Integrity is more than a value,  it is a foundational principle that guides our decisions, operations, and relationships. As a dynamic, forward-thinking company engaged in mining, renewable energy, and sustainable forestry, we are committed to building our reputation on a strong culture of ethics and responsibility from the ground up.

We believe that conducting business with honesty, fairness, and transparency is essential to earning and keeping the trust of our stakeholders, including employees, partners, customers, regulators, and communities.

BUILDING OUR ETHICAL FOUNDATION

Our Ethics and Compliance Program is designed to embed integrity into every level of our operations. This program includes:

  • Our Code of Ethics — a living document that outlines our expectations for ethical behaviour across all business units and geographies.
  • Ongoing ethics and compliance training for employees and contractors.
  • Confidential resources for reporting concerns or seeking guidance.
  • Clear expectations for ethical conduct from our suppliers and partners.

CODE OF ETHICS: A GUIDE FOR EVERYONE

The Global E.I. Trust Code of Ethics, first established in 2025, provides clear guidance for ethical decision-making. It is a critical tool for our employees, officers, board members, and partners as they navigate areas such as:

  • Environmental stewardship and sustainability
  • Anti-corruption and fair competition
  • Workplace conduct, harassment, and discrimination prevention
  • Human rights and labor practices
  • Health, safety, and operational integrity
  • Responsible sourcing and supply chain practices

We will regularly review and revise our Code of Ethics to stay aligned with evolving laws, best practices, and our company’s strategic growth. All updates will be transparently communicated.

ETHICS TRAINING: A SHARED RESPONSIBILITY

Ethical decision-making is a skill that can be strengthened through education. That’s why we provide:

  • Mandatory ethics training for all employees and new hires.
  • Annual compliance certifications for leaders and employees in sensitive roles.
  • Specialized modules tailored to roles in mining operations, forestry management, and renewable energy projects.
  • Real-world case studies to reinforce learning and promote critical thinking.

A SPEAK-UP CULTURE: WE ENCOURAGE REPORTING

Global E.I. Trust is committed to a culture of openness and accountability. Everyone — employees, contractors, suppliers, and stakeholders — is encouraged to speak up if they witness unethical conduct or have questions about the right course of action.

Concerns or questions can be reported anonymously and confidentially through:

  • The Global E.I. EthicsLine at [toll-free number]
  • Online submissions via [Ethics Reporting Portal] (available 24/7 in multiple languages)

These resources are managed independently, and all submissions are promptly reviewed by our Ethics and Compliance Team.

WE HOLD OUR SUPPLIERS TO HIGH ETHICAL STANDARDS

We are committed to ethical and sustainable practices not only within our company but across our global supply chain. Our Supplier Code of Ethics outlines our expectations in the following key areas:

  • Health and Safety: A safe and healthy work environment is non-negotiable.
  • Legal Compliance: Suppliers must adhere to all applicable laws and regulations in their jurisdictions.
  • Labor and Human Rights: Forced labor, child labor, and human trafficking have no place in our supply chain.
  • Environmental Responsibility: Suppliers are expected to minimize their environmental footprint and align with our sustainability goals.
  • Diversity and Inclusion: We encourage sourcing from a diverse range of businesses that reflect the communities we serve.

Non-compliance may result in review, corrective action, or termination of the business relationship.

RESPONSIBLE SOURCING AND SUPPLY CHAIN INTEGRITY

As a company operating in resource-intensive industries, Global E.I. Trust is especially focused on ethical procurementand risk management:

  • Our Responsible Sourcing Policy requires all materials and services to be evaluated not only for quality and cost, but for social and environmental impact.
  • Our Supply Chain Due Diligence Program identifies high-risk suppliers and ensures alignment with international human rights and environmental standards.
  • Our Wood and Resource Procurement Policy ensures that forestry resources are harvested in accordance with recognized sustainability and certification standards.
  • We conduct audits and assessments as needed and work with suppliers to improve compliance where gaps are identified.

We also comply with jurisdictional reporting requirements, such as the California Transparency in Supply Chains Actand Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

HUMAN RIGHTS: A GLOBAL COMMITMENT

Our Human Rights Policy is aligned with the UN Universal Declaration of Human Rights and integrated into our Code of Ethics. We take a proactive approach to identifying and mitigating risks in our operations and supply chain. This includes:

  • Regular employee and contractor training on human rights expectations
  • Supply chain mapping and risk assessments
  • Independent investigations of all reported violations
  • Transparent reporting to our executive leadership and board of directors

ACCOUNTABILITY AND CONTINUOUS IMPROVEMENT

We hold ourselves and our partners accountable. Employees who violate our Code of Ethics are subject to disciplinary action, up to and including termination. Suppliers who fail to meet our ethical standards may have their contracts reviewed or terminated.

As we grow, we will continue to evolve our ethics and compliance practices, striving to be not only compliant, but a leader in responsible business conduct.