Health, Safety & Environment

1. Statement of Commitment

"Pexa Resources Ghana Ltd", "Pexa Resources", "Pexa", or "Pexa Ltd" is unconditionally committed to the health, safety, and wellbeing of every person who works for it or is affected by its operations. We are equally committed to operating in a manner that protects the environment and complies with all applicable environmental laws and regulations.

Safety is not a department or a function at Pexa. It is the personal responsibility of every individual on site, from the Board level downward. No production target, commercial deadline, or cost consideration justifies bypassing safety standards or environmental obligations. Where there is a conflict between operational pressure and safety, safety takes precedence always.

PEXA operates under the Minerals and Mining (Health, Safety and Technical) Regulations, 2012 (LI 2182), the Labour Act, 2003 (Act 651), and the Environmental Protection Agency Act, 1994 (Act 490). Compliance with these instruments is mandatory, not optional.

2. Roles and Responsibilities

2.1 Board of Directors

The Board is ultimately accountable for HSE performance. It receives a summary HSE report at each quarterly Board meeting covering: incidents and near-misses, status of corrective actions, compliance status, and any regulatory notices received. The Board approves the HSE budget annually and ensures adequate resources are allocated.

2.2 Chief Executive Officer

The CEO is accountable to the Board for HSE performance across all PEXA operations. The CEO ensures that HSE considerations are integrated into business planning and procurement decisions, and that serious incidents are escalated to the Board promptly.

2.3 HSE Officer

The HSE Officer is responsible for: maintaining HSE management systems and documentation; conducting site inspections and audits; co-ordinating incident investigations; liaising with the Minerals Commission, EPA, and other regulatory bodies; delivering HSE inductions and training; and maintaining the incident register and corrective action log.

2.4 Site Supervisors

Site supervisors are the primary HSE practitioners on the ground. They are responsible for: ensuring all personnel in their area are inducted before commencing work; conducting daily pre-shift safety checks and toolbox talks; enforcing PPE and safe work procedure compliance; stopping unsafe work immediately; and initiating the incident reporting process when required.

2.5 All Personnel

Every individual on a PEXA site is responsible for:

• Following safe work procedures and site rules at all times.
• Wearing appropriate PPE correctly for the task being performed.
• Reporting all incidents, near-misses, and unsafe conditions immediately to the site supervisor.
• Not commencing or continuing work if they believe it is unsafe.
• Participating in safety inductions, training, and toolbox talks.

3. Personal Protective Equipment

3.1 Minimum Site Requirements

The following PPE is mandatory for all personnel on PEXA operational sites, without exception:

3.2 Task-Specific PPE

Additional PPE requirements apply for specific tasks including:

• Drilling fluid mixing or chemical handling: face shield, chemical apron, chemical-resistant gloves, and eye wash station within reach.
• Working at height (above 1.8m): full body harness with appropriate anchor point.
• Confined space entry: specific atmospheric monitoring, communication, and standby rescue requirements apply — confined space entry procedure must be followed in full.
• Welding or hot work: welding mask, leather gloves, leather apron, and fire watch protocol.

3.3 PPE Condition and Supply

PEXA provides required PPE at no cost to personnel. Personnel are responsible for maintaining PPE in serviceable condition. Damaged or inadequate PPE must be reported and replaced before commencing work. Personnel found working without required PPE will be removed from site pending an investigation.

4. Safe Work Procedures

4.1 Pre-Shift Safety Checks

Before each operational shift commences, the site supervisor conducts a pre-shift safety check covering: equipment condition and pre-start checks, site hazard identification, weather and environmental conditions, personnel fitness for work, and availability of first aid equipment and emergency contacts. Results are recorded in the pre-shift log.

4.2 Toolbox Talks

Toolbox talks are brief (5–15 minute) safety discussions held at the start of each shift or before commencing a new high-risk task. They cover the specific hazards associated with the planned work, the controls in place, and any emergency procedures relevant to the task. Attendance is recorded.

4.3 Permit to Work

A formal Permit to Work (PTW) is required before commencing any of the following activities:

• Confined space entry.
• Hot work (welding, cutting, or grinding) in proximity to flammable materials.
• Isolation of electrical or mechanical energy (Lockout/Tagout).
• Excavation or trenching.
• Working at height above 3 metres.

The PTW must be approved by the site supervisor and retained on file. Work covered by a PTW must cease if conditions change from those described in the permit.

4.4 Drill Rig Safety

Specific safe work procedures apply to the operation of drill rigs, including the ATR-200 RC and any other equipment in Pexa's fleet. These procedures cover: rig setup and levelling; rod handling and makeup/breakout; sample collection and dust suppression; rig-down and move; and emergency shutdown. Written SOPs for each rig are maintained by the HSE Officer and must be reviewed by all rig operators at induction.

5. Incident Reporting and Investigation

5.1 Definitions

5.2 Immediate Response

1. Secure the scene and attend to the injured person. Administer first aid. Call emergency services if required.
2. Notify the site supervisor immediately. The supervisor notifies the HSE Officer and CEO within one hour of any recordable incident.
3. Preserve the scene for investigation. Do not disturb equipment, samples, or the site environment unless necessary for rescue or to prevent further harm.
4. Notify the Minerals Commission and EPA as required under LI 2182 and applicable regulations. Regulatory notification timelines apply.

5.3 Incident Investigation

All incidents at Lost Time Injury level and above, and all dangerous occurrences, require a formal root cause investigation. The investigation must be completed within ten working days and must identify: the immediate cause, the underlying/root cause, any contributing factors, and a corrective action plan with assigned responsibilities and completion dates.

Investigations are led by the HSE Officer with input from the relevant site supervisor. For fatalities or serious injuries, an independent investigator is appointed. The investigation report is presented to the CEO and summarised for the Board.

6. Environmental Management

6.1 Environmental Obligations

Pexa operates under the Environmental Protection Agency Act, 1994 (Act 490) and associated regulations, and in compliance with any project-specific environmental permit conditions. Pexa is committed to minimising its environmental footprint through the responsible management of energy, water, waste, and land.

6.2 Drilling Fluid and Cuttings Management

Drilling fluid (including water-based, foam, or air-based) and drill cuttings must be managed in a manner that prevents contamination of surface water, groundwater, or soil. Specific requirements:

• Sump design, lining, and capacity must be approved by the HSE Officer before drilling commences.
• Spent drilling fluid must not be discharged to surface water or natural drainage channels.
• Cuttings must be disposed of in accordance with the project environmental management plan and any regulatory conditions.

6.3 Fuel and Chemical Storage

Fuel and chemicals must be stored in designated bunded areas with a containment capacity of at least 110% of the largest individual container. Fuelling of plant must be conducted away from natural drainage. Spill kits must be located at all fuelling and chemical storage points. Any spill must be reported immediately and remediated in accordance with the spill response procedure.

6.4 Waste Management

Waste generated on PEXA sites must be segregated (general, recyclable, hazardous) and disposed of through licensed waste contractors. No waste may be burned or buried on site without specific regulatory approval. A waste manifest is maintained for all hazardous waste movements.

6.5 Environmental Incidents

Any significant environmental incident including a spill reaching surface water, damage to vegetation, or community complaints about dust, noise, or water quality must be reported to the HSE Officer within two hours. Regulatory reporting obligations to the EPA must be met. The corrective action process for environmental incidents mirrors that for safety incidents.

7. Emergency Preparedness

Pexa maintains a site-specific Emergency Response Plan (ERP) for each operational site. The ERP covers: emergency contacts (internal, emergency services, regulatory bodies); roles in an emergency; evacuation procedures; muster points; first aid resources; fire response; spill response; and medical emergency and medevac procedures.

Emergency drills are conducted at least twice per year on active sites. All personnel are briefed on the ERP at site induction. Emergency contact lists are posted at the site office, the rig, and at the first aid station.

8. Alcohol, Drugs, and Fitness for Work

This section is supplementary to the provisions in POL-01. In the HSE context, the prohibition on alcohol and non-prescribed substances is absolute and is a condition of site access, not merely a conduct standard. Random breath and substance testing may be conducted without notice. A positive test or refusal to test results in immediate removal from site and initiation of disciplinary procedures.

9. HSE Training and Competency

All PEXA personnel must complete the following before commencing work on site:

• General HSE induction (PEXA site rules, hazards, emergency procedures, and PPE requirements).
• Task-specific training relevant to their role (drill rig operation, chemical handling, first aid, etc.).
• Any regulatory or site-specific certifications required for their role.

Training records are maintained by the HSE Officer. Refresher training is conducted annually or when a person's role changes materially. First aid trained personnel must be present on every active site at all times.

10. HSE Performance Monitoring

The following metrics are tracked monthly and reported to the Board quarterly: