Our mission is to develop a diverse portfolio of mineral projects, revitalize distressed and undervalued assets in remote areas and create thriving communities by unlocking

long-term business success through sustainable practices. Our approach is rooted in experience, integrity, open dialogue, and resilience.

Our Vision is to aim to drive a greener future by embracing our role as responsible producers of nickel and other critical materials.

Our Values define how we do business and our daily conduct. We must all take pride in both our achievements and how we achieve them. Adhering to our Values and the Principles outlined in our Code of Conduct (the “Code”) ensures not only that we will meet our business objectives but also a make a positive societal impact today, securing a favourable legacy for tomorrow.

Entrepreneurial and fast-paced decision making

We value dynamic thinkers who are quick on their feet and strategic in their planning. Ours is a culture of innovation and action, where ideas can take flight. Our collaborative spirit encourages teamwork and free-thinking and switching gears between brainstorming, execution, and continuous improvement is all part of the working day. As a smaller, private company, a world of opportunities to make a real difference await.

Resourceful People

At Solway, we foster a collaborative environment built on a foundation of shared goals. We seek talented individuals who resonate with our vision and can actively shape our strategies and operations. This approach ensures alignment and a culture that reflects the values we hold dear: creativity, adaptability, efficiency, open-mindedness, and tolerance. We value team players who thrive under pressure and demonstrate responsibility, understanding and professionalism in all situations.

Responsible business practices

We strive to be a positive force for transformation in the global mining industry, setting the example for responsible industrial practices. Our goal is to be a role model for corporate accountability, engaging stakeholders through open dialogue and actively participating in initiatives that promote sustainability and ethical business practices.

Ecosystem Integration

Ecosystem integration and systems thinking characterize our operating model. Together, these strategies suggest that we value a holistic view, looking at the big picture to optimize performance, sustainability, and effectiveness across all its operations. Mining operations are complex, and success requires close collaboration. Our approach relies on creative and logical thought, smart short and long-term decision-making, and balancing a variety of needs to ensure our projects are sustainable for all stakeholders.

Local autonomy under global rules

Our subsidiaries – strictly adhering to the rules and the underlying principles of our group-wide code of conduct – have significant freedom to make their own decisions and to try out new ideas, focusing entirely on achieving positive outcomes locally. Our team members are agile, adaptable, culturally sensitive, and emotionally intelligent. They have local insight and know how to execute business decisions, while being accountable to our group-wide strategy and policies.

Innovative mind-set

Solway attracts bold, tireless explorers who revel in new challenges and innovations in the mining sector, from unexplored areas to cutting-edge technologies. We pride ourselves on our entrepreneurial spirit, seizing overlooked or undervalued mining opportunities while rigorously managing risks. At Solway, individuals who are brave, curious, and committed, with a global perspective, thrive. Our culture is one that honours distinct, innovative approaches to advancing responsible mining.

Authenticity over perception

Our culture values expertise and practical experience communicated clearly and succinctly. We work on the basis of rigorous analysis and planning, avoiding baseless assumptions. Solway individuals combine practical wisdom, substantial knowledge, and forward-thinking professionalism. We value well-researched quantitative and qualitative reasoning to support significant decisions. In essence, we are professionals driven by data and evidence.

At Solway Investment Group, our purpose is to shape the future by responsibly harnessing the Earth’s resources. As a private international mining and metals group headquartered in Switzerland, we operate across diverse geographies, from the lush landscapes of Guatemala to the rugged terrains of Ukraine, and North Macedonia. Our focus lies primarily in nickel and copper production, but our purpose extends far beyond extraction. We are architects of sustainable progress, stewards of communities and guardians of the environment.

Our ambition is to set operating standards across our business that not only meet regulatory demands, but also the demands and expectations of our society, customers, and other stakeholders. We want to “do the right things” – deliver materials that are essential for a sustainable economy, and at the same time “do things right” by resourcing them responsibly.

We expect our Management to be fully committed to and to embrace the principles laid out in this Code of Conduct and lead by example. Compliance with our Code of Conduct is a key requirement for all Solway Group employees, contractors and associates working on behalf of Solway Group – every day and without exception.

The principles of this Code are intended to give practical direction. While our underlying policies, standards and procedures will be giving more detailed guidance, the Code of Conduct cannot set out prescriptive rules to cover every possible situation. This means to all of us that we always need to use good judgement, and whenever we are in doubt ask ourselves if our behaviour is truly in line with both the letter and spirit of these principles. We shall never hesitate to ask for advice if we are not sure what the principles of this Code of Conduct mean.

The integrity of our company is decisive for our common success. A violation of the principles stipulated in our Code of Conduct can be unlawful, damage the reputation of our company, or cause serious economic damage. Our business partners and stakeholders measure us based on our behaviour and how we deliver our products and services. Through an exemplary handling of the principles in this Code of Conduct we enable the long-term success of our company and a positive contribution to the future of our society and the planet.

Dan Bronstein, Chairman of the Board of Directors Solway Group

Purpose

The Committee’s purpose is to assist the Board in:

– Strategic support and supervision of Group’s on-going commitment to risk and compliance management matters in all their diversity at the level of the entire Group, including ethics, risk assessment and mitigation, compliance design, implementation, monitoring and evaluation procedures and other issues and concerns;

– Provide strategic guidance to design and implement the Group’s risk management and compliance comprehensive programs.

– Evaluate, mitigate, and monitor Risk and Compliance Matters that have a potential of severity, material impact or significant affection on the Group’s business activities, performance, and reputation.

– Oversee integration of strategically significant Risk and Compliance policies into the business operations and business strategy.

– Assist the Board with the review of technical, economic, compliance and business risk items with respect to projects of the Group that the Committee oversee including exploration, development, permitting, construction, and operation of the Group’s mining assets that are core to the Group’s strategy and growth.

Key Responsibilities and Duties

In addition to other duties as may from time to time be expressly assigned to the Committee by the Board, the Committee shall have the following responsibilities and duties:

– Strategically support the process of the design and implementation of the framework to monitor and detect unethical behavior, as well as to provide a strategic guidance on the systems of reporting and prevention of such activities.

– Evaluate risks of strategic significance and potentially material impact to the Group, approve respective mitigation plans and provide recommendations to the Board in this regard.

– Evaluate the enforcement of Company’s comprehensive compliance program, including policies, procedures, and guidelines that align with Company’s Code of Conduct, existing legal requirements and industry standards.

– Encourage integration of strategically significant risk and compliance matters into overall business strategy (e.g., recommend policies, practices, disclosures and strategy to Operations Team, Board and CEO).

– Approve independent investigations in relations to reported concerns and incidents, where appropriate, review investigation results, adjust to accepted standards with regard to the risk and compliance matters in the Group and approve remediation action plans to detect and prevent similar misconduct in the future.

– Engage with Company’s Communications Team to shape Group’s key compliance and ethics messages to employees, partners, suppliers and vendors, customers, investors, and other stakeholders as applicable in context of strategy and long-term value creation.

– Ensure sufficient resources are allocated to implement comprehensive compliance policies and measures, and to promote an ethical culture in the Company.

– Perform any other activities consistent with Charter, the Group’s accepted documents, and governing laws that the Board or Committee determines are necessary or appropriate.

– Report regularly to the Board regarding the execution of the Committee’s duties and responsibilities, activities, any issues encountered and related recommendations.

Composition

The committee nominees include four or five Members, including:

– The Chair of the Committee is Executive Director and Member of the Board.

– other members may be either Executive Members from the Management or independent non-executive members.

The committee’s decision formed by the opinions of the majority of all its members. In case even voting (2:2) the committee chair has a decisive vote. If only two members are present, in this specific case any question shall be decided unanimously.

Grievance is a formal complaint raised by an employee or group of employees within an organization. It typically relates to issues such as working conditions, unfair treatment, discrimination, harassment, or violations of company policies. Grievances are usually documented and submitted through a specific process, allowing the organization to investigate the complaint, address the concerns, and find a resolution. Handling grievances effectively is crucial for maintaining a positive workplace environment, ensuring fairness, and complying with legal and regulatory requirements.

Reporting concerns (Whistleblowing) refers to the act of an individual, usually an employee or someone closely associated with an organization, exposing information or activities within that organization that are deemed illegal, unethical, or otherwise not in line with established norms or regulations. Whistleblowers often report issues such as fraud, corruption, safety violations, or other forms of misconduct that can harm the public, employees, or the organization itself.

Whistleblowing can occur internally, where the individual reports the issue to a superior or a designated internal body, or externally, where the information is disclosed to outside entities such as regulatory agencies, law enforcement, or the media. Legal protections for whistleblowers vary by jurisdiction, but they are often in place to protect individuals from retaliation, such as being fired, demoted, or harassed, as a result of their disclosures.

Whistleblowing plays a crucial role in promoting transparency, accountability, and ethical behavior within organizations and industries.

Direct Dial:

Switzerland: 0800 561 024
Guatemala: 502 2458 1142
Northern Macedonia: +38970288700

English-speaking USA and Canada: 866-689-2680

E-mail: reports@syntrio.com (must include company name with report)
Fax: (215) 689-3885 (must include company name with report)