CORPORATE RESPONSIBILITY

The Board acknowledges the importance of its continuing obligations and ongoing regulatory considerations for a main market company to include the requirements of the UK Listing Authority (UKLA) and the London Stock Exchange's admission and disclosure standards.
INTRODUCTION
Altyn plc is a UK based company with its main properties and interests in the Republic of Kazakhstan. The company is registered in England with its Registered Office in London (Registration Number 05048549). Its shares are listed on the Main Market of the London Stock Exchange. Altyn plc is the parent holding company controlling the Kazakhstan operations. The operating companies are subsidiaries based in the Republic of Kazakhstan which are 100% owned by Altyn plc. The mineral rights and mining licence at Sekisovskoye are held by ME BAURGOLD LLP whilst the processing plant is held and operated by MMC Altyn MM LLP. Further subsidiaries hold the other Altyn plc interests in the area. These Kazakh operating companies hold, administer and maintain the mining and exploitation licences and the other statutory instruments required by Kazakh legislation and regulation on behalf of the parent company, Altyn plc.

Altyn plc and its subsidiary operating companies are committed to contributing positively to the well-being of their employees, the environment, economy and society and believe that the long- term future of the Company is best served by respecting the interests of all stakeholders: employees, customers, suppliers and the wider community. Altyn plc will look actively for opportunities to improve the environment and to contribute to the wellbeing of their local communities, believing that responsible behaviour generates greater value for the stakeholders and earns us the trust of employees, customers and the local communities.


PRINCIPLES FORM THE CORE OF ALTYN PLC COMMITMENT
— Implement and maintain ethical business practices and sound systems of corporate governance.
— Integrate sustainable development considerations within the corporate decision-making process.
— Uphold fundamental human rights and respect cultures, customs and values in dealings with employees and others who are affected by the company's activities.
— Implement risk management strategies based on valid data and sound science.
— Seek continual improvement of the company's health and safety performance.
— Seek continual improvement of the company's environmental performance.
— Contribute to conservation of biodiversity and integrated approaches to land use planning.
— Facilitate and encourage responsible product design, use, re-use, recycling and disposal of the company's products.
— Contribute to the social, economic and institutional development of the communities in which the company operates.
— Implement effective and transparent engagement, communication and verifiable reporting arrangements with the company's stakeholders.
OBJECTIVES
The Stakeholder Engagement Plan (SEP) is a communication tool that will link and assist in the management and flow of information between Altyn plc and its stakeholders. Its primary aim is to enhance and encourage relations between all parties in an objective way and to clearly disseminate information about the company's plans, the project, its associated activities and the potential impacts, both adverse and positive, which may accrue, together with details about how this information flow will be achieved. Implementation of the plan will reduce the risk of ambiguity in decisions reached and increase the level of transparency displayed by providing information in language which will be accessible and easily understood by all interested stakeholders.

Stakeholder engagement provides an opportunity for the stakeholders to ask questions, discuss the programme and express any concerns they may have, so that Altyn plc is able to respond to comments received. Periodic monitoring and evaluation of the SEP will ensure that any necessary revisions are made in a timely manner to ensure that the programme remains relevant to the needs of both the company and the stakeholders. The SEP also defines a formal complaint procedure.

THE MAIN OBJECTIVES OF THE SEP ARE TO
— Facilitate open communication with all interested stakeholders;
— Build a robust and open relationship with the local community of Sekisovka;
— Provide publicly available information concerning the policies and plans of Altyn plc and details of project;
— Provide timely, relevant, accessible and easily understood information to stakeholders in an appropriate non-technical format, in both Kazakh and Russian languages;
— Open consultation with stakeholders to ascertain and discuss their opinions and concerns;
— Propose and establish formal and informal public consultation and participation procedures;
— Implement management and mitigation measures designed to reduce potential negative impacts while enhancing potential benefits;
— Establish accessible and effective systems for reporting, investigating and resolving grievances separately for both Altyn plc employees and the general community; and
— To establish stakeholder engagement as an integral part of on-going environmental and social impact assessment activity, vital in ensuring mitigation measures address impact and a priority as a basis for future engagement.
AVAILABILITY OF INFORMATION ON KEY IMPACTS AND MITIGATION
Although not required by Kazakhstan laws or the London Stock Exchange, a full Environmental Impact Assessment (EIA) and Social Impact Assessment (SIA) for the Sekisovskoye Mine has been prepared by Altyn plc, as part of its commitment to meeting best international practice.

The major potential environmental and socio-economic benefits of the project have been identified as:

— Creation and provision of new jobs due to the increase in overall mine production and the associated upgrades to the mine and the process plant;
— increased contributions to revenues from taxes and royalties;
— establishment of improved local infrastructure and upgraded social amenities;
— improved local economic conditions;
— encouragement for local entrepreneurship and the establishment of new small locally based businesses;
— long term rehabilitation of the Sekisovskoye working area with a sympathetically designed restored landform conforming generally with the existing undisturbed regional landscape;
— provision of improved biodiversity as part of the restoration and rehabilitation plan;
— agreed community development projects sponsored by the company; and
— by multi-skilling, re-skilling and education opportunities provided by employee training at the mine.

The major potential adverse environmental and socio-economic impacts of the project have been identified as:
— visual intrusion particularly on the local landscape;
— environmental health impacts due to dust, noise, and blasting vibration;
— production of greenhouse and noxious gases from mobile plant, blasting and other operations and functions;
— hydrological impact on the quality and quantity of local water resources;
— the social impacts of the recruitment of workers from outside the area;
— the social impacts of the exhaustion and closure of the open pit and its replacement with underground operations and the consequent potential loss of local jobs; and
— the socio-economic impacts of mine closure.

REGULATIONS AND REQUIREMENTS
IETF (2018 and 2017)
KAZAKHSTAN LEGISLATION
Background to the legislative obligations

Details of the requirements of Kazakh legislation are set out below.

In 2007, the Ecology Code came into force in Kazakhstan and it combined all main regulations related to ecology issues into one document, including duties and responsibilities of the authorized state bodies and of nature users as well as requirements on protection of natural resources. The Ecology Code requires that development activities and projects, which have direct or indirect impact on the environment and socio-economic issues, are subject to the Environment and Social Impact Assessment (ESIA) process. The ESIA process includes the evaluation of the impact on the environmental and social issues over the life of the project and requires that studies should establish baseline prior to commencement of works with regular update and review throughout the project's life. Monitoring of environmental and social impacts is required and is regulated by the terms of the licence and by periodic regulatory inspection by the authorities to ensure compliance. Emissions and other limits are set for a number of parameters such as water quality, air quality, soil quality, dust noise and vibration. The regulatory authorities expect and require full compliance with the achievement and fulfilment of all environmental limiting indices and licence requirements and any non-compliance or violations may lead to severe consequences, including cessation of operations and judicial penalty.

The international EIS and SIA preparation which has been carried out by Altyn are in addition to the statutory requirements of the Kazakh codes. Altyn has completed these studies to ensure that best practice methods are achieved at their operations. All new and/or additional operations acquired or taken up by Altyn will be conform to the standards adopted and being put in place at Sekisovskoye.

Engagement Requirements

The regulatory framework provided by the government of the Republic of Kazakhstan is relevant to our approach to stakeholder engagement. In this context, it is important to note that the government of Kazakhstan has ratified the UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters, also known as the Aarhus Convention. The Aarhus Convention requires the government to grant the public rights regarding access to information on the environment, including information on the environmental impacts of corporate activities, access to which is available only to the relevant environmental authority. This ecological information should be provided in advance to any affected party.

Accordingly to the legal regulations information disclosure and dissemination, as well as public consultation, are a part of the development process, especially if the project impacts the environment.
LEGISLATIVE ACTS RELATE TO PUBLIC PARTICIPATION IN DECISION MAKING WITHIN KAZAKHSTAN
Although not required by Kazakhstan laws or the London Stock Exchange, a full Environmental Impact Assessment (EIA) and Social Impact Assessment (SIA) for the Sekisovskoye Mine has been prepared by Altyn plc, as part of its commitment to meeting best international practice.

The major potential environmental and socio-economic benefits of the project have been identified as:

— Creation and provision of new jobs due to the increase in overall mine production and the associated upgrades to the mine and the process plant;

— increased contributions to revenues from taxes and royalties;

— establishment of improved local infrastructure and upgraded social amenities;

— improved local economic conditions;

— encouragement for local entrepreneurship and the establishment of new small locally based businesses;

— long term rehabilitation of the Sekisovskoye working area with a sympathetically designed restored landform conforming generally with the existing undisturbed regional landscape;

— provision of improved biodiversity as part of the restoration and rehabilitation plan;

— agreed community development projects sponsored by the company; and

— by multi-skilling, re-skilling and education opportunities provided by employee training at the mine.

The major potential adverse environmental and socio-economic impacts of the project have been identified as:

— visual intrusion particularly on the local landscape;

— environmental health impacts due to dust, noise, and blasting vibration;

— production of greenhouse and noxious gases from mobile plant, blasting and other operations and functions;

— hydrological impact on the quality and quantity of local water resources;

— the social impacts of the recruitment of workers from outside the area;

— the social impacts of the exhaustion and closure of the open pit and its replacement with underground operations and the consequent potential loss of local jobs; and

— the socio-economic impacts of mine closure.



INTERNATIONAL FINANCIERS' REQUIREMENTS
IFC/ World Bank Guidelines

The IFC Handbook "Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets" forms a principal reference setting out the principles and practice for the establishment of good stakeholder engagement focussing on stakeholder groups "external" to the core operation of the business, such as affected communities, local government authorities, non-governmental and other civil society organizations, local institutions and other interested or affected parties. It does not address engagement with suppliers, contractors, distributors, or customers, because interaction with these parties is a core business function for most companies and subject to national regulations and/or established corporate policies and procedures. The handbook stresses that the stakeholder engagement programme must be tailored to fit each individual project in order to achieve the programme's aims but notes that in order to foster transparency and openness stakeholder participation should be pro-active and should be commenced as early as practicable, rather than driven by the onset of problems. The relationships between company and stakeholders take some time to establish and early engagement provides a valuable opportunity to influence public perception and set an early positive tone with stakeholders. The early interactions with stakeholders can be used as a predictor of potential issues and risks, and to help generate ideas and alternative solutions on design questions.
It is Altyn intention to fulfil the recommendations of the IFC guidelines.