Code Of Ethics

Complaint Procedures - Procedures for Reporting Accounting, Internal Accounting Controls and Audit Related Complaints

The Audit Committee of Optima Global Mining and Trading has approved the following procedures for receipt of complaints regarding accounting, internal accounting controls or audit related matters.

Confidential, Anonymous Employee Submissions

Optima’s Code of Business Conduct and Ethics provides that employees may report any concerns regarding accounting, internal accounting controls or audit related matters to the General Counsel, who will communicate the concerns to the Audit Committee. In addition, Optima’s toll free compliance hotline established in connection with the Code of Business Conduct and Ethics may be used for reporting any such concerns. Instructions for access to the hotline by employees are attached to the Code of Business Conduct and Ethics and are posted on the Optima’s intranet.

Submissions by Non-Employees

Option 1:
Anyone may report a complaint in writing, addressed to the General Counsel of Optima at the address set out below.

Optima Global Mining
B760-10 Shiuno Road, Awudome Estates, Accra, Ghana, West Africa

The General Counsel will communicate the concern to the Audit Committee.

Option 2:
Alternatively, a complaint regarding accounting, internal accounting control or audit related matters may be submitted by forwarding it in writing, addressed as follows:

Chair of Audit Committee
Optima Global Mining
c/o Kenneth Erickson
P.O. Box AN-7566 Accra North, Ghana West Africa

Kenneth Erickson will forward the complaint to the Chair of the Audit Committee.

Treat All Employees Fairly, with Dignity and Respect

Each of us should treat everyone whom we encounter with personal dignity and respect no matter what their role or responsibility. All employees are entitled to work in an environment free of verbal, physical and sexual harassment. Further, the company believes promotion of workforce diversity is an important objective in its own right, and is a source of competitive advantage, as well as being consistent with equal employment opportunity.

Deal Honestly and Fairly with Clients, Suppliers, Vendors, Contractors and Financial Partners

The long-term success of the company depends upon establishing mutually beneficial relationships. While the law requires that we fulfil obligations written into contracts and agreements, we will also be fair, ethical and consistent in all business dealings.

Conduct Marketing and Advertising Activities Fairly, Honestly and Accurately

The company may use marketing and advertising activities to educate investors and the public, provide information to proposed clients, increase awareness of our services and business offerings, and recruit new employees. The company is committed to representing its services and offerings fairly, honestly and accurately. Advertising, marketing and promotional materials cannot contain unfair, inaccurate or deceptive statements or grossly exaggerated or unwarranted representations. Employees must not use any advertising, marketing or promotional materials that unfairly describe the services of a competitor or make disparaging comments or innuendo.