian Act.
Table 1: Reporting criteria and corresponding sections where requirements are addressed
The Canadian Act
The UK Act
Section
Pages
Identify the legal name of in-scope entities
Reference to in-scope entities
About our business
3
The organisation's structure, activities, and supply chains.
The organisation's structure, its business, and its supply chains.
About our business
3
Specifically targets forced labour and child labour in supply chains.
Broader in scope, addressing various forms of slavery,
including forced labour, human trafficking, and servitude.
About this report
1
The parts of the organisation's business and supply chains that carry a risk of forced labour or child labour being
used.
The organisation's part of its business and supply chain where there is a risk of slavery and human trafficking taking
place.
About potential risks
9
1 The Ivanhoe entities that have been assessed as being subject to section 54 of the Act are: Ivanhoe Mines UK Limited, RKR Mining Limited and Gardner & Barnard Mining UK Limited. The board of directors of each of these entities has approved this Statement.
The organisation's policies and due diligence processes in relation to forced labour and child labour. The steps the organisation has taken to prevent and reduce the risk that forced labour or child labour is used at any step of production of goods in its business and supply chain.
The organisation's training provided to employees on forced labour and child labour.
The organisation's policies in relation to slavery and human trafficking. The organisation's due diligence processes in relation to slavery and human trafficking in its business and supply chains. The steps the
organisation has taken to assess and manage the risks of slavery and human trafficking taking place identified in parts of its business and supply chain. The organisation's training and capacity building about slavery
and human trafficking available to its staff.
About our policies and due diligence processes
5
In particular, measures taken by the organisation to
remediate any forced labour or child labour. Measures taken by the organisation to
remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains. Where no measures have been taken to remediate the above, a statement by the
organisation confirming the same.
Requires a statement that indicates the steps taken to ensure modern slavery is not present in supply chains, including due diligence processes.
About our policies and due diligence processes
5
How the organisation assesses its effectiveness in ensuring that forced labour and child labour are not being used in its business and supply chains.
The organisation's effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it
considers appropriate.
Assessing our effectiveness
11
This Report describes the steps taken by Ivanhoe Mines to assess and address Ivanhoe's risks with respect to forced labour and child labour ("Modern Slavery Risks"). In this Report, unless otherwise stated, references to "Ivanhoe Mines", "Ivanhoe", the "Company", "we", "us", "our" and similar expressions include our operations and projects (the "Sites"). Monetary amounts in this Report are expressed in US dollars, unless otherwise stated.
Ivanhoe's material Sites over which it exercises Control, contained in this Report are as follows:
Material projects
Existing under the laws of
Ownership
Activity
Ivanplats Proprietary Limited (also known as the Platreef Project)
The Republic of South Africa
64%
A multi-generational Platreef palladium-rhodium-nickel-platinum-copper-gold Project which is still in construction. Commencement of production is planned for 2025.
Kipushi Corporation (also known as the Kipushi
Mine)
The Democratic Republic of the Congo
62%
A historic zinc-copper germanium-silver-lead mine which commenced production in June 2024.
In addition, for this Report, the Company has elected to include information on its third material project, which it operates as a joint venture.
Material projects
Existing under the laws of
Ownership
Activity
Kamoa Copper SA (also known as the Kamoa-Kakula Copper Complex, or Kamoa-Kakula)
The Democratic Republic of the Congo
Joint venture in which Ivanhoe holds an effective 39.6%
Began producing copper concentrate in
May 2021 and has since undergone multiple phases of expansion. The ongoing Phase 3 expansion will further increase copper production at Kamoa-Kakula, which is already one of the largest copper mines in the world. The construction of the on-site direct-to-blister copper smelter is in
the final stages with commissioning expected in 2025.
Ivanhoe Mines is a Canadian mining company, listed on the Toronto Stock Exchange (TSX), with its head office located in Vancouver, British Columbia (TSX: IVN) and principal properties located in Southern Africa. The Company's registered and records office is located at 606 - 999 Canada Place, Vancouver, British Columbia, V6C 3E1, and its African head office is located at 82 on Maude, Second Floor, 82 Maude Street, Sandton, Johannesburg, South Africa, 2146. The Company currently has three material assets, which have been included in the scope of this Report ("Sites"), namely:
The Kamoa-Kakula Copper Complex (or "Kamoa-Kakula"), a large, high-grade, stratiform copper deposit, was discovered by the Company beyond the previously known western limit of the Central African Copperbelt, in Lualaba Province, DRC. Kamoa-Kakula began commercial production of copper concentrate in July 2021. Kamoa-Kakula is currently undergoing its third phase of expansion, and is among the world's largest copper mines, as well as being one of the lowest carbon-intensive major copper mines.
The Platreef Project, a thick and high-grade palladium, nickel, platinum, rhodium, copper and gold deposit on the northern limb of the Bushveld Complex, in Limpopo, South Africa. The Platreef Project is a tier-one, multi-generational asset, which is currently undergoing construction, with the Phase 1 concentrator expected to commence cold commissioning in 2025, with first production at the end of 2025.
The Kipushi Mine, a historic, ultra-high-grade, underground, zinc-copper-germanium-silver-lead mine in the Central African Copperbelt, in Haut-Katanga Province, DRC. The Kipushi Mine achieved first production in June 2024.
The Company conducts its operations through control of its material projects, as well as through a joint venture at Kamoa-Kakula. The following diagram depicts the corporate structure of the Company as of December 31, 2024:
Figure 1 Simplified Company structure (refer to the Annual Information Form for a detailed indication of the Company and its material and other key subsidiaries and joint ventures - https://www.ivanhoemines.com/wp-
content/uploads/IVN_AIF_31-Dec-2024-vF.pdf).
As of December 31, 2024, Ivanhoe Mines (including through its subsidiaries, and excluding employees of the Kamoa-Kakula joint venture) had approximately 1,751 employees, almost all of whom were employed on a permanent basis. Five of its employees were based in the head office in Vancouver, Canada. The remaining employees work at the Company's corporate offices in Johannesburg, London and Beijing, as well as at the Company's projects in the Democratic Republic of the Congo and South Africa. In addition, as of December 31, 2024, the Company's Kamoa-Kakula joint venture had approximately 6,531 employees.
Approximately 40% of the Projects' employees (excluding the Kamoa-Kakula) are unionized, and an additional 91%, while not unionized, are covered by a collective bargaining agreement. Kamoa-Kakula's multi-party collective bargaining agreement comprises several trade unions, where 52% of the employees are unionized and 94% are covered by the collective bargaining agreement.
Ivanhoe Mines' stewardship and governance is the responsibility of our Board of Directors (the "Board"), who fulfils its mandate either directly or through delegation to its five committees at regularly scheduled meetings, or as required. Each committee of the Board oversees risks within their functional area. The Sustainability Committee is primarily responsible for establishing and overseeing our sustainability and environmental, social and governance ("ESG") risks and opportunities, practices, policies, performance and disclosures across a number of areas such as human rights (including Modern Slavery Risks), anti-corruption, security practices, health, safety and well-being, employment practices, non-discrimination and equal opportunity, responsible sourcing, climate governance, water management, tailings management and local economic development.
The Company's President and Chief Executive Officer chairs the executive committee and bears the ultimate management responsibility for ESG risk management, together with the Chief Operating Officer and Chief Financial Officer. Sustainability is regarded as a cross-functional discipline and the Executive Vice President, People, as well as the Vice President, Sustainability are also responsible for convening and coordinating employees in other corporate functions or business units (legal, supply chain, human resources ("HR"), communications etc.) to support programs or activities that reinforce Ivanhoe's focus on ESG matters, inclusive of risk management. The Vice President, Sustainability heads a dedicated corporate sustainability team which interfaces with the Sites and oversees operational implementation of the Company's sustainability strategy.
Most the Company's procurement activities occur through a procurement function/department at each Site. Each Site is required to abide by the applicable in-country regulatory framework as well as the Company's Responsible Sourcing Policy which is aligned to the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct and the Act. We have also developed a Responsible Sourcing Standard which, in 2024, was distributed to all our sites for consideration and incorporation into site-relevant procedures. Implementation of this standard will be monitored as part of our ongoing due diligence processes.
Our Sites each procure a wide range of goods and services to support their key operations and/or project phase activities, including construction, mining, processing and transportation. A small portion of our procurement activities are also attended to by various departments at the Company's corporate offices. These activities mainly include information technology and administrative-linked procurement, as well as the procurement of services from an array of specialist consultants.
The Procurement Department at each Site is responsible for procurement governance, with oversight from the Sites' Managing Director or General Manager, as well as the Commercial Finance Managers. In general, procurement is done by way of the Company's standard form contractual agreements, inclusive of the organization's general terms and conditions.
In 2024, together with the help of an external consultant, the Company progressed its efforts towards the development of a responsible sourcing toolkit, which will be embedded into the existing supplier portals (for more stringent supplier registration requirements) and procurement due diligence processes. This toolkit includes a sanctions screening process for new suppliers. In 2024, we rolled out an ESG supplier survey to a select group of suppliers, aimed at evaluating their policies, governance, and performance concerning human rights and environmental matters. Looking ahead, the Company plans to refine this survey and expand it to key suppliers and customers in 2025. Additionally, we intend to update our supplier risk identification methodology to support our ongoing due diligence and responsible sourcing efforts.
Due to the jurisdictions within which we operate, the Company recognises the importance of supporting local enterprises and suppliers by creating opportunities across the value chain. The majority of the Company's supply chain activities take place in the DRC and South Africa. When measured by value, the Company's total procurement expenditure was approximately $3.5 billion (on a 100% project basis) for the financial year ended December 31, 2024, with 69% attributed to the DRC, 18% to South Africa and the remainder to other African and global spend. Much of this expenditure was generated through the Company's support of local businesses and service providers.
Our ambition towards creating long-term shared value for our shareholders, stakeholders and society is underpinned by the World Economic Forum's ("WEF") four pillars for stakeholder
capitalism - principles of governance, people, planet and prosperity - which are aligned to the United Nations Sustainable Development Goals ("UN SDGs"). The Company has embedded eight priority SDG into our corporate strategy, reinforcing our commitment to advancing the 2030 Agenda.
Through the Company's policies, standards and procedures, we commit to upholding our responsibility to respect human rights, as guided by the United Nations Guiding Principles on Business and Human Rights ("UNGPs"), implementing measures to contribute towards responsible environmental stewardship at all of our projects, and implementing appropriate governance measures to operate responsibly and avoid involvement with bribery and corruption.
In our contracts, we require that our business partners and suppliers within our supply chain agree to comply with the Ivanhoe Mines Code of Business Conduct and Ethics, as well as with specific terms and conditions inclusive of relevant standards and policies.
The Company follows good international environmental, social, and governance practices in our sourcing and contracting of products and services, and when managing our relationship with business partners in our supply chain. As part of this, Ivanhoe acknowledges its role in the management of risks related to human rights and environmental violations, and governance-related infringements in our supply chain.
Together, the following corporate policies, which are either used directly by the sites or aligned with site-specific corresponding policies and/or procedures, form a framework of standards required of our Board of Directors, officers, employees, contractors and suppliers to ensure human rights are respected, and to identify and appropriately address Modern Slavery Risks in our operations and supply chains:
Code of Business Conduct and Ethics and Companion Booklet (the "Code") - describes our commitment to a culture of honesty, integrity, accountability and respect for our communities and provides guidelines, principles and policies for everyone to comply with. The Code applies to directors, officers, employees, consultants, contractors and advisors of the Company and its subsidiaries and covers issues ranging from compliance with laws, rules and regulations, conflicts of interest, corporate opportunities, confidentiality and Company assets, to insider trading, improper payments, fair dealing, health and safety, compliance with environmental laws, corporate disclosure and Company records, among other things. As a company subject to Canadian securities laws and the policies of the Toronto Stock Exchange, Ivanhoe is also required to establish whistleblower procedures relating to auditing and accounting matters which are also addressed in the Code.
Corporate Citizenship, Statement of Values and Responsibilities Policy - sets out the Company's commitment to conducting its operations and activities in accordance with its core principles. This policy reflects the obligations and partnerships that naturally accompany the various permissions that we receive to operate in countries and communities with divergent degrees of economic development. It establishes the Company's commitments with respect to responsible exploration and mining by being a good global corporate citizen through its support for human rights, social justice and sound environmental management. The policy reiterates the Company's commitment to fostering honesty, integrity and accountability throughout our business activities.
Human Rights Policy - promotes respect for human rights and the conduct expected from all personnel and partners in order to realize this commitment. This policy is designed to ensure proper understanding, and effective use and integration of the Company's human rights related management systems within the context of corporate- and site-level policies, international standards and Ivanhoe's culture of responsible and accountable corporate citizenship. Through
our commitment to the UNGPs, the Company aims to ensure that these principles are integrated throughout the policies and processes which are designed to identify, assess and mitigate human rights risks across our Sites and value chain. Through ongoing monitoring, reporting, and transparent dialogue with stakeholders, the Company commits to ensuring a responsible and ethical business environment and seek partnerships with entities that share our commitment. In 2024 the policy was updated to align with additional Good International Industry Practices (GIIPs) on vulnerable groups.
Responsible Sourcing Policy - promotes transparent, ethical and competitive purchasing, taking into account environmental and social considerations and objectives. Within this policy, the Company pledges to make reasonable efforts to identify, assess, and manage material human rights impacts that they cause, contribute to, or are directly linked to through their supply chains. With the oversight of senior management, this Policy is progressively integrated into existing business processes and procedures through collaboration and coordination across different functions in the Company's corporate offices and Sites, with a view to ensuring its full realisation.
Grievance Policy - promotes a healthy working environment where individuals are treated with respect and courtesy and feel comfortable to lodge grievances without the being victimized or subjected to discrimination when they submit or deal with grievances. The Company commits to resolve problems or where a member of staff feels that they have been unfairly or unreasonably treated and to provide members of staff with a reasonable and prompt opportunity to obtain redress of any grievance.
Anti-bribery and Anti-corruption (ABAC) Policy - reinforces the Company's commitment to maintaining high standards of professional and ethical conduct in line with our corporate values. It outlines the risks related to bribery and corruption, the responsibilities of Employees and Business Partners under anti-corruption laws and Company policies, and provides the tools and support needed to identify and address these risks.
Whistleblower Policy - establishes procedures for receiving, retaining, and addressing complaints related to accounting, internal controls, and auditing matters, in compliance with Canadian securities law. It also provides a confidential, anonymous channel for employees and third parties to report concerns about various issues, including questionable accounting or audit matters, intentional and unintentional violations of applicable laws or Company policies, bribery and corruption, and other matters which may negatively impact the Company's business and reputation. Access to the whistleblower hotline is available on the Company's website (https://secure.ethicspoint.com/domain/media/en/gui/35636/index.html).
Our policies are designed to ensure comprehensive alignment with international, regional, and national standards on responsible business conduct, supply chain due diligence, sustainability, human rights, and transparency. Specifically, they support compliance and integration of the following:
National laws in every country we operate in.
International human rights and labour standards, including the United Nations
Guiding Principles on Business and Human Rights (UNGPs), Voluntary Principles on Security and Human Rights (VPSHRs), International Labour Organization (ILO) conventions, and Canada's Forced and Child Labour Act.
Global responsible sourcing frameworks such as the OECD Guidelines, Conflict-Free Gold Standard, the London Platinum and Palladium Market (LPPM) and (London Metal Exchange) LME policies.
Environmental and social risk management principles such as the IFC Performance Standards and Equator Principles.
Transparency and sustainability disclosure standards, including Extractives Industry Transparency Initiative (EITI), and International Sustainability Standards Board (ISSB).
Market and listing obligations, meeting all compliance requirements of the Toronto Stock Exchange.
To manage our third-party risk management, Ivanhoe employs a third-party due diligence platform offered by London Stock Exchange Group (LSEG) Data & Analytics (formerly Refinitiv). This platform is used to screen suppliers on a risk-based approach for allegations and convictions of a variety of offences such as sanctions violations, bribery and corruption, child labour, forced labour, human trafficking, other human rights violations, fraud, money laundering, adverse media and more. This is part a management process consisting of:
Obtaining supplier references.
Comparing proposals at operations.
Submission of company legislative forms on an electronic supplier portal.
Utilising our detailed verification records from prior years.
Our due diligence approach is risk-based, with greater scrutiny for suppliers who appear to pose a potential risk.
Child and Forced Labour Policies have been developed and implemented at Kamoa-Kakula and the Platreef Project. Development of the policy for the Kipushi Mine is currently underway. These policies are also applicable to our suppliers and contractors, and our human resource procedures ensure the prevention of employment of minors.
Our supplier registration processes include screening for potential human rights risks, and our contractual provisions require that our suppliers abide by the Code, as well as other policies and procedures, providing the Company with the right to terminate the agreement in the event of a breach. We have also reviewed our contractual agreements and standard terms and conditions to include forced labour and child labour practices provisions.
We believe that trusted, effective grievance mechanisms play a key role in identifying and remediating social risks including human rights, modern slavery and loss of social licence to operate. We are committed to timeously and amicably resolving grievances. The Company regards a grievance as a notification, concern or complaint raised by an individual or group affected by our projects' activities averring that they have suffered some form of offence, detriment, impairment or loss as a result of our business activities and/or employee or contractor behavior.
The Company has devoted and will continue to devote appropriate time and resources to sharing project information, obtaining stakeholder feedback, addressing concerns, negating misinformation and resolving issues, to the best of our ability. To govern this process, the Company has implemented non-judicial grievance procedures at all of the projects, in line with the recommendations of the UNGPs. These grievance procedures serve as the formal channels through which stakeholders can notify the projects that offense was taken and guide the remediation process through specific and structured steps.
The external grievance procedure at each of our key projects is widely communicated to stakeholders, offering multiple channels for engagement and feedback, including in-person meetings, public or
community liaison sessions, community portals, phone, SMS, and email. Managed by the community relations teams at each project, grievances are recorded and tracked through a web-based stakeholder management system. We recognize that concerns and complaints may arise from both real and perceived impacts of our operations and approach all grievances with respect and care. Our grievance mechanisms are communicated through local platforms and accepted methods, ensuring a timely resolution process. While we aim to address all grievances internally, our system allows for escalation, and we respect the complainant's right to seek judicial remedies. We further analyze trends and root causes of issues raised and develop action plans to address them.
Where appropriate, stakeholders can also make use of the Ivanhoe Mines' corporate whistleblower mechanism, which was established to alert the Company of potential fraudulent or criminal activities. The whistleblower reporting mechanism is accessible 24/7 through a link available on the Ivanhoe Mines' website (available in English and French) or by phone (available in 150 languages). This is overseen by the Audit Committee, to encourage the Company's colleagues and stakeholders to raise concerns or report actual or suspected violations of law or policies. Whistleblower reports are confidential and can be made anonymously. For more information on this, please refer to our Management Proxy Circular (accessible through the following link: https://www.ivanhoemines.com/investors/document-library/#proxy).
In 2024, we introduced our updated Whistleblower Policy. Failure to comply with this policy by employees may result in disciplinary action, including termination of employment. For contractors, non-adherence may lead to the termination of their contracts.
Ivanhoe did not receive any modern slavery reports through its whistleblower process in 2024, nor through its site-based external grievance mechanisms. Despite receiving no complaints related to modern slavery, we continue to look for ways to strengthen the effectiveness of our grievance/complaint mechanisms. Recognizing that effective grievance mechanisms require ongoing refinement, in 2024 we conducted an independent review of the effectiveness of our grievance mechanisms at Kamoa-Kakula, Platreef and Kipushi. In addition, an independent review of the site-level stakeholder engagement practices was undertaken to assess the effectiveness thereof in line with the Company's policies, procedures and best practice guidelines.
As the Company has not identified any instances of the use of forced or child labour, we have not undertaken any related remediation efforts. In the event that we identify any instances of the use of forced or child labour in the future, we will take appropriate remediation measures suitable for the circumstances and in accordance with international and industry standards.
Ivanhoe is cognizant of and endorses the critical importance of remaining abreast of the risk landscape and the fast-evolving interplay between economic, environmental, geopolitical, societal and technological risk factors, both in terms of their likelihood of occurrence and potential impacts on our business. The Company also undertakes human rights risk and impact assessments, which consider the severity of adverse consequences from potential impacts to both people and the environment. In 2024, we conducted thorough Human Rights Impact Assessments (HRIAs) at our Platreef and Kipushi Projects and updated the 2022 HRDD at Kamoa-Kakula. These HRIAs, based on scoping reviews, stakeholder engagements, site visits, and document reviews, assessed human rights impacts across various areas, including employment, health and safety, security, social issues, and environmental concerns. In the future, we plan to hold workshops to discuss the HRIA outcomes and refine control measures, which will be integrated into human rights management plans for implementation over the next two years. In additional, Synergy Global Consulting (Synergy) updated their initial assessment of risks at Kamoa-Kakula, focusing on gender issues, such as discrimination, GBV, and sexual abuse, as well as contractor management, and security management (based on the Voluntary Principles on
Security and Human Rights (VPSHRs)). The VPSHR assessment involved consultations with security management, security forces, civil society organizations, and stakeholders. The assessment reviewed Kamoa's risk control policies and practices in relation to VPSHRs and provided recommendations for better alignment. The current human rights management plan at Kamoa-Kakula will be revised based on these 2024 findings.
Child labour in mining is commonly found in artisanal and small-scale mining activities (ASMs). Only the Kipushi Mine has ASMs in its surrounds. The Company actively engages with these ASMs and has launched several campaigns in the last few years to prevent the presence of children, as well as the exploitation of women, on these ASM sites.
In 2024, we commissioned an independent scoping study on ASMs, which provided several recommendations that are now being reviewed for implementation based on their relevance and priority. One of the key initiatives is the establishment of an ASM working group in 2025, led by a local facilitator, to ensure stakeholder involvement and fairness in determining eligibility for livelihood restoration related to the new tailings storage facility (TSF) area. In addition to our ongoing efforts to address child labour, Ivanhoe recognizes the critical importance of tackling gender-based violence (GBV) as a key human rights issue within our operations and surrounding communities. GBV, which often intersects with other forms of discrimination and exploitation, presents a significant risk to both our workforce and local populations. As part of our commitment to human rights, we actively assess the potential for GBV in our risk assessments and work to ensure a safe and inclusive environment for all individuals, particularly women, who may be vulnerable to violence, harassment, and discrimination. In line with our human rights strategy, we plan to integrate specific GBV-related controls into our management plans, further strengthening our efforts to foster a culture of respect and safety across all our operations.
We acknowledge that our tailings storage facilities (TSFs) also have the potential to impact on human rights if the risks associated with these facilities are not managed. In 2024, SRK Consulting conducted independent assessments of the Platreef Phase 1 TSF (still under construction) and the Kipushi TSF against the ICMM Conformance Protocol. The Company is working to implement the recommendations from these reviews to improve operations and GISTM compliance. Additionally, Knight Piésold performed a third-party audit on the Kamoa-Kakula TSF, finding no major issues and confirming good progress towards GISTM compliance.
The Company has not identified any instances of lost income for the most vulnerable families arising from our efforts to address Modern Slavery Risks. As we continue to assess and address such risks and if we identify any lost income for vulnerable families resulting from the actions we take in the future, we will take appropriate remediation measures suitable for the circumstances and in accordance with international and industry standards.
The Company acknowledges that ongoing due diligence and capacity building needs to be undertaken to ensure that all of our projects are aware of their role in supplier management, as well as the framework which is in place to support the Company's objective to source responsibly. As part of our ongoing commitment to sustainability, human rights training is incorporated into the Group's annual Key Performance Indicators, ensuring that human rights considerations are embedded throughout the organization.
In 2024, we carried out a groupwide sensitization on Ivanhoe's human rights and responsible sourcing policies. Key personnel participated in comprehensive training, which included sessions on the Global Industry Standard on Tailings Management (GISTM) and a workshop on the OECD guidelines, aimed
at enhancing understanding of responsible business practices. On-the-job training is also provided by our independent human rights experts, Synergy, to various heads of department as part of our ongoing human rights due diligence processes. We also launched extensive communication and training initiatives covering the Code of Conduct, anti-bribery and anti-corruption measures, and addressing harassment and discrimination. Our security providers are required to conduct annual training on the Voluntary Principles on Security and Human Rights (VPSHRs) to ensure adherence to our high standards, with plans for audits in 2025 to verify the effectiveness of this training.
Additionally, Kamoa-Kakula collaborated with the Lualaba provincial division of the Commission Nationale des Droits de l'Homme (CNDH), an independent human rights body, to train local communities. This initiative aims to empower communities with the knowledge and tools to defend human rights, through ongoing training on human rights concepts and the application of relevant laws.
To foster a safe and inclusive work environment, Ivanhoe launched GBV awareness campaigns across its workforce, focusing on respect, equality, and providing clear reporting mechanisms for incidents of harassment, discrimination, or violence. In 2024, the Company implemented harassment and discrimination training as part of its governance program. At the Site level, surveys and workshops with women at Kamoa-Kakula, Platreef, and Kipushi were conducted to understand their experiences and identify necessary safety measures. These measures aim to enhance the psychological, economic, physical, and sexual safety of women, in line with the international definition of GBV. Findings also highlighted the need for training men on recognizing and addressing GBV to support a safer workplace. Additionally, in August 2024, Platreef's Women in Mining committee launched a GBV awareness campaign in collaboration with various stakeholders, reaching over 200 employees and community members through workshops focused on recognizing, preventing, and supporting victims of GBV.
Through these initiatives, Ivanhoe remains dedicated to prioritizing the protection of human rights.
The Human Rights and Responsible Sourcing programs will continue to be embedded in 2025 and are enforced through both corporate and Site-level key performance objectives. Both programs include compliance to the Canadian Act and the UK Act. This process will provide an assessment of Ivanhoe's effectiveness in implementing processes to prevent and mitigate human rights impacts both within the organization, as well as in its supply chains. The outcome of this process will be a human rights action plan, the implementation of which will be monitored and evaluated both internally, as well as by an independent consultant to assess our progress and effectiveness.
Ivanhoe Mines is committed to continuous improvement in all aspects of our business operations. We acknowledge that elements of human rights and Modern Slavery Risks have the potential to appear in all areas of our business, and not just in our supply chain. It is therefore the Company's responsibility to take meaningful steps to engage at all levels within our business to educate our employees about these risks as well as Ivanhoe's strict stance against Modern Slavery Risks, in line with our Corporate Policies described earlier.
In addition, we are planning the following actions for 2025:
We plan to hold multidisciplinary workshops to review the draft Human Rights Impact Assessments (HRIAs) and refine the proposed controls for significant impacts. The finalized controls will be incorporated into human rights management plans for implementation over the next two years.
Implement the recommendations from the VPSHR assessment, including the development of a VPSHR management plan at Kamoa-Kakula. VPSHR training for all security contractors and the police is planned for the second quarter of 2025.
Stiving to ensure that all women across all Ivanhoe's projects and operations have access to an independent and confidential helpdesk to enable regular and open reporting of all GBV-related incidents, as well as the ongoing support and training for the women involved in managing these help desks.
Establish an ASM working group at Kipushi Mine to be led by a local facilitator.
Implementing the recommendations proposed from the review of the internal and external grievance mechanisms at each operation and project.
Commencing with immediate priority actions as identified from the independent GISTM assessment conducted at both Platreef and Kipushi as well as the third-party audit on the Kamoa-Kakula TSF, inclusive of a community sensitization and information campaign on tailings dam operation and management.
Refine the ESG supplier survey and expand to all key suppliers and customers. Additionally, we intend to develop a supplier identification procedure for material high-risk suppliers to support our ongoing due diligence and responsible sourcing efforts.
Development of ongoing workforce training and awareness building.
Further education for our employees related to available reporting mechanisms.
This Report was approved by the boards of directors of Ivanhoe Mines UK Limited, RKR Mining Limited, and Gardner & Barnard Mining UK Limited (collectively, the "UK Boards") pursuant to Section 54 of the UK Act on May 27, 2025. The UK Boards have delegated authority to me, Dr. Phumzile Mlambo-Ngcuka, in my capacity as Director of Ivanhoe Mines, and not in my personal capacity, to sign this Report on their behalf.
This Report was approved by the Board of Ivanhoe Mines pursuant to Section 11(4)(a) of the Canadian Act on April 29, 2025. In my capacity as Director of Ivanhoe Mines and not in my personal capacity, I make this attestation in accordance with the requirements of the Canadian Act. In accordance with the requirements of the Canadian Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for entity or entities listed above.
Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Canadian Act, as well as for the UK Act for the reporting year listed above.
I have authority to bind Ivanhoe Mines Ltd.
(Signed) Phumzile Mlambo-Ngcuka Dr. Phumzile Mlambo-Ngcuka Director
https://www.ivanhoemines.com [email protected]
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Ivanhoe Mines Ltd. published this content on May 30, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 30, 2025 at 22:02 UTC.