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This policy should be read together with the full suite of Spektrum’s policy statements.

The global transition from fossil fuels-based economy towards a decarbonised economy is an existential challenge of our time. 

Decarbonisation is essential, but projects that proceed without legitimacy — including Indigenous consent — do not endure. 

Spektrum unlocks investable projects in politically and socially complex environments, contributing to the timely production of minerals required for the transition.  

We aim to contribute to a just transition. 

This policy applies to all Spektrum activities and partnerships. Indigenous consent and governance are conditions of project progression and capital deployment. 

We recognise that acceptance cannot be assumed or managed. Legitimacy must be earned through informed participation, Indigenous decision-making, and durable consent. 

We recognise Indigenous Peoples as rights-holders with inherent authority over their lands, waters, and communities, and we work on the basis of their governance, decision-making processes, and priorities. 

We recognise that Indigenous communities are not homogenous and that histories of harm, governance arrangements, and cultural authority vary by place. Engagement must therefore be locally grounded and context specific. 

We operate consistently with:  

• EU environmental law and safeguards  

• EIB Environmental & Social Standards  

• World Bank Environmental and Social Framework  

• IFC Performance Standards  

• SFDR Article 8 and Article 9 requirements (where relevant to capital alignment)  

• UN Guiding Principles on Business and Human Rights  

• UN Declaration on the Right to Development  

• UN Declaration on the Rights of Indigenous Peoples (UNDRIP), including FPIC  

Foundational principles 

In pursuing our approach, we are guided by the following principles:

1. Indigenous self-determination and UNDRIP
   We acknowledge the inherent rights of Indigenous Peoples, consistent with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP). 

2. Living FPIC
   We treat Free, Prior and Informed Consent (FPIC) as a continuous, auditable process that may result in consent, conditional consent, non-consent, or withdrawal. Our development process includes seven defined stages, within which the possibility of withdrawal of consent is recognised and respected. Following agreement and investment, we ensure that robust monitoring, governance, and escalation mechanisms are in place to uphold the terms of consent and to address new or emerging concerns over the life of the project. 

3. First Peoples cultural heritage

   We recognise that cultural heritage is living, interconnected, and inseparable from Country and community governance. 

Where domestic legal frameworks fall short of international standards, we seek to operate consistently with UNDRIP and Dhawura Ngilan principles. The Dhawura Ngilan principles include Respect and Self-Determination; Collaboration and Consent; Truth and Holistic Heritage; Caring for Country and Culture; Supporting Indigenous Peoples Prosperity; and Advocacy and Leadership. 

Operational Approach — Indigenous consent and governance resolution

Our operating approach:

1. Early consent diagnostics 

   Identify rights-holders, cultural authority, representative institutions, and unresolved grievances — without presuming representation or consent. Map consent risk drivers and governance gaps early. 

2. FPIC pathway co-design

   Agree scope, information, timeframes and community decision processes. Define how outcomes will be recorded, including consent conditions, non-consent or withdrawal. 

3. Handling contested or divided positions 

   Diagnose sources of division (representation, benefit-sharing, legacy harm). Design mediated processes that respect customary decision-making while preventing coercion. 

4. Governance design for durability 

   Establish joint governance arrangements (monitoring, triggers, roles, dispute resolution) that operate over the life of the asset and align with community institutions. 

5. Grievance and remedy 

   Provide a safe, accessible grievance mechanism with clear Service Level Agreements and escalation, and track remedies to ensure effectiveness and non-retaliation. 

6. Consent conditions 

   Define transparent, pre-agreed criteria for advancing, pausing or halting projects based on FPIC status, conflict diagnostics, and legal defensibility. 

7. Documentation and assurance 

   Maintain an auditable trail: disclosures, consultation minutes, FPIC status, governance terms, grievances, and decisions. Independent review may be used to strengthen credibility. 

This policy should be read together with the full suite of Spektrum’s policy statements.

1. Purpose — Preventing environmental conflict and securing durability

The energy transition demands new minerals, but projects fail when environmental risks (water, biodiversity, cumulative and regional impacts) escalate into social conflict, litigation and reputational harm. These risks are not abstract values; they are determinants of operability, legal defensibility and bankability over the life of the asset.

Spektrum’s role is to address environmental legitimacy risk upstream by identifying and resolving conflict drivers and cumulative impacts before financing – so that projects are designed to withstand social, ecological, regulatory, and legal scrutiny over time — not merely to meet minimum statutory requirements.

We operate consistently with:

• EU environmental law and safeguards

• EIB Environmental & Social Standards

• World Bank Environmental and Social Framework (ESF)

• IFC Performance Standards

• SFDR Article 8 and Article 9 requirements (where relevant to capital alignment)

• UN Guiding Principles on Business and Human Rights

• UN Declaration on the Right to Development

• UN Declaration on the Rights of Indigenous Peoples (UNDRIP), including FPIC (where environmental decisions intersect with Indigenous rights)

Our purpose is to strengthen safeguards by making environmental decisions robust and irreversible – designing, sequencing, and documenting them so they withstand scrutiny from auditors, courts, inspectors‑general and civil society.

2. Foundational principles

• Institutional alignment is foundational

  By operating consistently with globally recognised frameworks, we provide institutions confidence that our role is integral to risk management, not symbolic alignment.

• Grounded in reality, not rhetoric

  We recognise a core development reality: commodities are essential, but they cannot be secured at the expense of biodiversity, water systems or climate stability. Our approach integrates these constraints into project design from inception, ensuring long‑term operability and defensibility.

• Science matters 

  Our decisions are grounded in independent, objective expertise and sound engineering. We do not commission advice for validation; we rely on credible sources and act on it, even when inconvenient. By embracing rigorous assessment at every stage, we ensure projects remain resilient, adaptive, and defensible under scrutiny.

• Closing the gap between compliance and durability

  Technical compliance alone does not prevent conflict. We address the systemic gap where compliant projects still fail by diagnosing conflict triggers early and redesigning projects to remove or mitigate those risks before financing.

• Cumulative and regional impact lens 

  We look beyond individual project footprints to understand combined pressures across a region and over time. By modelling water, biodiversity, and socio-environmental baselines at a regional scale, we anticipate and manage risks that commonly lead to conflict or litigation – strengthening long-term defensibility.

• Water security first  

  Water is not a secondary consideration – it is a gating condition for project viability and approval certainty. By prioritising water security and cultural values, we reduce litigation exposure and strengthen institutional confidence.

• Nature Positive as a strategic safeguard

  We strive toward Nature Positive outcomes, recognising that full achievement is not possible – but measurable progress materially reduces long-term risk. Our commitment goes beyond compliance: we aim for measurable biodiversity gains wherever feasible, reducing residual impacts and restoring ecosystems. This approach is not aspirational; it is a deliberate risk control that strengthens project defensibility and institutional confidence over time.

• Designing out risk before capital commitment

• We integrate risk elimination into project design and sequencing – removing conflict drivers such as water, dust, noise and tailings before they harden into liabilities.

3. Operational approach — how we resolve environmental conflict upstream

Spektrum’s operational approach converts compliance into durability and bankability by addressing environmental risks before financing. Our methods are designed to give confidence that projects will remain defensible over time.

• Early diagnostics

  We identify environmental risks most likely to trigger opposition – such as water stress, biodiversity fragmentation, cumulative impacts, and legacy issues – at the earliest stage, mapping exposure and stakeholder dynamics.

• Cumulative impact modelling

  We build regional baselines and scenario models to quantify thresholds and tipping points across multiple projects and jurisdictions, ensuring decisions anticipate cross-boundary effects.

• Risk-responsive design

  We redesign footprints, phasing and technology choices to remove or materially reduce conflict drivers before capital commitment, documenting why selected options represent the least-regret pathway.

• Managing uncertainty as a risk driver

  We treat uncertainty itself as a source of institutional exposure. Instead of assuming unknowns will resolve over time, we plan for them. This means building conservative safety margins into project design, setting clear indicators that signal when conditions are changing, and defining pre-agreed responses if those indicators are triggered. Independent experts validate these measures to ensure they are credible, proportionate and auditable.

• Assurance through documentation

  Every material decision is backed by an auditable trail - covering methods, assumptions, alternatives analysis, stakeholder inputs and residual risk rationale

• Early-warning systems

  We install monitoring designed to detect leading indicators, not just lagging metrics, and link them to pre-agreed responses to prevent escalation into conflict or litigation.

• Consent conditions

  We establish transparent, pre-agreed criteria for advancing, pausing, or halting projects – grounded in conflict diagnostics, cumulative impact thresholds, and legal defensibility. This ensures decisions remain auditable and defensible, providing institutions with confidence in the integrity of the process and the robustness of development sequencing.

This policy should be read together with the full suite of Spektrum’s policy statements.

1. Purpose – building durable community relationships

Spektrum treats community legitimacy as a core condition of project viability.  Consent, participation, and fair process are not abstract values – they are practical safeguards that reduce conflict, strengthen trust, and ensure projects remain viable and defensible over time.  Projects that lack procedural integrity are vulnerable to opposition, delay, and loss of confidence from regulators, communities, and capital. Our approach is therefore designed to embed legitimacy early and sustain it throughout the life of a project. This policy applies across the full project lifecycle, including development, construction, operation, modification, and closure.

We operate consistently with:

• EU environmental law and safeguards

• EIB Environmental & Social Standards

• World Bank Environmental and Social Framework

• IFC Performance Standards

• SFDR Article 8 and Article 9 requirements (where relevant to capital alignment)

• UN Guiding Principles on Business and Human Rights

• UN Declaration on the Right to Development

• UN Declaration on the Rights of Indigenous Peoples (UNDRIP), including FPIC

2. Foundational principles

• Alignment with international standards
  Our processes are aligned with globally recognised frameworks to ensure consistency, credibility and confidence in the integrity of our approach across jurisdictions.

• Procedural fairness and transparency
  Engagement is conducted through clear, inclusive, and documented processes.  Decisions are made through transparent, fair processes, with clear grievance pathways and records that remain defensible over time.

• Inclusive participation
  We identify and address barriers to participation particularly for vulnerable or marginalised groups to ensure meaningful engagement and equitable outcomes. We recognise that development often occurs within contexts of unequal power, access to information, and resources, and we design engagement processes to address these imbalances

• Community health, safety and wellbeing
  We anticipate, assess and seek to avoid adverse impacts on community health and safety and design proportionate measures to protect wellbeing. 

• Shared benefits and development
  We strive for outcomes that reflect meaningful participation and fair distribution of benefits, contributing to sustainable development and regional development.

3. Operational approach — how we put principles into practice

• Stakeholder mapping and early diagnostics

  Identify affected communities, legitimate representatives, and vulnerable groups early. Diagnose consent and legitimacy risks before project decisions are made.

• Stakeholder engagement plan

  Develop and maintain a clear plan for engagement, including information disclosure, consultation processes, inclusion measures, and timelines. 

• Procedural fairness protocols

  Document trade-offs, dissenting views, and decision rationales. Ensure transparency and accessibility of records.

• Decision alignment 

  Findings from community engagement, consent diagnostics, and grievance processes directly inform investment decisions, project sequencing, and go/no-go determinations.

• Grievance mechanism

  Implement a safe, accessible, and culturally appropriate grievance mechanism with clear steps for acknowledgement, investigation, and resolution. 

• Remedy
  Where adverse impacts are identified, Spektrum works with affected parties to design and implement appropriate remedies, and to prevent recurrence.

• Consent conditions

  Define clear criteria for advancing, pausing, or halting projects based on consent status, conflict diagnostics, and legal defensibility – so decisions remain auditable and fair.

• Documentation and assurance

  Maintain an auditable trail of engagement activities, grievances, remedies, and decisions. Independent review may be used to strengthen credibility.

• Independent review

  Independent review may be used where appropriate to strengthen credibility, resolve contested issues, or provide assurance to communities, regulators, or capital partners.

All Spektrum Development policies are bound by our shareholder commitments, values, and purpose. The board reviews and approves this policy every three years to ensure it continues to meet the expectations of shareholders, staff, and the communities we support.

Our code of conduct and ethics policy is founded on our belief that ethical business and conduct is fundamental to our operations on projects and internally as an organisation. We align with the following:

• Exemplify our values and behaviours as they are our identity as an organisation: Not least of all are transparency, accountability, and collaboration

• We acknowledge and respect the reality of cultural differences and are wary of projecting one cultures values on other culture

• We seek to observe best practice standards

• Speak out culture where everyone is encouraged to communicate concerns, challenge decisions and speak honestly about risks and misconduct without fear of retaliation.

We underpin those principles with our five key areas to ensure we move beyond rhetoric to achieve transformational results.

1. Anti-corruption:

• We do not engage with any form of bribery or corruption

• We observe the UN Convention Against Corruption even where not legally required in the country/s in which we are operating.

• We observe the standards of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Our anti-corruption compliance program is being developed to be consistent with Transparency International’s Business Principles for Countering Bribery.  We observe the national applicable laws and regulatory developments of nations in which we operate, not least of all the Australian Criminal Code Act 1995 (Cth)

• We treat each dealing as a transaction on commercial terms and make clear there are no implied downstream benefits or reward

• We hire and reward on merit irrespective of family or other connections

• We require accurate and complete report of all gifts or personal benefits (excluding travel rewards programs) more than $100USD

• We do not make transfers between personal accounts and company accounts other than approved, accurate, and tax-compliant expense claims

• We avoid partnering with or dealing with organisations that have unclear beneficiary ownership structures

2. Respect at work:

• Harassment (sexual, racial, humiliation), discrimination, bullying will not be tolerated within Spektrum

• Staff are not required or expected to participate in assignments that place them in disrespectful environments

• We encourage accurate and complete reporting of all incidents

• We are committed to the ILO Declaration on Fundamental Principles and Rights at Work

3. Human rights:

• We treat human rights as universal as defined by the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.

• Operating in a manner consistent with the United Nations (UN) Guiding Principles on Business and Human Rights (UNGPs) and the 10 UN Global Compact Principles.

• Operationalise the UN Declaration on the Rights of Indigenous Peoples as set out in our Indigenous People’s policy

• Partners are required to demonstrate respect for human rights, evidenced by their management systems and responsible sourcing including modern slavery and commitment to net zero goals congruent to those of Spektrum

• We encourage staff and partners to identify and report risks to any persons that may be impacted through the actions of our company 

4. Protect others and the company:

• We trust directors and staff to be able to identify and protect confidential company information, including IP, in-line with our confidentiality and privacy policy. Staff are required to report any breach immediately and make reasonable attempts to immediately address the issue.

• We encourage the proactive identification and reporting of risks to our people, our commercial goals, partners, communities, and investors.

5. Insider trading:

• Our partners and projects trust us to implement systems and policies to protect highly sensitive information

• We do not share information – gained through involvement or interactions with Spektrum – with other parties within Spektrum or externally, unless authorised to do so.

• We will report the use of insider information about Spektrum or our dealings to the relevant authorities.

• We request that company staff, partners, and advisers do not trade in any securities related to our work prior to that information being publicly available. We make declarations and procedures available to manage existing investments and to declare any conflicts of interest.