CODE OF BUSINESS

CONDUCT AND ETHICS

LAST UPDATED APRIL 2022

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 ABOUT US
CONTENTS INTRODUCTION
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A MESSAGE FROM OUR CEO

OUR PEOPLE
Who We Are. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Endeavour is committed to doing business in a safe, ethical, socially
responsible, and sustainable manner. Our growth and long-term viability are
Our Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
based on values that guide all our activities.
A Responsible Miner. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Our Code of Business Conduct and Ethics (the
Our Code of Business Conduct & Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 “Code”) reflects our purpose and values and
provides a clear framework for how we should
Speaking Up. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
conduct our business.
This Code applies to each of us as employees
Our People. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 and directors as well as to our contractors,

SAFETY & SOCIAL RESPONSIBILITY

• Human Rights. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 suppliers, agents, and consultants. It guides
our interactions with each other and with our
• Our External Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 stakeholders, including host communities and
• Employment & Inclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 governments.

• People & Partners Commitment in Practice . . . . . . . . . . . . . . . . . . . . . . . . 11 WE MUST LIVE AND

BREATHE THIS CODE
Safety & Social Responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
It is imperative that we all read this Code and
• Health & Safety. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 understand our responsibilities. We recognise
that the Code does not address every situation
• Environmental Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
that may arise. If you are in a situation that you
• Sustainability & Community . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 feel is not covered by the Code, or in any of our
policies or procedures, you should always feel
• Safety & Responsibility Commitment in Practice. . . . . . . . . . . . . . . . . . . . . 15
empowered to ask questions.
We encourage a transparent dialogue at
Ethical Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

ETHICAL CONDUCT
Endeavour, and we expect everyone to speak
• Working with Governments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 up and report any concerns that are not in
accordance with our purpose and values,
• Anti-Bribery & Anti-Corruption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 or this Code.
• Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 I am confident that each one of us will do
• Gifts, Travel & Entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 business in line with the Code regardless of
where we are or what we do. Working together
• Fair Competition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 as a team, we will be able to build sustainable
growth, create value for all our stakeholders and
• Money Laundering & Tax Evasion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
reinforce our commitment to doing business
• Fraud . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 ethically, safely, and responsibly.

DATA & PROPRIETARY INFORMATION

Data & Proprietary Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
• Inside Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
• Data Privacy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
• Confidential Information & Intellectual Property . . . . . . . . . . . . . . . . . . . . 21
SEBASTIEN DE MONTESSUS
• Company Property & Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 President and CEO
• Accurate Books & Records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

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 2 ABOUT US

WHO WE ARE
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

ABOUT US
Endeavour Mining is a leading global gold producer and the largest in
West Africa, with operating assets in Senegal, Cote d’Ivoire and Burkina OUR VALUES
Faso and a strong portfolio of advanced development projects and Endeavour operates across a
exploration assets on the highly prospective Birimian Greenstone Belt. number of different jurisdictions,
meaning that our operations

OUR PEOPLE
Endeavour is listed on the London and Toronto stock exchanges under
blend together a wide range
the ticker symbol “EDV”.
of nationalities, cultures and
abilities.
We embrace the diversity that this brings
to our company and the opportunity it
provides for enhancing our performance.
By promoting a culture based on respect
for all individuals, we strive to achieve a
common language that guides our decision-

SAFETY & SOCIAL RESPONSIBILITY

making internally and our relationships with
external stakeholders.

PROACTIVE

PARTNERS

ETHICAL CONDUCT
Working together for a shared goal
We are respectful and transparent with all stakeholders that have a vested
interest in our activities including our employees, contractors, host communities,
authorities and shareholders.
Mines Development Projects Advanced Exploration Birimian Greenstone Belt

PERFORMERS
Striving to be the best

1 We aim for excellence in all that we do. From a business perspective, we are
constantly looking for operational, technical, technological or financial
improvements to our operations. For our host communities, we always strive

Leading No. 1 LSE/TSX

to deliver on all our promises.

DATA & PROPRIETARY INFORMATION

Global Gold Producer in Listed
Producer West Africa PIONEERS
Thinking outside the box
We encourage innovation and learning from one another, as we constantly explore
ways to advance and improve our business.

PROACTIVE
6 2 ~5,600 Going beyond to achieve more
Mines Development Employees We are all contributors to our collective success, whatever our position.
Projects Our employees are our most important asset and therefore safety and health
at work will always be our first and foremost priority.

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 4 ABOUT US
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS
A RESPONSIBLE MINER
“I believe empowering the next generation of miners to develop
new skills, support their communities and create lasting value
for all of society is how we can continue to support the wellbeing
of our people and host countries long into the future.”
Sebastien de Montessus, President and CEO
OUR PURPOSE
Our purpose is to produce gold that provides lasting value to
society. As one of the largest producers of gold, our starting point
is protecting and promoting the people and places where our gold
comes from.
Our work is a partnership, helping to create resilient and self-sustaining communities,
where people are equipped with the skills, knowledge and expertise needed to prosper.
We recognise the responsibility and opportunity we have to support long-term social and
economic development within our host countries and communities.
We set high standards for our ethics and governance and are trusted to unlock the full
benefits of the material we mine for all stakeholders, from local communities, government
partners to our shareholders, who are invested in its discovery and production.
Mining, when done well and responsibly, is a catalyst for
economic growth and social upliftment, and we strive to
ABOUT US
work in partnership with our host governments to drive
the delivery of national sustainability and development
agendas.
Having a strong social licence to operate is vital for the business to operate
effectively. For Endeavour, this means mining responsibly, complying with
all local laws and regulations as a minimum, aligning with best practice
where we can, enhancing our positive impacts, managing, mitigating
and remediating our negative ones, and ensuring open and honest
OUR PEOPLE
communication regarding our impacts.
To maximise our impact, we have focused our actions on those areas where
we know we can have the most impact; social upliftment and economic
development, investing in our host countries and protecting the environment.
To do this we have identified a number of priority areas for our social
investment. These are health, education, economic development and access
to water and energy.
Our environmental priorities seek to address issues of both global and
local concern; addressing climate change and building resilience, water
stewardship, protecting biodiversity, and tackling the scourge of plastic
SAFETY & SOCIAL RESPONSIBILITY
waste, which is prevalent and problematic for our local communities.
To further amplify our efforts and extend our impacts beyond our immediate
communities, we established the Endeavour Foundation to implement
sustainability programmes at the regional and national levels.
Our approach is supported by a strong governance foundation, which
includes respect for human rights, delivery of zero harm, support for
employee well-being, diversity and inclusion, promotes responsible sourcing,
and is backed up by transparent disclosure through rigorous reporting.
To guide continual improvement on our performance and standards, we have
adopted the main sustainability frameworks and standards to address the
information needs of all our stakeholders: TCFD, GRI, RGMPs, SASB, LPRM
and we are a participant of the United Nations Global Compact.
Our commitments to our local communities and host countries are clearly
outlined in our Social Responsibility Policy. We have a social responsibility
to provide value to all our stakeholders, and to leave a positive impact
ETHICAL CONDUCT
wherever we operate. Endeavour’s Social Responsibility principles
seek to make a meaningful contribution towards improving
people’s lives in our host countries and are core to our
social license to operate. LINK TO
Our Social
Responsibility
Policy
DATA & PROPRIETARY INFORMATION
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 6 ABOUT US
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

How to make decisions with integrity

ABOUT US
OUR CODE OF BUSINESS according to the Code
CONDUCT & ETHICS The Code is designed to help us make ethical decisions. While the Code and our written polices
help us address the significant risks we face, it’s not possible to cover every eventuality. When facing
This Code represents our commitment to act in accordance with a difficult decision or situation not covered in the Code, we ask ourselves the following questions:
our values, policies and meet applicable legal requirements.
Our purpose Question Action
The Code has been adopted by our Board of Directors and applies to all employees,
officers, directors and contractors, suppliers, agents, and consultants, doing business
and values
with or on behalf of Endeavour. This Code requires we maintain the highest level of

OUR PEOPLE
No Uncertain Contact your supervisor or
integrity in our dealings with each other and it defines the minimum requirements and Is it legal?
provides direction and guidance in applying our values. Being a responsible company the site GM
means upholding the highest ethical standards and complying with all applicable laws and
regulations, industry practices and as well this Code and all other Endeavour policies. Yes
The intent with this Code is to:
Set expectations on how to do business responsibly, safely, ethically, and legally. No Is it consistent with Uncertain Contact your supervisor or
 emind us of values and key principles to consider when making decisions or when
R This Code our policies? the site GM
faced with a dilemma.
Yes

SAFETY & SOCIAL RESPONSIBILITY

Provide guidance on how to raise concern.
Where laws or regulations are less stringent than this Code or policies, we apply the
No Is it aligned with our values Uncertain Contact your supervisor or
higher standard.
and expectations? the site GM
We uphold the Code across the business by:
Identifying, assessing, and managing risks. Yes
Ensuring training is provided to all our employees, directors, and our main contractors. Our Group
Policies

Do not proceed
Communication on what is, and what isn’t acceptable behaviour. No Have I assessed all the Uncertain Contact your supervisor or
risks involved? the site GM
What are my responsibilities?
Everyone at Endeavour has a responsibility to act with integrity and take personal Yes
responsibility for his or her conduct, ensuring that our behaviour, decisions, and actions
are consistent with, and guided by the values and requirements covered by this Code,
No Uncertain Contact your supervisor or
our policies and applicable laws and regulations. Each one of us is responsible for Is it the right thing to do?
understanding and applying the requirements of this Code, and for reporting any actual the site GM

ETHICAL CONDUCT
or perceived violations of the Code, policies or laws and regulations. Compliance with the Laws and
Code, policies and laws and regulations is mandatory. Yes
regulations

No Would the action look Uncertain Contact your supervisor or

What happens if I breach the appropriate to those
outside Endeavour?
the site GM

Code or our policies?

Yes
This Code and policies reflect our values and how each of us should act.
Endeavour takes breaches of the Code and policies very seriously.
Depending on the gravity of the breach, consequences may range from No Could I justify my actions Uncertain Contact your supervisor or
a warning to termination of employment. to friends and family? the site GM

DATA & PROPRIETARY INFORMATION

Yes

No Will I still feel good Uncertain Contact your supervisor or

about my decision in
the site GM
a week’s time?

Yes

Proceed

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 8 ABOUT US

Our managers and supervisors

ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

ABOUT US
We expect our leaders across the business to be a strong role model for acting with
integrity and promoting a safe, responsible, and ethical culture. As a leader we believe that
you must:
L ive Endeavour values and act in accordance with the Code and policies.
Endeavour encourages a culture of openness where you can raise concerns
L ead by example, by modelling ethical decision-making. and views and be confident that you will be supported by the management.
T alk to your team about ethics and integrity and be clear that you expect work to be You must report any behaviour that violates our policies, standards or this
done ethically. Code including fraudulent, unethical, or illegal financial activity.
 reate an environment where everyone feels trust and are comfortable asking questions
C Always raise your concerns with your manager, supervisor or via our whistle blower system. Endeavour

OUR PEOPLE
and reporting issues. takes concerns seriously and handles them promptly. Reporting your concerns allow us to address them
proactively, prevent any further misconduct and limiting negative financial, reputational and other impacts.
T ake concerns seriously and address them appropriately.
 e attentive and report any violations of the Code.
B

Our business partners How to raise your concern?

We value our relationships with any third parties by being fair, open, and transparent in our It is important that you feel you can report issues without fear of retaliation of any kind.
dealings with them. In turn, we expect them to share our commitment to ethical, safe and It takes courage to speak up when something is not right. We understand that speaking up
responsible business practices. Our third parties include our suppliers, vendors, and other may make you uncomfortable or anxious and that is why we do not tolerate retaliation.
counterparties. We expect that all reports are done in good faith, and you may choose to raise your concern

SAFETY & SOCIAL RESPONSIBILITY

on an anonymous basis.
Endeavour conducts due diligence on all third parties to ensure that we only engage with
business partners that share same commitment to ethical business practices and conduct The confidentiality of those involved will be respected. Your identity will only be shared where
as we do. it is necessary to do so in order to address the concern or is required by law.
We seek to ensure that third parties maintain: Our people are our most important asset, and we want you to feel supported in speaking up,
• Lawful business practices. LINK TO and there are several ways you can do this.
• Safe, healthy and fair workplace. Our Supplier Code We encourage you to first discuss your concern with your manager or supervisor.
of Conduct
• Zero tolerance for human rights violations. In addition to your manager or supervisor, you can report your concerns to:
These requirements are supported through communication and training. All third parties • Your mine General Manager
must sign a compliance certificate to confirm that they comply with Endeavour Policies, • The Head of Internal Audit
which are also included in our Supplier Code of Conduct.
• Any Executive Committee member
We may terminate or decline to renew the contract of any third party who breaches the
You can also leave a note of your concern at a submission box at your mine site
law, the Code or Endeavour’s relevant policies.
(anonymously, if you wish).
24-hour WhistleBlower hotline:

ETHICAL CONDUCT
•W
 e also have an independently run phone and web-based service to which you can
report your concerns.
• It is important that you feel you can report issues without fear of dismissal, disciplinary
action or retaliation of any kind.
• T hose reporting in good faith will not be charged, disciplined, demoted, suspended,
threatened or discriminated against.
LINK TO
WhistleBlower Hotline 24/7 Our Whistleblower
Policy
The hotline is independently managed by a third party and available
24 hours a day, 7 days a week:

DATA & PROPRIETARY INFORMATION

Phone: Email:
Côte d’Ivoire, Mali, Burkina Faso, Senegal: endeavourmining@integritycounts.ca
Call Collect / Reverse Charge: +1-604-922-5953 Website:
North America Call Toll Free: +1-866-921-6714 integritycounts.ca/org/endeavourmining
United Kingdom Call Toll Free: 0-800-092-3586

What’s the process when you make a report

When a report is received of a potential violation of the Code, the Legal Department will
investigate it and take appropriate action. Endeavour expects all employees to cooperate with
investigations and act in a transparent manner. The Legal Department will report on a quarterly
basis to the Audit Committee of the Board of Directors on any received Code violations.

INTEGRITY COUNTS
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OUR PEOPLE
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS
Our people are the most important contributor to our success. We believe that a
diverse workforce is essential for a successful business. We treat our people fairly
and with respect, and ensure they have the opportunity to develop their careers
to match their potential. Endeavour is committed to doing business ethically and
takes zero tolerance approach to all forms of modern slavery.
HUMAN RIGHTS
ABOUT US
We must respect, and work to, uphold and advance human rights LINK TO
in everything that we do. Our Human
Rights Policy
We respect the human rights of all our stakeholders, as defined in the United Nations (UN)
International Bill of Human Rights and respect those rights wherever we operate.
We expect our suppliers to adhere to the same human rights standards as we do. We have
zero tolerance for any form of child labour or slavery, including forced labour. We work hard to
ensure that our supply chains comply with international standards and that we do not cause,
or are complicit in, human rights abuses, either directly through our activities or through our
business relationships.
OUR PEOPLE
Our commitment to human rights is set out in our Human Rights Policy, which is reviewed
and updated annually. We report on human rights-related grievances to the Board as part of
our quarterly whistleblower reporting mechanism. We also expect our business partners to
share our commitment to human rights and we leverage our business relationship to advance
human rights.
OUR EXTERNAL COMMITMENTS
We support the United Nations Guiding Principles on Business and Human Rights.
SAFETY & SOCIAL RESPONSIBILITY
 e align our security and human rights policies and procedure to the Voluntary Principles
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on Security and Human Rights (VPSHR) and we are in the process of becoming formal
members of the VPSHR.
We support the UN Universal Declaration of Human Rights.
We are a member of the UN Global Compact.
The security procedures are reinforced by risk assessments and incident reporting
mechanisms, as well as training for our security staff and contractors.
EMPLOYMENT & INCLUSION
Fair work, in fair conditions, for fair pay.
We believe all employees have a right to a fair and inclusive working environment.
Our people are offered attractive terms of employment with competitive remuneration and
career development opportunities. Remuneration is gender neutral, determined by expertise,
experience and performance and is regularly reviewed against our peers in the industry. LINK TO
ETHICAL CONDUCT
Our Harassment
We are committed to respecting the labour legislation of the countries in which we operate.
Prevention Policy
We support the International Labour Organisation’s fundamental principles and recognise the
rights of employees to choose whether to belong to a union and to seek to bargain collectively.
Our approach to employee representation is based on trust and transparency, respectful
dialogue, and constructive, peaceful resolution.
We value diversity and are committed to a work environment that treats all employees
and partners with respect and dignity, regardless of race, gender, nationality, ethnic origin,
disability, religion, age or sexual orientation We do not tolerate bullying, intimidation or
harassment of any kind in our workplace. LINK TO
Our commitment to a fair and inclusive working environment is set out in our Diversity Our Diversity
Policy and Harassment Prevention Policy which are reviewed and updated annually. Policy
DATA & PROPRIETARY INFORMATION
PEOPLE & PARTNERS COMMITMENT IN PRACTICE
We act honestly and with integrity and are accountable for everything we do.
We communicate with respect and integrity.
 e recognise the benefits of having employees from diverse backgrounds who can bring
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fresh perspectives and experiences to the way we conduct our business.
 e consider criteria that promote diversity, including with regard to race, religion, colour,
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sex, sexual orientation, age, national or ethnic origin or physical handicap.
We work together as a team.
We watch out for our own, and one another’s mental and physical well being.
We don’t tolerate discrimination, bullying and harassment of any kind.
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SAFETY & SOCIAL HEALTH & SAFETY

ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

LINK TO

ABOUT US
Keeping our people safe must always be our foremost priority. Our Health &

RESPONSIBILITY
At Endeavour, we follow a simple approach to health and safety. We believe that all Safety Policy
occupational injuries and work-related illnesses are preventable, and that everyone can
return home safely at the end of each day. We call this “Zero Harm”, and this ambition
guides our behaviour, our actions and is codified in our Safety & Health Policy.
We are committed to a strong safety culture that requires visible leadership from all levels
of the line management, a high level of engagement from employees and contractors
and a focus on hazard identification, risk analysis and risk management. Our leaders
are accountable for implementing the local standards and procedures and ensuring that

OUR PEOPLE
supporting systems are in place. Our people receive training that enables them to carry out
their tasks safely and in accordance with our health and safety policies and procedures.
Each of us is responsible for working safely, including, complying with applicable
occupational health and safety laws and regulations, and caring for the health and safety
of our colleagues. Our employees have the right to refuse unsafe work. No-one should
commence any task that they consider unsafe or where the hazards cannot be controlled.
We expect others that we work with, including contractors, consultants, agents, and
suppliers, to adhere to our health and safety requirements.
Our leaders must provide an environment where everyone feels safe to report any threats
to their own safety, or the safety of others. We have a responsibility to report the work

SAFETY & SOCIAL RESPONSIBILITY

of our colleagues if we think they are putting their health and safety – or that of others –
at risk.
We also have a zero-tolerance stance to drug and alcohol use on site, and regularly
conduct drug and alcohol screening and random testing across our operations.
Our commitment to health and safety is set out in our Safety & Health Policy which
is reviewed and updated annually.

ENVIRONMENTAL PROTECTION
At Endeavour, we know that being responsible stewards of the
environment is critical to our long-term success as a business.
We also recognise that gold mining and its associated processes
can have an impact on the natural environment.
We are committed to managing, mitigating and minimising the impacts of our

ETHICAL CONDUCT
operations on the environment, which is also something our stakeholders expect from
us. We recognise the potential impacts of climate change on our operations and our LINK TO
communities and work to address these. Our Environmental
Policy
Our business principles including our approach to environmental management are based
on a ‘Zero Harm’ philosophy. This philosophy underpins our Environmental Policy, which
compels us to:
 ctively comply with all applicable environmental laws, regulations, and other
A
requirements for environmental management.
 lign with relevant industry standards relating to the management of environmental
A
risks, including ISO14001 standards and the International Cyanide Management Code.

DATA & PROPRIETARY INFORMATION

 stablish and maintain management systems to identify, monitor and control the
E
environmental aspects of our activities.
 ake resources available to meet our reclamation, environmental and mine closure
M
obligations, including progressive rehabilitation, and we will consult with our local
communities and key stakeholders as part of our mine closure planning.
 ork with local representatives in the communities in which we operate to educate the
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community on the environmental obligations associated with our activities.
Conduct regular internal and third-party audits to monitor, measure and evaluate

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the effectiveness of our environmental management systems, and will communicate the resettlement of communities and where it is unavoidable, we consult closely with the
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

findings to the Technical, Health & Safety Committee of the Board of Directors, and, affected population. Our approach towards resettlement is aligned with the Resettlement Action

ABOUT US
where appropriate, to external stakeholders. Plan (RAP) which is drafted by external experts in line with both our own Resettlement and
Compensation guidelines and International Finance Corporation (IFC) Performance Standards.
 ork with local community representatives to educate our host communities on the
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We respect community collaboration and ensure economic livelihood following resettlement.
nature of our impacts, how we manage them, our environmental obligations, and our
performance. Endeavour believes that our mines can serve as a positive catalyst and foster long-term
economic development and social benefit.
 ork to continually improve our environmental performance over time, including with
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regard to increasing our energy efficiency and reducing emissions and waste, and to Endeavour supports the UN Sustainable Development Goals (SDGs) and strives to make a
promote sustainable development in the areas in which we operate. meaningful contribution to their achievement.
 ssess our biodiversity impacts and develop management plans with the goal of
A

OUR PEOPLE
minimising deforestation and other biodiversity and land access impacts and ensuring SAFETY & RESPONSIBILITY COMMITMENT
no net loss of critical habitat.
IN PRACTICE
 anage our hazardous and non-hazardous waste, including safe transport, storage,
M We stop work, and stop our colleagues working, if there is an unsafe situation.
and handling, and will seek to reduce and recycle where possible.
We asses the health and safety risks and implement adequate procedures.
Design, govern, and manage our tailings facilities in line with industry good practice.
We implement safe working conditions and provide a safe and trustworthy equipment.
 ontinuously monitor the quantity and quality of the water used in our processes and
C
practice responsible waste water disposal. We implement standards to be applied by everyone and train people on how to work safely.

Engage with our host communities to ensure sustainable and equitable access to water.

SAFETY & SOCIAL RESPONSIBILITY

Work proactively to manage our carbon reduction strategy.
We seek to minimise our environmental footprint, mitigating any adverse impacts,
and to promote sustainable development in the areas in which we operate.
Our external environmental commitments include:
Align our annual reporting with the Task Force on Climate-related Financial Disclosure (TCFD).
Align with the Global Industry Standard for Tailings Management.
Be a member of the UN Global Compact.

Feasibility
Environmental and Social Impact Assessments (ESIAs) are conducted to understand
site specific environmental and social impacts and risks. The ESIA is used to inform the
development of site specific environmental management systems (EMS) and environmental
management plans (EMP).

ETHICAL CONDUCT
SUSTAINABILITY & COMMUNITY
Endeavour recognises that local communities are at the heart
of the livelihood of our operations and are fundamental to our
day-to-day work.
We are committed to building strong relationships and proactively engaging in dialogue
with local communities and institutions, as well as the government at a local, regional and
national level. In our relationship with local communities, we respect and promote human
rights within our area of influence. This includes respect for the cultural heritage, customs
and established rituals.
Our work is a partnership, helping to create resilient and self-sustaining communities,

DATA & PROPRIETARY INFORMATION

where people are equipped with the skills and expertise needed to prosper. We support
community development programmes with a special focus on education, vocational
training, health and sustainable income-generating projects. We seek to establish dialogue
and lasting relationships with these communities at a very early stage. We design and
implement effective local grievance mechanisms and remediation processes in particular
towards vulnerable groups.
The development or expansion of a mine sometimes necessitates the relocation of local
communities and people away from their homes, farms, and land. We seek to avoid

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ETHICAL CONDUCT WORKING WITH GOVERNMENTS

ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

ABOUT US
Long lasting, productive relationships with government are critical
to our success and ability to operate. However, we must ensure
that when we engage with government or political bodies, it is done
appropriately.
• We do not bribe or in any way attempt to gain an unfair business advantage.
•W
 e respect every country’s political process and do not favour any political party, group
or individual.
•W
 e do not make any type of financial contributions to any political campaign, political

OUR PEOPLE
party, political candidate, or any affiliated organisations with the intention of obtaining
a business or any other advantage in any of the countries in which we operate.
We recognise the freedom of our employees to support political parties or candidates.
These political activities must never be done on company time or using company
resources, or in the name of Endeavour.
LINK TO
ANTI-BRIBERY & ANTI-CORRUPTION Our Anti-Bribery
and Anti-Corruption
We have a zero-tolerance approach to bribery and corruption, Policy
enshrined in our Anti-Bribery and Anti-Corruption Policy (ABC Policy)

SAFETY & SOCIAL RESPONSIBILITY

which sets out the framework for ensuring we conduct our business
in an honest and ethical manner, reflecting the highest standards
of integrity.
Our Compliance Team and Audit Committee ensure that we conduct our business in
compliance with all the relevant anti-bribery and anti-corruption legislation, including the UK
Bribery Act of 2010, the Canadian Corruption of Foreign Public Officials Act (CFPOA), the
US Foreign Corrupt Practices Act (FCPA), and anti-bribery and anti-corruption local laws.
We expect our contractors, suppliers, and business partners to comply with our ABC Policy,
which is included in our Supplier Code of Conduct. In addition, we have an anti-bribery and
anti-corruption clause in all our supplier contracts and undertake vendor due diligence as
part of our supplier onboarding and contract renewal process.
We do mandatory annual bilingual anti-bribery and anti-corruption training for all directors,
executives, managers, and employees in positions where the risk of corruption is elevated.
This equips our teams with the necessary knowledge to identify and respond appropriately
to risks of corruption

ETHICAL CONDUCT
DATA & PROPRIETARY INFORMATION
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18 ETHICAL CONDUCT

CONFLICTS OF INTEREST MONEY LAUNDERING & TAX EVASION

ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS

We must always act in Endeavour’s best interest and avoid any situations
that may give rise to, or even appear to be, a conflict of interest.
All business decisions must be made objectively, free from personal favouritism and based upon a
good faith belief about what is best for Endeavour.
Conflict situations may arise when an employee or director has financial or other personal interests
that affect, could affect, or have the appearance of affecting, their judgement, objectivity, or
independence, when making business decisions.
Common examples of actual, perceived, or potential conflicts of interest include:
ABOUT US
We don’t accept money or other assets if we become aware
LINK TO
they derive from criminal activity. Our Sanctions
Third parties may exploit us to engage in money laundering and tax evasion. Policy
We all need to be vigilant and take the necessary steps when we notice suspicious
transactions, requests or illegal activity by others so that we can protect Endeavour
and ensure we aren’t used by others to launder money and facilitate tax evasion.
All third parties must undergo due diligence and we can only do business with third
parties that have been approved. There are red flags for possible money laundering
and tax evasion that we must be vigilant about and promptly report to the VP

OUR PEOPLE
• Holding outside positions, including directorships. Group Controller, such as when a business partner:
• Holding investments directly or indirectly in businesses that work for or on behalf of Endeavour. •W
 ants to pay in cash.
• Receiving benefits such as gifts or entertainment that may influence the decision to engage a •W
 ants to pay in a different currency to that of the invoices.
supplier or other third party. •W
 ants to receive funds into an offshore account or a bank account in a different
•O
 ffering jobs to close relatives or friends. country from where business is conducted.
•P
 ursuing or awarding Endeavour business opportunities for any personal gain or for the benefit of •W
 ants to receive or pay funds into or from multiple bank accounts, or thorugh
close relatives or friends. a third party.

You must take steps to ensure that nothing you do conflicts with our responsibilities to Endeavour
or jeopardises your ability to make objective and impartial business decision in Endeavour’s

SAFETY & SOCIAL RESPONSIBILITY

best interest. Any actual or potential conflict of interest must be reported and managed in
a transparent manner. FRAUD
Endeavour does not engage in fraudulent and corrupt conduct.
GIFTS, TRAVEL & ENTERTAINMENT Regardless of your position at Endeavour, you must say No! to anything that sounds
or looks suspicious or illegal and have the courage to speak up when you see
We must exercise sound judgment and moderation when exchanging
something that just doesn’t look or feel right.
business courtesies.
Giving and receiving gifts, hospitality and travel can build strong working relationships between
Endeavour and those we do business with. But gifts, meals, or trips that are extravagant or lack
transparency or a legitimate purpose may be viewed as bribes or as simply inappropriate.
• When we offer or accept gifts, hospitality, or travel, we make sure they are reasonable, appropriate,
and have a legitimate business purpose.
• We don’t give or accept cash gifts, or cash equivalent gifts, such as gift card, certificate or voucher.
• We do not solicit gifts, hospitality or travel from third parties, or put them in a position where they
feel obligated to provide something in order to do business with us.

ETHICAL CONDUCT
• We don’t ask a third party, like an agent or supplier, to give gifts, hospitality, or travel on our behalf.

FAIR COMPETITION
We are committed to the principle of fair competition.
We compete ethically and respect all applicable competition and antitrust laws across the globe,
which prohibit certain practices considered detrimental to free and fair competition. We all want to
succeed – but that success must always be within the law and in line with our purpose and values.
Anti-competition laws differ from country to country and can be complex, and violation of laws may
give rise to sanctions including fines, penalties and business restrictions. To ensure compliance with
anti-competition laws we must:

DATA & PROPRIETARY INFORMATION

• Never obtain information about our competitors, suppliers, or customers through improper means,
nor communicate false information about our competitors.
• Avoid discussing with our competitors confidential matters such as production, sales, investments,
suppliers, or proposed mergers or acquisitions when the information relating to these matters has
not been made public.
• Avoid relationships with our competitors that could create the appearance of collusion or
impropriety.

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DATA & PROPRIETARY
ENDEAVOUR MINING | CODE OF BUSINESS CONDUCT AND ETHICS
INFORMATION
INSIDE INFORMATION
Inside information means information of a precise nature
that has not been made public, which includes information
about products or processes, pricing, marketing strategies,
vendor lists, non-public financial reports, and information
about asset sales, mergers and acquisitions.
All initial media enquiries received should be immediately directed to VP – Investor
Relations and nobody should communicate with the media in response to such
enquiries if they have not been given this responsibility (regardless of seniority).
Inside information is not to be released to employees (unless they are already
on the insider list in relation to the matter in question, see below). If employees
or others working for Endeavour need inside information for the performance of
their function, their name should be placed on an insider list maintained by the
Company Secretary, and they should acknowledge in writing their duties and
responsibilities relating to such information. After this procedure has been followed
the person concerned may receive the inside information.
You are an “insider” because you have access to non-public information. You must
not deal in Endeavour’s securities until the information is made public. You must
not share the information with anybody else, including family members.
If you breach these rules, you will have committed a serious offence. You could
be fined, lose your job or even go to prison. You may also trigger obligations on
Endeavour or sanctions against Endeavour.
The Company has adopted “Rules on Share Dealing” which sets out the rules on
dealing in the Company’s shares and to which insiders are subject.
DATA PRIVACY
We only collect and handle the personal information of our
colleagues, shareholders, business partners, suppliers,
customers and associated family or next of kin when needed
for legitimate business purposes.
We respect the rights each of us has to review, update and correct our information.
We only share personal data with others when there is a legitimate business or
legal need to do so. We ensure that those receiving personal data understand the
importance of keeping the data private.
When we work with others who may see or process our data, we make clear the
importance we place on privacy and the standards we require them to meet.
CONFIDENTIAL INFORMATION &
INTELLECTUAL PROPERTY
ABOUT US
We protect and respect the business value of information and
ideas, whether they belong to Endeavour or another company.
• We use best practices to protect access to confidential information, and avoid
discussing it in common spaces, or with colleagues who don’t need to know it.
•W
 e do not use confidential information for non-Endeavour business use, and we
maintain confidentiality even if we stop working for Endeavour.
•W
 e protect our intellectual property (including patents, copyright, trademarks, and
trade secrets) and closely monitor for unauthorised use of our intellectual property
OUR PEOPLE
by others.
•W
 e respect the confidentiality and intellectual property of others, such as
our suppliers and competitors, and do not use others’ information without
authorisation.
•W
 e do not use or copy third-party copyrighted materials, like software, graphics,
and videos, without a license.
COMPANY PROPERTY & RESOURCES
We are responsible for safeguarding Endeavour resources.
SAFETY & SOCIAL RESPONSIBILITY
We use company resources and funds to do our jobs every day.
These resources belong to Endeavour, and we have a responsibility to our investors
to use them responsibly:
•W
 e spend Endeavour’s funds wisely, and guard against waste and abuse.
 e do not obtain, use or divert Endeavour property or financial resources for
•W
personal (including family) use or benefit, or for any activity that causes a conflict
of interest, or is inappropriate or illegal.
 e are provided with electronic resources such as email, internet and telephone to
•W
help us do our jobs.
 e can occasionally use these resources for personal reasons if that use does not
•W
impact company systems, incur undue costs for the company or interfere with our
work duties.
 e use our corporate accounts and services, not personal accounts or services,
•W
for business correspondence and data.
ETHICAL CONDUCT
 e understand that business-related data is Endeavour’s property, and it may be
•W
accessed, preserved and reviewed in accordance with our polices and applicable
laws.
•W
 e do not alter, destroy or remove Endeavour property or records unless
authorised to do so.
ACCURATE BOOKS & RECORDS
We keep records that are clear, accurate, and complete.
Investors rely on accurate and comprehensible information to understand our
financial results and where we are headed as a company. Keeping accurate records
is critical to maintaining investors’ trust, making good business decisions, and
DATA & PROPRIETARY INFORMATION
meeting our regulatory obligations as a public company.
•W
 e honestly and accurately record and report financial transactions and business
information, following applicable laws, regulations, and accounting practices.
•W
 e are transparent about our commitments to our business partners, and our
written contracts reflect the actual economics of the deal.
•W
 e don’t make side agreements or other “off-the- book” arrangements.
•W
 e execute financial transactions only with appropriate authorisation and record
them in compliance with Endeavour’s accounting practice.
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 HEAD OFFICE
5 Young Street
London
W8 5EH
United Kingdom
T: +44 203 011 2723
CONTACT US
info@endeavourmining.com OPERATIONS OFFICE
Hotel Palm Club
Follow us: Croisement Boulevard Latrille et
rue du Lycée Technique
Abidjan
08 BP 872
Côte d’Ivoire
endeavourmining.com T: +225 27 22 48 99 00