Conduct, ethics & accountability.

Miziba is built to operate at institutional standards. That means more than verification at the weighbridge. It means a published, enforceable framework for how we conduct ourselves with farmers, with counterparties, with regulators, and with each other. This Code applies to all directors, officers, employees, contractors and partners of Miziba Infrastructure Ltd.

01Our commitment

We commit to operate Miziba and the TradeAxis programme in accordance with:

• The laws of the Republic of Ghana and any other jurisdiction in which we operate;
• The United Nations Guiding Principles on Business and Human Rights (UNGP);
• The Sustainable Development Goals, particularly Goal 1 (No Poverty), Goal 2 (Zero Hunger), Goal 5 (Gender Equality), Goal 8 (Decent Work and Economic Growth) and Goal 12 (Responsible Consumption and Production);
• The International Labour Organization conventions on forced labour (C29, C105) and child labour (C138, C182);
• The principles set out in the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act 2010, regardless of whether those statutes apply to us as a matter of law;
• The principles set out in the United Kingdom Modern Slavery Act 2015 in respect of our supply chain.

02Anti-corruption and anti-bribery

We do not pay bribes. We do not accept bribes. We do not facilitate bribes by others. This applies whether the counterparty is a public official or a private individual, whether the transaction is in Ghana or abroad, and whether the value is large or small.

Specifically:

• We do not offer, give, request or accept any payment, gift, hospitality or other advantage that is, or could reasonably be perceived to be, intended to improperly influence a business decision or a public official.
• We do not make facilitation payments. We will refuse such payments even where they are customary in a particular setting.
• We require all counterparties to certify, as part of their onboarding, that they have not engaged in corrupt practices in connection with their relationship with Miziba.
• We maintain accurate books and records that reflect every transaction in reasonable detail.
• We will report any suspected corruption to the relevant regulatory authority in line with applicable law.

03Modern slavery and forced labour

Forced labour, bonded labour, indentured servitude and any other form of modern slavery have no place in our operations or our supply chain.

• Every farmer who supplies into our network does so voluntarily.
• Workers in our hubs and partner aggregator operations have the freedom to leave their employment at will, subject only to reasonable contractual notice.
• We do not retain workers' identification documents, hold deposits, or use any other coercive practice that restricts a worker's freedom of movement or freedom to leave employment.
• We require our aggregation partners to commit to the same standard and we audit compliance through our hub network.

04Child labour exclusion

We are particularly attentive to child labour risks in cocoa, given the well-documented prevalence of the worst forms of child labour in West African cocoa supply chains. Where we operate in cocoa, we apply enhanced verification:

• FarmerIQ profiles record the household composition of every registered supplier.
• Hub operators are trained to recognise and report indicators of child labour.
• Suppliers identified as engaging in child labour are removed from the network and the matter is reported to relevant authorities for remediation.
• We engage with cocoa sector remediation frameworks such as the Cocoa Livelihoods Programme and the International Cocoa Initiative protocols where relevant.

Our exclusion is absolute. Commercial considerations do not override it.

05Farmer welfare and fair treatment

Our operating premise is that institutional finance for rural commodity trade should improve outcomes at the base of the value chain, not extract from it.

• Same-day payment. Farmers delivering to a TradePoint hub are paid on the same day, in over ninety-eight per cent of cases. Delays are recorded as exceptions, investigated, and remediated.
• Transparent grading. Quality grade is independently sampled and the result is recorded against the farmer's profile in FarmerIQ. Farmers may inspect their own record at any time.
• Calibrated weighing. Hub weighbridges are independently calibrated. Records of each weighing are retained.
• Cumulative payment record. Registration in FarmerIQ produces a payment history that supports each farmer's access to formal financial services over time.
• No coercion. Farmers are not required to deliver to our network. Participation is voluntary.

06Environmental responsibility

The commodities we facilitate finance for are agricultural. Their long-term viability depends on the long-term health of the land. We commit to:

• Encourage agronomic practices that maintain soil health, water quality, and biodiversity in the regions in which our network operates.
• Decline to verify or facilitate finance for trades whose source-of-supply involves illegal deforestation, encroachment on protected areas, or other environmentally unlawful activity.
• Cooperate with sectoral initiatives on traceability and deforestation-free supply (including the EU Deforestation Regulation framework and equivalent regimes) where applicable to the commodity and corridor.
• Minimise the environmental footprint of our own operations through reasonable measures appropriate to our size.

07Conflicts of interest

Conflicts of interest within our operations are disclosed to every counterparty under non-disclosure agreement and are managed through documented structural controls. We do not rely on assurance alone to manage conflicts: we rely on contractual tier separation, immutable settlement sequences, and independent oversight.

Our board of directors and (once formed) advisory board provide independent oversight of programme governance. Material conflicts are reviewed and where appropriate disclosed in writing to affected counterparties.

08Data protection and confidentiality

We treat farmer data, counterparty data, and personal data of any employee or contractor as confidential. Our practices are documented in our Privacy Policy, and align with the Ghana Data Protection Act 2012 and, where relevant, the EU General Data Protection Regulation. Data we collect is used for the purposes for which it was collected and not for any other purpose without consent.

09Health and safety

Hub operations involve weighbridges, vehicles, manual handling and physical infrastructure. We commit to operating safe workplaces, providing necessary protective equipment, training operators, and reporting and learning from incidents.

10Workplace conduct

We commit to a workplace free from harassment, discrimination, bullying or intimidation. We make decisions about hiring, advancement, compensation and termination on merit and without regard to ethnicity, religion, gender, age, sexual orientation, disability, or any other protected characteristic. We promote a culture in which concerns can be raised without fear.

11Whistleblowing

12Compliance and review

This Code is reviewed annually by our board of directors. Material amendments are published on this page with an updated effective date. Our advisory board (under formation) will provide independent oversight of compliance.

Counterparties wishing to review our compliance documentation in greater detail are invited to make contact under non-disclosure agreement.

13Contact

This Code of Conduct is approved by the Board of Directors of Miziba Infrastructure Ltd and is subject to annual review.