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    Steppe Gold Limited © 2025 All Rights Reserved.
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    3. Sustainability

    Sustainability

    Environmental, Social, and Governance
    2024 Report
    Scholarship Program
    Ugai Culture
    Edelbay Ram Herd Improvement Project
    Flying Flock Beekeeping Project
    Composting and Organic Waste Management

    From Mine Land to Wildlife Habitat

    Ulaanbulag Tree Nursery

    Environmental Monitoring

    Water

    Biodiversity

    Land

    Chairman and CEO Statement

    Waste

    Tailings

    Mine Closure

    Energy and Climate

    Chairman and CEO Statement

    Health, Safety and Wellbeing

    Diversity and Inclusion

    Community Relations

    Chairman and CEO Statement

    Corporate Governance and Business Ethics

    Compliance and Risk Management

    Scholarship Program
    Ugai Culture
    Edelbay Ram Herd Improvement Project
    Flying Flock Beekeeping Project
    Composting and Organic Waste Management

    From Mine Land to Wildlife Habitat

    Ulaanbulag Tree Nursery

    Environmental Monitoring

    Water

    Biodiversity

    Land

    Chairman and CEO Statement

    Waste

    Tailings

    Mine Closure

    Energy and Climate

    Chairman and CEO Statement

    Workforce Health and Safety

    Diversity and Inclusion

    Community Relations

    Chairman and CEO Statement

    Corporate Governance and Business Ethics

    Compliance and Risk Management

    At Steppe Gold, sustainability is at the heart of how we operate. We focus on developing our resources responsibly - protecting the environment, supporting local communities, and creating long-term value for all stakeholders.
    Explore our journey and progress through our Environmental, Social and Governance (ESG) Reports below.
    2024 Report
    2023 Report
    2022 Report

    Scholarship Program

    Steppe Gold Limited believes that providing equal opportunities from the outset empowers the youth and creates long-term value for society. We give priority to investment in human capital, which reflects the United Nations Sustainable Development Goal 4: Quality Education.

    Since 2017, we have awarded scholarships to a total of 1,886 students pursuing studies in national and international universities, from Tsagaan-Ovoo soum in Dornod aimag as well as from Shinejinst and Bayan-Undur Soums of Bayankhongor aimag.

    As an outcome, there has been a tangible reduction in the shortage of skilled professionals within local government agencies and private enterprises across the region.

    “I am very thankful that Steppe Gold has been providing scholarships to students like me. I believe that investing in the youth education creates a bright future for us, creating a long-term vision for all of us.”

    Uugandari A.

    2023

    “I am majoring in the Aviation 2+2 program at Ikh Zasag International University, I am very grateful to receive this scholarship, as it helps ease the financial burden on my parents.”

    Sophomore student at Ikh Zasag

    2022

    “I’m a third-year Law student. I will do my best to continue earning this scholarship each year. MNT 1,000,000 is a significant investment for us, and I truly appreciate this opportunity.”

    Junior year student

    2022

    As an outcome of the scholarship program, there has been a tangible reduction in the shortage of skilled professionals within local government agencies and private enterprises across the region.

    Preserving Buryat Cultural Heritage - “Ugai Culture” multimedia project

    The Buryat ethnic minority in Mongolia has a rich and complex history, closely tied to centuries of migration and settlement. It is widely believed that the Buryats are part of the Mongolic peoples who migrated from Central Asia to the Lake Baikal region between the 11th and 14th centuries. During the mass migration of 1918, many Buryat families from Russian territory settled in Tsagaan-Ovoo soum of Dornod aimag. Today, this soum is recognized as a historical homeland for a significant portion of the Buryat community. As of 2021, Tsagaan-Ovoo soum is home to 3,959 residents, 98% of whom are ethnic Buryats.

    Mongolia is home to various Buryat clans and subgroups, including the Tugchin, Khachin, Guunai, Mekheerchin, Tsongool, Sartuul, and Uriankhan, among others. Known for their nomadic herding lifestyle, the Buryats are distinguished by their unique dialect, traditions, and vibrant cultural practices. However, in recent decades, their cultural heritage has been at risk of fading. This has created an urgent need to preserve and revitalize Buryat traditions for future generations.

    In response, Steppe Gold Limited launched the “Ugai Culture” multimedia heritage project in 2022. A dedicated team of six researchers—from the Institute of History and Ethnology and the Institute of Language and Literature of the Mongolian Academy of Sciences, along with the NGO “Yazguur Uv Erdene”—collaborated to document the customs and traditions of the Buryats. Their work includes an in-depth research book highlighting seasonal customs and a documentary film capturing the daily lives, rituals, and rich heritage of nomadic Buryat herder families in Tsagaan-Ovoo soum. The film crew spent over a year living among the herders and authentically portraying their way of life. Both the book and the documentary are expected to be released in 2025, marking the completion of this impactful three-year initiative.

    The Buryat culture is incredibly diverse, encompassing practices such as hospitality rituals, felt-making, and seasonal festivals. Even within the same community, there are variations in customs—especially in celebrations and religious observances. For example, during Sagaalgan – the Buryat Lunar New Year, families visit elders and extended relatives to offer respectful greetings. The traditional greeting involves placing one’s arms beneath the elder’s arms—a gesture symbolizing support—followed by a kiss or sniff on the cheek. While some communities believe that wearing a hat during the greeting honors one’s lineage, others view removing the hat as a sign of humility and respect.

    Despite the richness of these customs, many are at risk of disappearing. One such tradition is the “pillow fight” wedding ritual, which was fondly recalled during an interview with a 92-year-old woman from the Ulaalzai Khugduud tribe. Recognizing the importance of such cultural practices, ATO operations are working closely with local communities and researchers to preserve these fading traditions and safeguard the untold stories of the people of Tsagaan Ovoo soum.

    Edelbay Ram Herd Improvement Project

    2024 September-born hybrid lambs

    Over the past 30 years, Mongolia has experienced severe pasture degradation due to uncontrolled land use and excessive livestock growth. A 2018 study indicated that 65% of the country’s pastureland was degraded. To combat this, a series of measures must be implemented, including proper land use, revival of traditional rotational grazing practices, and improving livestock quality to reduce herd sizes. Overgrazing has led to vegetation loss and, ultimately, desertification. As plant diversity in pasturelands declines, livestock are unable to obtain sufficient nutrients, resulting in lower body weights year after year. This has weakened their resilience to Mongolia’s harsh climate, contributing to high mortality during extreme winters, which in turn causes serious financial and emotional strain for herder families.

    To address these challenges, Boroo Gold partnered with the National Federation of Pasture User Groups of Mongolia (NFPUG) under its biodiversity offset program to implement a Pasture Management Improvement Subproject. In 2022, the company launched a pilot project to improve local flocks by crossbreeding with Edelbay, a pure meat-fat breed of sheep.

    The main objective of the project was to introduce need-based crossbreeding using Edelbay rams, enabling herders to sell lambs before maturity, reduce grazing pressure, and promote more sustainable herd management. As planned, the first breeding season took place in autumn 2023, using selected Edelbay rams for insemination. At the request of local authorities and herders, the breeding began with three experienced herder households. By spring 2024, the project had successfully produced over 90 Edelbay-Mongolian hybrid lambs.

    In coordination with local policies to establish a breeding nucleus, two rams were provided to the soum’s core breeding stock. The hybrid lambs were then raised using a formulated feeding schedule for 30 days with the goal of increasing their live weight for market sale. This process was carried out under the supervision of a Ph.D. advisor from the Mongolian University of Life Sciences.

    The hybrid lambs were weighed six times over the 30-day fattening period. Results showed that first-generation Edelbay-Mongolian crossbred lambs gained between 5.6 and 7.2 kg, while pure Mongolian lambs gained only 4.2 to 5.3 kg. On average, hybrid male lambs gained 180–210 grams per day, compared to 140–165 grams per day for pure Mongolian males. These figures indicate that the hybrid lambs outperformed their local counterparts by over 25% in weight gain.

    After the 30-day feeding period, the hybrid lambs were sold to Mah-Impex, a private meat processing company, at a price of MNT 9,000 per kilogram. The cost of fattening one lamb over the month was MNT 17,782. Based on an estimated meat yield of 17–18 kg per lamb, the gross revenue significantly outweighed the investment. Excluding labor costs, the net profit margin exceeded 80%, demonstrating strong economic potential for herders.

    The trial confirmed that Edelbay lambs have superior growth performance compared to local breeds. Short-term crossbreeding with high-yield meat-fat breeds like Edelbay, followed by early sale of lambs, has proven to be an effective strategy for increasing income and reducing herd pressure on pastures.

    Participating herders have expressed strong interest in continuing this approach—raising and selling hybrid lambs as a source of income. However, further support and formal approval from local government are needed to expand the initiative.

    "Flying Flock" Beekeeping Project

    As part of its biodiversity offset program, Boroo Gold has implemented several pasture restoration and improvement initiatives in Bayangol soum, Selenge aimag, aimed at adjusting grazing pressure and improving land health. The “Flying Flock” beekeeping project, launched in 2019, is one such subproject focused on ecosystem recovery and sustainable livelihood development.

    Beginning in 2019, Boroo Gold introduced beekeeping on rehabilitated land to promote ecological stability. The initiative supports both environmental goals and local livelihoods. By allowing bees to forage in areas with flowering plants, the project not only creates income opportunities for herders through honey production but also enhances the productivity of pasture ecosystems by up to 30% through pollination. This contributes significantly to the natural regeneration and biodiversity of the rehabilitated sites.

    With a strong focus on community engagement and social responsibility, Boroo Gold allocated funding and encouraged local participation in the project. Local residents were actively involved, and the project was financially supported by the company.

    Since its inception, the beekeeping project has been successfully implemented in partnership with herders from Kharaa bagh, Bayangol soum, where Boroo’s operations are based. Initially, herders received training and guidance from professional organizations. Over time, they gained sufficient knowledge and experience to manage their beekeeping operations independently. Their success has inspired other herders in the area to explore beekeeping, some with local government support, others using their own resources.

    In 2024, as in previous years, bee colonies were placed and pastured in Dorgont, a site near the Boroo mine and Bayangol soum. During the summer months (July to September), six colonies were placed in the most flower-rich locations within the mine area. The colonies were jointly monitored weekly by herders and staff from Boroo Gold’s Environmental Department. As cooler autumn weather approached, the colonies were relocated from the mine area and overwintered in specially prepared shelters managed by herders.

    Honey harvested from bee colonies pastured on the rehabilitated site in 2024 was sampled and tested at the General Agency for Specialized Inspection’s Food and Agriculture Laboratory and the “Eruulzu” laboratory. Test results confirmed compliance with MNS 6294:2011, the national standard for pure honey. No harmful bacteria or hazardous compounds were detected, confirming the honey’s safety and suitability for consumption.

    Boroo Gold purchased the harvested honey from herders at market price, directly contributing to household income. The company also showcased the honey at international mining exhibitions, distributing it as a promotional gift to visitors. The initiative received high praise from stakeholders, including the public and industry professionals, who acknowledged the project’s scale, impact, and innovation.

    Going forward, Boroo Gold is committed to building on past experiences to enhance the sustainability and efficiency of the beekeeping project, further supporting both ecosystem health and rural livelihoods.

    Composting and Organic Waste Management

    Steppe Gold Limited is implementing practical solutions to reduce organic waste and support land rehabilitation across its operations. Food waste from site kitchens is converted into nutrient-rich compost used to improve soil quality and support revegetation.

    At Boroo Gold, a composting program launched in 2023 processes food waste from worker camp kitchens, replacing the previous practice of transporting waste offsite. Organic waste is combined with carbon-rich materials such as wood shavings and sawdust and managed through controlled composting processes.

    The initiative has delivered measurable results, including 180–200 kg of food waste processed monthly, 2.4 tonnes of waste diverted from disposal, and approximately 500 kg of mature compost produced by October 2024. The compost is laboratory-tested to meet MNS 6507:2015 standards before being used in site rehabilitation areas.

    Boroo Gold has also introduced vermicomposting using red worms (Eisenia fetida) to accelerate organic waste decomposition and produce high-quality biohumus, further supporting soil improvement.

    At the ATO Mine, composting has evolved into a permanent system with the construction of a 31.2 m³ composting facility in 2024. The facility processes kitchen waste together with livestock manure sourced from local herders. The final compost is tested at accredited laboratories to ensure compliance with national standards and is used in rehabilitation and revegetation areas.

    The composting process is monitored regularly, with samples tested in accredited laboratories to confirm chemical and microbiological safety. The final compost meets MNS 6507:2015 standards and is applied to rehabilitation and revegetation areas.

    From Mine Land to Wildlife Habitat

    In 2018, Boroo Gold established a man-made pond in the reclaimed and afforested Ikh Dashir Valley area to support the local ecosystem and enhance biodiversity. The project also created a natural space where employees can spend time outdoors while contributing to environmental restoration.

    Designed to blend naturally with the surrounding landscape, the pond covers 2,700 m² and includes a water reservoir, pedestrian paths, and green areas. It holds 1,400–1,700 m³ of water, replenished through spring snowmelt, seasonal flooding, and surface runoff, creating a natural water recharge system.

    The project also incorporates circular economy practices. Used waste tires from the mine are sorted and repurposed into pedestrian pathways, swings, stairs, and flowerpots, contributing to landscaping around the pond while reducing waste.

    To better understand the local ecosystem, trail cameras have been installed around the pond to monitor wildlife visiting the area for drinking and grazing. The collected data supports observation of animal habitats and population activity in the reclaimed environment.

    This initiative demonstrates how reclaimed mine land can be transformed into functional ecosystems that support biodiversity while also providing a natural recreational area for employees.

    Ulaanbulag Tree Nursery

    Boroo Gold joined the “One Billion Trees” national movement initiated by the President of Mongolia in 2021, committing to plant and maintain 3 million trees by 2030 to support climate change mitigation, forest restoration, and ecosystem protection.

    To support this commitment, the Company established the Ulaanbulag Tree Nursery in 2022 near its operations in Bornuur soum, Tuv aimag, covering 41.7 hectares. The nursery produces high-quality seedlings for afforestation, land rehabilitation, and green space development. Infrastructure includes greenhouses, irrigation systems, water wells, and outdoor cultivation areas.

    In 2024, the nursery maintained and cultivated over 400,000 seedlings from previous planting cycles and conducted new planting of multiple deciduous and conifer species. The facility also grows fruit trees such as seabuckthorn, raspberry, cherry, and apple.

    The nursery supports local employment and skills development, providing seasonal work and training opportunities for local residents involved in seed collection, soil preparation, planting, and maintenance.

    Through the Ulaanbulag Nursery, the Company contributes to reforestation, land restoration, and the expansion of green spaces in Mongolia.

    Environmental Monitoring

    Steppe Gold Limited implements a comprehensive environmental monitoring program across its projects to assess and mitigate environmental impacts. The monitoring program includes regular checks of water quality, air quality, soil health, vegetation, and wildlife. These assessments are conducted in compliance with relevant standards, ensuring that the company’s operations do not negatively affect the surrounding environment. Environmental monitoring includes regular assessment of water, soil, and air quality using accredited methods, with results compared to relevant Mongolian National Standards to ensure compliance and detect potential risks.

    In 2024:

    Water

    Steppe Gold Limited recognizes water as a critical resource for all operations and surrounding communities. The Company is committed to responsible water management through efficient use, continuous monitoring, and compliance with regulatory standards to protect local water resources and ecosystems.

    Water quality and groundwater levels are regularly monitored across all operations. At Boroo, monitoring was conducted at 42 locations, with 420 water samples analyzed during 2024. At Ulaanbulag, 74 samples were collected from 10 monitoring points, including surface water, groundwater, and open-pit runoff. At the ATO Mine, groundwater levels near the leach pad are measured weekly through control boreholes, with 425 measurements recorded in 2024.

    Steppe Gold Limited also supports water protection initiatives across its operations. At the ATO Mine, a riparian forest restoration project along the Kherlen River and spring protection initiatives in Tsagaan-Ovoo soum were implemented to strengthen water resource conservation. Protection zones around reservoirs in the Khentii River basin were also marked to support compliance with environmental protection regulations.

    At Boroo, water is sourced from five deep wells in the Boroo River Valley and monitored through centralized metering systems. Water use is regulated through agreements with the Kharaa-Erdene River Basin Administration, ensuring compliance with Mongolia’s Water Law and responsible water use. Water efficiency and reuse are key priorities: treated wastewater is reused in the processing cycle, preventing discharge to the environment, with 80-90% of production water supplied from recycled sources during warmer seasons.

    At the Ulaanbulag open-pit mine, rainwater and underground seepage are collected in a reservoir and reused for irrigation and dust control, supporting efficient water use and environmental management.

    Biodiversity

    Steppe Gold Limited is committed to protecting biodiversity across its operations in accordance with Mongolia’s environmental regulations, including the Law on Environmental Impact Assessment and related regulatory frameworks. The Company implements site-specific biodiversity management and offset programs designed to mitigate environmental impacts and support long-term ecosystem restoration.

    Mining activities can alter land and habitats; therefore, Steppe Gold applies a stepwise approach to environmental management, focusing on minimizing disturbance during operations, conducting progressive rehabilitation, and restoring ecosystems following project completion.

    Biodiversity Management and Monitoring

    Baseline biodiversity studies have been conducted across the Company’s project sites to assess ecosystem conditions and guide long-term biodiversity management plans. These plans include habitat restoration, wildlife monitoring, ecological assessments of rehabilitated areas, and species conservation initiatives.

    In 2024, independent environmental specialists conducted biodiversity surveys of rehabilitated areas at the ATO Mine, assessing plant and insect populations and evaluating the effectiveness of vegetation recovery efforts.

    ATO Conservation Initiatives

    At the ATO Mine, Steppe Gold continues to implement targeted biodiversity conservation initiatives in collaboration with environmental experts and local communities. Key initiatives include wildlife monitoring programs, habitat restoration, and ecological studies of rehabilitated areas.

    A marmot restoration program successfully reintroduced 400 marmots in the Tsagaan-Ovoo area throughout the years. Additional initiatives include the installation of artificial bird nests to support local bird populations and the restoration of degraded land through reseeding with native perennial plant species. Wildlife monitoring surveys conducted in the surrounding area also confirmed healthy populations of Mongolian gazelle.

    Biodiversity Offset Programs at Boroo

    At the Boroo Mine, biodiversity offset measures are implemented in accordance with Mongolia’s environmental regulations where certain areas cannot be fully rehabilitated. These initiatives focus on restoring ecologically similar areas to compensate for unavoidable impacts.

    Since 2018, Boroo Gold has implemented two major long-term biodiversity offset projects:

    • 45.6 ha afforestation project in Bortolgoi
    • 7,000 ha pastureland restoration program in Dorgont

    These projects focus on restoring degraded ecosystems, improving pasture management through collaboration with local herder communities, and enhancing vegetation recovery. Monitoring results indicate measurable improvements in vegetation cover and pasture health.

    Supporting Local Ecosystems and Communities

    Steppe Gold Limited’s biodiversity initiatives also contribute to local environmental and community development. Tree-planting programs and ecosystem restoration activities have been implemented in several soums, helping expand green spaces, strengthen environmental stewardship, and support sustainable land management practices.

    Through these initiatives, Steppe Gold Limited aims to contribute to long-term ecological resilience while supporting sustainable livelihoods in the regions where it operates.

    Afforestation - Before 2018
    After -2022
    Current - 2024

    Land

    Responsible land use and soil protection are key elements of Steppe Gold’s commitment to environmental sustainability. Effective management of disturbed land helps minimize the environmental impacts of mining while supporting ecosystem restoration and maintaining the ecological health of surrounding areas. Through the preservation of fertile topsoil and the implementation of both technical and biological reclamation measures, the Company works to meet environmental standards while enhancing biodiversity and land stability.

    At the ATO Mine, rehabilitation is integrated into ongoing operations. Since 2020, the ATO team has completed a total of 34.23 ha of technical and 33.4 ha of biological rehabilitation. Disturbed areas such as roads, exploration sites, and infrastructure zones are progressively restored, while fertile topsoil is carefully removed and stockpiled for use in future reclamation.

    At the Boroo mine, reclamation has been a core part of operations since mining began in 2004. To date, Boroo Gold has completed 592.1 hectares of technical reclamation and 579.8 hectares of biological reclamation, restoring land and supporting the gradual return of vegetation and biodiversity. Monitoring shows that vegetation cover on reclaimed areas continues to improve as ecosystems recover.

    At the Ulaanbulag project, land management and soil protection measures are already being implemented during the early stages of development to support effective rehabilitation in the future.

    Through progressive rehabilitation, responsible soil management, and long-term planning, Steppe Gold Limited aims to ensure that land affected by mining is restored to a stable and productive condition after operations.

    Statement from the Chairman and Chief Executive Officer

    Steppe Gold Limited is proud to present our sustainability journey for 2024. This is our third ESG report, and our first joint report following integration with Boroo Gold LLC.

    The past year was marked by the successful acquisition of Mongolia’s leading gold producer, Boroo Gold LLC, which advances our path to becoming a new mid-tier gold producer. This integration of new assets and expertise creates an opportunity to learn from each other’s best practices across the operational sites.

    As we expand, health and safety remain top priorities for us. We successfully maintained zero workplace fatalities for the sixth year in a row and strive to continue to provide a safe workspace for our employees. We foster an inclusive and diverse environment where skills and expertise are prioritized. By year-end, women held 35% of the middle management positions in Steppe Gold Limited.

    We strive to positively impact our communities and support them through our daily operations and various programs. In 2024 alone, we spent approximately US$1.4 million on goods and services sourced from local and regional suppliers. Through community programs, we invested US$0.9 million in essential areas, including infrastructure improvement, educational scholarship, and small business support and training.

    Beyond financial contributions, we hold deep respect for the local community. Since 2022, we have undertaken “Ugai Soyol,” a multimedia project dedicated to preserving the intangible cultural heritage of the Buryats, an ethnic minority residing in Tsagaan Ovoo soum. This impactful three-year initiative is set to conclude in 2025 with the release of a book and a documentary.

    To mitigate our environmental impact, this year we initiated the implementation of Environmental Management Systems (EMS) at the ATO project, aligned with the ISO 14001:2015 international standard. Through these efforts, Steppe Gold Limited has achieved a score of over 95% in the implementation of the Environmental Management Plan in 2024 in all three projects.

    As the largest gold producer in Mongolia, we aim to be a blueprint for responsible mining and showcase the positive impact mining can have on humans and the planet. On behalf of our Management Team, my sincere appreciation goes to all of our employees who give their best every day.

    Bataa Tumur-Ochir
    Chairman and CEO, Steppe Gold Limited

    Waste

    Steppe Gold Limited manages operational waste to minimize environmental impacts through proactive planning, regulatory compliance, and the 3R principle – Reduce, Reuse, Recycle. In 2024, more than 90% of actions outlined in site-specific Waste Management Plans were implemented.

    Waste across operations is classified into domestic, hazardous, and industrial streams and segregated at source. Domestic waste such as plastics, paper, wood, and food waste is collected in color-coded bins and transferred to municipal facilities through licensed service providers. Hazardous materials, including used oils, batteries, and chemical containers, are stored in secure, labeled storage areas and handled by licensed contractors to ensure safe treatment or disposal. No incidents of uncontrolled hazardous waste discharge were recorded in 2024.

    Recycling and reuse initiatives continue to expand across operations. At Boroo Gold, used kitchen oil is recycled into hand soap, plastic waste is processed into durable products, and used vehicle batteries are sent to licensed recycling organizations. In 2024, approximately 8 tonnes of waste oil were collected for recycling.

    At ATO, more than 5,100 kg of plastic bottles were collected for recycling, while scrap wood and metal were reused by local herder households. Reusable materials were also used in tree planting and irrigation trials supporting over 15,000 planted trees at the site.

    Tailings

    Tailings from both Boroo and Ulaanbulag Mine are managed at the Boroo Tailings Storage Facility (TSF).

    The TSF is regularly inspected and monitored through weekly environmental checks, including seepage monitoring using 10 piezometers installed at the tailings dam. In addition, annual inspections by specialized engineering firms and monthly geotechnical monitoring at nine locations are conducted to assess dam stability and infrastructure integrity.

    Drone monitoring is also used to track changes in the facility and surrounding environment. These measures support safe and responsible tailings management and ensure compliance with national and international environmental standards, protecting the surrounding environment and local communities.

    Mine Closure

    Responsible mine closure is an essential part of sustainable mining. Steppe Gold Limited manages environmental and social impacts throughout the full lifecycle of its operations, ensuring that mined areas are rehabilitated and can support future land use for local communities.

    At the ATO Mine, a comprehensive mine closure and rehabilitation plan was developed in 2018, prior to the start of mining activities, in accordance with Mongolian regulatory requirements. The plan is regularly updated to reflect operational data, evolving environmental standards, and best practices.

    At Boroo Gold, rehabilitation is integrated into daily operations to ensure that closure planning is proactive and continuous. Activities such as land restoration, vegetation planting, and soil rehabilitation support the long-term recovery of disturbed areas.

    The Company also supports research and innovation to improve rehabilitation outcomes. In partnership with the National University of Mongolia, the Company is conducting phytoremediation studies and native plant trials to restore soil quality, promote biodiversity, and strengthen long-term ecosystem recovery.

    To support these commitments, Steppe Gold Limited maintains financial provisions for environmental rehabilitation and mine closure, calculated in accordance with regulatory requirements and reviewed with independent specialists to ensure adequate funding for closure obligations.

    Energy and Climate

    Climate change presents significant risks to ecosystems, economies, and communities. Steppe Gold Limited is committed to managing climate-related risks and supporting climate resilience in the Mongolian steppe where its operations are located.

    The Company aligns its climate actions with international frameworks including the Paris Agreement and the UN Sustainable Development Goals, focusing on improved emissions monitoring, energy efficiency, and sustainable operational practices.

    Boroo Gold has independently tracked its CO₂ emissions since 2017, while ATO Mine greenhouse gas emissions were calculated in 2023 and benchmarked against 2022 data to strengthen transparency and data accuracy. Steppe Gold continues to enhance its climate approach through improved data management and the integration of low-carbon operational practices.

    Tree Planting and Carbon Sequestration

    Steppe Gold Limited supports ecosystem restoration through large-scale tree planting initiatives.

    ATO Mine: 22,644 trees planted since 2021, including 15,040 in 2024. Due to their early growth stage, these trees are not yet included in carbon sequestration estimates.

    Boroo Gold: 43,393 trees planted in 2024, bringing the total since 2021 to 168,203 trees. By the end of 2024, these trees are estimated to have absorbed 56,232 tonnes of CO₂ and released 149,952 tonnes of oxygen.

    Renewable Energy and Energy Efficiency

    Steppe Gold Limited is implementing renewable energy and energy efficiency measures across its operations.

    At ATO Mine, solar-powered systems support operational facilities, communications infrastructure, and site lighting, reducing reliance on grid electricity.

    At Boroo Gold, several energy-saving measures have been introduced, including LED lighting across facilities, smart energy-efficient heating systems, temporary shutdown of non-essential equipment during peak winter demand, and the installation of smart electricity meters to improve monitoring and energy management.

    Health, Safety and Wellbeing

    Steppe Gold Limited is committed to maintaining a safe, healthy, and supportive working environment for all employees, contractors, and visitors. Guided by the principle that “Safety is the measure of success,” the Company promotes a strong safety culture built on proactive risk management, continuous improvement, and shared responsibility across all operations.

    Comprehensive safety management systems are implemented across all operations, supported by regular safety inspections, job hazard assessments, and ongoing workforce engagement. Steppe Gold is also implementing the ISO 45001:2018 Occupational Health and Safety Management System, strengthening the Company’s ability to identify, assess, and manage workplace risks while ensuring compliance with applicable regulatory standards.

    Employee well-being is supported through workplace health programs, including pre-employment medical examinations, annual health screenings, and additional health monitoring for employees working in higher-risk roles.

    Safety Performance

    Steppe Gold Limited continues to maintain a strong safety record across its operations. In 2024:

    • Lost Time Injury Frequency Rate (LTIFR): 0
    • No fatalities recorded across all sites

    These results reflect the Company’s focus on proactive safety management, workforce engagement, and continuous improvement.

    Training and Emergency Preparedness

    Occupational Health and Safety (OHS) training programs are implemented across all operations to strengthen risk awareness and emergency preparedness. Training includes:

    • New employee safety orientation
    • Routine safety briefings and refresher training
    • Emergency response and fire safety training
    • High-risk job certification programs in accordance with Mongolian labor regulations

    Through these initiatives, Steppe Gold continues to foster a workplace where health, safety, and well-being are integral to operational excellence and long-term sustainability.

    Diversity and Inclusion

    Steppe Gold Limited is committed to fostering an inclusive workplace that reflects the communities in which we operate. The Company prioritizes local employment, equal opportunity, and respect for human rights, creating a safe and supportive work environment for employees and contractors.

    Our Human Resources policies promote fairness, transparency, and mutual respect across all operations. These policies include a zero-tolerance approach to discrimination and harassment, fair grievance procedures, equal opportunities regardless of gender or background, and support for employees’ rights to freedom of association.

    Local Employment

    Supporting local employment is an important part of Steppe Gold’s approach to community development. Wherever possible, the Company prioritizes hiring from local aimags and soums surrounding its operations and works with local communities and authorities to support workforce development.

    As of the end of 2024, Steppe Gold’s Mongolian operations employed 1,039 employees and contractors, including:

    • 272 individuals from local aimags and surrounding areas
    • 236 employees from soums located near the Company’s operations

    Gender Diversity and Equal Pay

    Steppe Gold Limited is committed to equal pay and equal opportunities across the organization. Employees in the same roles with equivalent qualifications receive the same compensation regardless of gender.

    While the mining industry traditionally has a higher proportion of male employees, Steppe Gold continues to support greater gender diversity within its workforce. As of 2024:

    • Women represented 12% of employees
    • Women represented 24% of contractors
    • Women held 34.6% of mid-level management positions

    Through these initiatives, Steppe Gold aims to promote an inclusive workplace while contributing to local economic development and sustainable workforce growth in the regions where it operates.

    Community Relations

    We are committed to creating long-lasting, positive impacts on our local communities. Through continuous investment, collaboration with local authorities, and a strong focus on local employment and procurement, all three mines are contributing significantly to the socio-economic development of their regions. These efforts align with our broader sustainability goals, ensuring that mining operations benefit not only our stakeholders but also the communities where we operate.

    In 2024:

    MNT 3.1B

    invested in community programs and funds

    MNT 4.8B

    spent on local procurement

    From 2019 to 2024, Steppe Gold Limited has made significant local investments in the respective soums.

    We successfully implement our Cooperation Agreement in all operating soums, driven by our aim to give back more than we receive. This strong track record demonstrates a firm commitment to fulfilling obligations and delivering tangible, long-term benefits to local communities.

    Corporate Governance and Business Ethics

    We are dedicated to upholding the highest standards of corporate governance, ensuring that our operations are conducted with integrity, transparency, and accountability. Ethical conduct is more than a policy—it is a core value that guides every decision we make.

    Policies

    In 2024:

    100%

    of local workforce completed training on our Code of Conduct and Ethics

    Approved by our Board of Directors in 2018, our Code of Business Conduct and Ethics is the core of our compliance efforts. It provides clear guidelines for everyone connected to our business – from employees and contractors to directors, suppliers, and consultants – empowering them to make ethical choices and take ownership of their conduct.

    Promoting a Speak-Up Culture

    We believe in open communication and mutual respect, and our Open Door Policy reflects this. Every employee is encouraged to share concerns, suggestions, or workplace challenges directly with their supervisors. This approach fosters trust, strengthens team cohesion, and helps resolve issues quickly and respectfully.

    Compliance and Risk Management

    Steppe Gold Limited maintains a strong governance framework to ensure responsible decision-making, effective risk oversight, and compliance with applicable laws and regulations. Risk management is integrated across the organization to support operational stability and long-term value creation.

    Risk Management Framework

    The Company applies a structured risk management process that includes the identification, assessment, and mitigation of operational, financial, environmental, and regulatory risks. Oversight of key risks is led by the Board of Directors and its Audit Committee, working closely with senior management and internal audit functions.

    The risk management process includes:

    • Identification of key risks across all operations
    • Assessment of risk likelihood and potential impact
    • Evaluation of existing controls and mitigation measures
    • Development of action plans to manage or reduce risks
    • Ongoing monitoring and reporting to senior management and the Board

    Regular risk reviews are conducted at both operational and corporate levels to ensure emerging risks are identified and addressed in a timely manner.

    Steppe Gold recognizes the importance of managing climate-related risks and opportunities as part of its broader environmental and risk management strategy. Through the implementation of its ISO 14001 Environmental Management System, the Company identifies environmental aspects and assesses associated risks and opportunities, with corrective actions implemented and monitored as part of ongoing environmental management.

    Compliance and Internal Controls

    Steppe Gold Limited is committed to maintaining full compliance with applicable national regulations, industry standards, and internal corporate policies across all operations. Compliance programs cover key areas including environmental protection, health and safety, labor practices, and operational permitting.

    Dedicated legal and compliance teams monitor legislative developments, support internal audits, and ensure regulatory requirements are consistently implemented across the Company’s operations.

    Internal compliance assessments are conducted regularly to verify adherence to legal and regulatory obligations. Through this governance, risk management, and compliance practices, Steppe Gold Limited seeks to maintain transparent, responsible, and sustainable operations while safeguarding the interests of shareholders and stakeholders.

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