Environmental, Social & Governance (ESG) Policy
PEXA Ltd is founded on the belief that responsible mining services and commercial success are mutually reinforcing.
Policy Details
Policy Number
POL-12
Version
1.0 (Inaugural)
Effective Date
2025
Policy Owner
CEO / Board of Directors
Approved By
Board of Directors
Review Frequency
Annual
Applies To
PEXA Ltd, all subsidiaries, joint ventures, and all contractors and agents acting on PEXA's behalf
Frameworks & Standards
1. Message from the Chief Executive Officer
"Pexa Resources", "Ghana Ltd", "Pexa Resources", "Pexa", or "PEXA Ltd" was founded on the belief that responsible mining services and commercial success are not in tension — they are mutually reinforcing. The communities we operate in, the environment we work within, and the governance standards we uphold are not external constraints on our business. They are the foundation of the trust that makes our business possible.
This ESG Policy sets out our commitments across Environmental stewardship, Social responsibility, and Governance integrity. It is not a document written to satisfy a lender's due diligence checklist — although it does that. It is a statement of what PEXA is, what we stand for, and how we hold ourselves accountable to our employees, clients, communities, investors, and the planet.
We are an inception-stage company, and we are realistic about where we are today. The targets in this policy reflect the ambition of where we intend to be as we grow. We will report on our progress annually, honestly, and with the same rigour we apply to our financial accounts.
This policy has been approved by the Board of Directors and applies to every person who acts in PEXA's name — from the boardroom to the drill site.
2. Purpose, Scope, and ESG Framework
2.1 Purpose
This policy establishes PEXA's Environmental, Social, and Governance framework — the principles, commitments, targets, and accountability mechanisms through which PEXA manages its ESG responsibilities. It is the overarching policy that governs PEXA's approach to sustainable business, and it takes precedence over all other PEXA policies in matters of ESG principle.
The policy serves three interrelated purposes: it articulates PEXA's values and commitments to external stakeholders; it provides internal guidance on ESG responsibilities and expectations; and it establishes the framework for ESG measurement, management, and reporting.
2.2 Scope
This policy applies to: all PEXA operations, projects, and administrative functions; all employees, directors, and contractors acting on PEXA's behalf; all supply chain relationships over which PEXA has meaningful influence; and all joint ventures or project structures in which PEXA participates.
2.3 Materiality
PEXA identifies material ESG topics through a structured materiality assessment, consistent with GRI 3 (Material Topics). Materiality considers: the significance of PEXA's actual and potential impacts on the environment, people, and economy; and the significance of those topics to the assessments and decisions of PEXA's key stakeholders (employees, clients, investors, communities, and regulators).
Pillar 1 — Environmental Stewardship
3. Climate Change and Greenhouse Gas Emissions
3.1 Policy Position
PEXA acknowledges the scientific consensus on anthropogenic climate change and accepts its responsibility to manage and reduce the greenhouse gas (GHG) emissions associated with its operations. PEXA aligns its climate approach with the Paris Agreement's goal of limiting global warming to 1.5°C above pre-industrial levels, and with Ghana's Nationally Determined Contributions (NDC) under the UNFCCC.
PEXA adopts the TCFD framework for climate risk disclosure, covering: governance of climate risks; strategy including scenario analysis; risk management processes; and metrics and targets.
3.2 GHG Inventory and Measurement
PEXA measures and reports GHG emissions in accordance with the GHG Protocol Corporate Standard, covering:
- Scope 1 (Direct): Diesel combustion in drill rigs, generators, and company vehicles; LPG use at operational camps.
- Scope 2 (Indirect): Grid electricity consumption at offices and any grid-connected facilities.
- Scope 3 (Value Chain): Significant upstream emissions from fuel production and transportation; equipment manufacturing; chemical production and transportation; business travel.
3.3 Emission Reduction Targets
| KPI / Target | Baseline (Year 1) | Year 3 Target | Year 5 Target |
|---|---|---|---|
| Scope 1 GHG emissions intensity | Baseline established | 10% reduction vs. Year 1 | 25% reduction vs. Year 1 |
| Fleet fuel efficiency | Baseline established | 8% improvement vs. Year 1 | 20% improvement vs. Year 1 |
| Idle time as % of total engine hours | Baseline established | Below 15% | Below 10% |
| Renewable energy use (camps) | 0% | 20% of camp energy | 50% of camp energy |
3.4 Climate Risk Assessment
PEXA conducts a climate risk assessment annually, covering physical risks and transition risks. Material climate risks are included in PEXA's Risk Register.
4. Water Management
4.1 Policy Position
Water is both essential to PEXA's drilling operations and a critical resource for communities. PEXA is committed to responsible water use, the protection of groundwater and surface water quality, and full compliance with the Water Resources Commission Act, 1996 (Act 522) and EPA standards.
4.2-4.4 Water Use, Groundwater Protection, and Effluent Management
PEXA measures water consumption, protects groundwater (casing/abandonment of boreholes), and manages drilling fluids via lined sumps with non-toxic additives. No spent fluids are discharged to surface water.
5. Air Quality, Dust, and Noise
PEXA implements controls such as water suppression for dust, speed limits, noise monitoring, and community notification to mitigate air quality and noise impacts from drilling operations.
6. Biodiversity and Land Management
PEXA acknowledges the "30x30" framework. Commitments include pre-mobilisation biodiversity screening, no drilling in legally protected areas, minimising site footprint, and site rehabilitation upon completion. Aligned with IFC PS6.
7. Waste and Chemical Management
Waste is managed per EPA requirements and the waste hierarchy. A Chemical Register is maintained (Act 928), chemicals are stored in bunded areas, and handling is strictly controlled.
Pillar 2 — Social Responsibility
8. Occupational Health and Safety
Safety is PEXA's highest operational priority. Aligned with ISO 45001:2018 and LI 2182. Our commitments include Zero Harm (zero fatalities, zero LTIs), meaningful near-miss reporting, and robust worker participation.
9. Labour Rights and Fair Employment
PEXA is committed to the ILO core Conventions and Ghana Labour Act: no forced or child labour, freedom of association, non-discrimination, living wage benchmarks, formal contracts, and regulated working hours. These apply to our operations and supply chain.
10. Diversity, Equity, and Inclusion (DEI)
Aligned with SDG 5 and SDG 10. Commitments include targeted recruitment of women, no gender pay gap, strict sexual harassment policies, and strong Ghanaian workforce localisation (90%+ non-specialist roles).
11. Community Relations and Social Licence to Operate
Aligned with IFC PS 1, 4, 5, and 7. Structured stakeholder engagement, Free, Prior, and Informed Consent (FPIC) principles, community grievance mechanisms, and a commitment to reinvesting net profits into community initiatives.
12. Human Rights
Grounded in the UN Guiding Principles on Business and Human Rights (UNGPs). Includes Human Rights Due Diligence (HRIA), no involvement with abusive security forces or illegal artisanal mining, and accessible remediation channels.
Pillar 3 — Governance Integrity
13. Corporate Governance and ESG Oversight
The Board of Directors bears ultimate responsibility for PEXA's ESG performance. ESG considerations are integrated into new client onboarding, procurement, capital allocation, and transactions.
14. Anti-Corruption, Ethics, and Business Integrity
Zero-tolerance for corruption (POL-01), beneficial ownership transparency (disclosed to Registrar General and in Annual ESG Report), absolute prohibition on political contributions, and commitment to tax transparency (paying our fair share).
15. Transparency and ESG Reporting
PEXA publishes an Annual ESG Report (GRI aligned) detailing performance across E, S, and G metrics. We support GHEITI compliance and commit to lender/investor reporting, targeting third-party assurance from Year 3.
16. Responsible Supply Chain
All significant suppliers are assessed for labour standards, HSE, environmental compliance, anti-corruption, and conflict minerals. Supplier corrective action plans are implemented, or relationships terminated for core violations.
17. ESG Targets Summary Dashboard
| Indicator | Year 1 | Year 3 | Year 5 |
|---|---|---|---|
| E: Scope 1 GHG intensity reduction | Baseline | 10% reduction | 25% reduction |
| E: Camp energy from renewable sources | 0% | 20% | 50% |
| S: % female workforce | Baseline | 25% | 35% |
| S: Ghanaian nationals in workforce | 90%+ | 90%+ | 90%+ |
| G: ESG metrics independently assured | Not yet | Limited assurance | Reasonable assurance |
18. ESG Implementation Roadmap
| Phase / Timeline | Key Milestones |
|---|---|
| Foundation: Year 1 (2025) | ESG Policy adopted; baseline data collection; grievance mechanisms operational; initial stakeholder mapping; first Annual ESG Report published. |
| Development: Years 2–3 (2026–27) | GHG inventory completed; TCFD assessment; supplier ESG assessments initiated; DEI targets embedded; limited assurance of key ESG metrics. |
| Maturity: Years 4–5 (2028–29) | TCFD-aligned disclosure published; ISO 14001/45001 certification; gender pay gap below 5%; renewable energy at 50%; reasonable assurance over ESG report. |
19. Grievance Mechanisms and Access to Remedy
PEXA provides formal, accessible, and protected grievance mechanisms for staff (POL-10) and stakeholders (POL-11), acting as the access-to-remedy channel under UNGP Pillar 3. Grievance data is reported to the Board quarterly.
20. Policy Review and Continuous Improvement
Reviewed annually by the Board. Continuous improvement means targets are raised, not maintained, as capacity grows. PEXA welcomes stakeholder feedback on its ESG commitments and performance.
21. Board Adoption and Acknowledgement
This ESG Policy was reviewed and approved by the Board of Directors of PEXA Ltd and takes effect from the date of approval.