Social

Orla is committed to conducting our business in a responsible manner at all times, which means respecting the health and safety of our employees, encouraging diversity, tolerance, and mutual respect in the workplace, protecting the environment, respecting the human rights of our employees and the residents in the communities in which we operate, and contributing to their sustainable development. Our approach to the social factors is guided by our Corporate Social Responsibility Policy. We are committed to:

• Develop meaningful and effective strategies for engaging with all stakeholders;
• Consult with local communities to identify effective and culturally appropriate development goals;
• Establish grievance mechanisms, based on international best practices;
• Partner with credible organizations, including non-governmental organizations and local community groups;
• Identify and develop socio-economic opportunities that lead to sustainable prosperity in the communities and countries in which we operate;
• Integrate socio-economic, environmental, occupational health and safety, human rights and governance best practices into our business processes; and
• Make meaningful and sustainable contributions to host countries and local communities where we operate.

Our approach to health and safety is guided by our Environmental, Sustainability, Health & Safety Policy. We are committed to:

• Be responsible for maintaining a safe and healthy workplace by following health and safety rules and practices and reporting accidents, injuries and unsafe equipment, practices and results of investigations to the proper committee(s);
• Provide training to pursue an injury-free workplace and to take appropriate actions during emergency situations in the facilities;
• Ensure that violence and harassment in the workplace are specifically prohibited. Orla employees who are victims of, or become aware of, violence or harassment in the workplace are required to report such incidents;
• Ensure a safe work environment for our employees by reducing the risk of incidents in the workplace in which drugs or alcohol are a contributing factor, and deterring the use of alcohol, drugs and other substances where such use could negatively affect work performance and safety;
• Establish appropriate systems, standards, and procedures for health and safety management, reporting and compliance with applicable laws, rules, and standards of corporate conduct.

Orla strives to actively engage and maintain a positive relationship with our local communities based on open and honest communication and mutual respect.

At the Camino Rojo Project, through agreements signed with the ejidos of San Tiburcio, El Berrendo and San Francisco de los Quijano, we provide social support, scholarships, and food to the local communities. In the face of the COVID-19 pandemic, we have provided emergency food and personal protective equipment to local communities along with educational material on how to prevent the transmission of the virus. Our COVID-19 related support has been in partnership and collaboration with the local health authorities. We have also developed a community and social relations program in addition to the requirements under the ejido agreements. We have a full-time community relations team for the Camino Rojo Project.

We contracted an external expert consultant to conduct an independent assessment of social and community impacts of the development of the Camino Rojo Project, and to provide guidance on actions and policies needed to ensure that we obtain and maintain our social license to operate. Key community concerns were related to community employment and development, environmental contamination, water shortages, increased community populations, and local infrastructure. The results of this assessment are being incorporated into the project development and permitting plans and we have developed a Social Management System to mitigate key community-related risks.

In Panama at the Cerro Quema Project, we support the local communities of Tonosi and Macaracas by providing medical equipment, access to water, and by providing social and education support. We have a community and social relations program to receive and document community requests, concerns and resolutions.

For additional examples of ways we have supported local communities, see Overview of the Camino Rojo Project.

Orla is committed to the health and safety of our employees and strives to create and maintain a safe working environment by complying with all applicable health and safety laws, rules, and regulations. Orla acknowledges that there are safety risks associated with our business and, through proactive risk management, continuously aims to minimize and control these risks. We have a Health and Safety department with full time personnel at both Camino Rojo and Cerro Quema Projects and we have developed a comprehensive Health & Safety Risk Management plan and all employees and Company partners must comply.

Orla forms a direct relationship with our employees based upon fairness and respect. In addition to compensation and benefits that exceed national averages in all cases, we support the right of employees to associate and collectively obtain labour agreements. We have and will continue to work with employees and their representatives to achieve and maintain positive labour relations. Orla also conducts rigorous due diligence when engaging with contractors and consultants as a precaution to ensure they maintain strong labour standards and are compliant with local regulations and laws including those relating to child labour.

In the third quarter of 2021, Orla finalized the negotiation of the Collective Bargaining Agreement (“CBA”) with the Miners’ Union (Sindicato Minero). Orla’s employees at Camino Rojo ratified the CBA with 99% employee approval. The ratification of the CBA solidifies Orla’s relationships with our employees and the elected union while standardizing a set of fair and competitive benefits for all employees.

We have several policies and procedures in place to maintain a high business standard and prevention of bribery and corruption, including a Code of Business Conduct and Ethics and a Whistleblower Policy.

Board expects Management to operate in a manner that enhances shareholder value and is consistent with the highest level of integrity and transparency. Management is expected to execute the Company’s business plan and to meet performance goals and objectives according to the highest ethical standards.

To this end, the Board has adopted a Code of Business Conduct and Ethics (the “Code”) for its Directors, officers, and employees as well as consultants and contractors. The Code also addresses such important topics as diversity and workplace bullying and harassment and states that the Company is committed to fostering a work environment of mutual respect and tolerance for diversity and will not tolerate and is dedicated to preventing bullying and harassment of any kind. All employees are required to review and certify the Code of Business Conduct and Ethics on an annual basis. We expect all representatives to take all responsible steps to prevent a violation of this Code. Employees are required to report any violations under the Code or the Company’s corporate governance policies in accordance with the Whistleblower Policy.

We have also adopted a Whistleblower Policy which provides that an individual may report any concerns or complaints regarding accounting, internal accounting controls, audit-related matters, or fraud to the Chair of the Audit Committee. Such concerns and/or complaints will be kept confidential and may be communicated anonymously if desired. Reporting may be made in writing or through the dedicated confidence line, a service offered through a third-party independent service provider. Following the receipt of any complaints, the Chair of the Audit Committee shall promptly investigate each matter so reported. No complaints were received under the Whistleblower Policy in 2020. Employees are expected to cooperate in internal investigations of misconduct and we have a no retaliation policy.

Finally, we publish an Extractive Sector Transparency Measures Act Annual Report which discloses payments made to governments by the Company.