Conflict Minerals Policy

Introduction:

FG Capital Advisors Ltd. ("FGCA" or "the Company") is committed to conducting its business in an ethical and responsible manner that supports and respects the protection of human rights. This Conflict Minerals Policy reflects our commitment to avoiding the use of minerals that finance or benefit armed groups in conflict-affected and high-risk areas.

Scope:

This policy applies to all operations, suppliers, and contractors of FG Capital Advisors Ltd. It covers the sourcing of tin, tantalum, tungsten, and gold (3TG) which are extracted from mines in conflict-affected and high-risk areas, particularly in the Democratic Republic of the Congo (DRC) and adjoining countries.

Policy Statement:

1. Due Diligence and Supply Chain Transparency: FGCA commits to conducting rigorous due diligence on its supply chain to ensure that 3TG minerals used in any process, product, or service provided by FGCA do not directly or indirectly finance or benefit armed groups in conflict-affected and high-risk areas. This includes adhering to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
2. Supplier Code of Conduct: All suppliers and contractors of FGCA are required to comply with this Conflict Minerals Policy and to provide evidence of their due diligence measures. Suppliers must demonstrate their commitment to ethical sourcing practices and provide transparent supply chain information.
3. Zero Tolerance Policy: FGCA adopts a zero tolerance policy towards the use of conflict minerals that directly or indirectly finance or benefit armed groups in the DRC and adjoining countries. Should any supplier be found to violate this policy, FGCA will take immediate action to remedy the situation, which may include terminating the relationship with the supplier.
4. Continuous Improvement: FGCA commits to continuously improving its due diligence and remediation processes to enhance the transparency and responsibility of its supply chain. This includes regular reviews of our Conflict Minerals Policy and practices, engaging with stakeholders, and participating in industry initiatives aimed at eliminating the use of conflict minerals that finance or benefit armed groups.
5. Reporting and Communication: FGCA will annually report on its due diligence efforts and progress towards eliminating conflict minerals from its supply chain. This report will be made publicly available on our website and communicated to all stakeholders.
6. Employee and Supplier Training: FGCA will provide ongoing training to its employees and suppliers on the importance of ethical sourcing and the requirements of this Conflict Minerals Policy to ensure compliance and understanding across our supply chain.
7. Stakeholder Engagement: FGCA will engage with NGOs, industry peers, and other stakeholders to share best practices, learn from others, and collaboratively work towards the elimination of conflict minerals that finance or benefit armed groups.

Implementation and Compliance:

FG Capital Advisors Ltd. is committed to implementing this policy across all its operations and expects all its business partners to adhere to these principles. The Company will monitor compliance with this policy through internal and external audits, supplier assessments, and third-party certifications. Non-compliance with this policy will result in corrective actions and may lead to termination of business relationships.