1. Introduction

1.1. Extent
This policy applies to all SMB Sarl activities, including all of its agents and associates.

1.2. objectives
The claim policy aims to:

  • Offer SMB Sarl’s employees, suppliers, customers and any interested person, with means to enable him/her to report any deviation or violation of the relevant principles that guide the operation of the SMB Sarl.
    These claims are therefore based on the violation of the law or regulation (in particular the Mining Code, the mining regulations, the Labor Code), OECD guidelines on due diligence or any value or principle of the law. SMB Sarl.
  • Promote transparency in the activities of SMB Sarl. This is an effective deterrent for any SMB Sarl agent or any individual involved in his or her activities who is tempted to engage in conduct that is contrary to the law and the principles and values ​​of society.

2. Complaints to be transmitted

  • Any violation of the law, the requirement of security or any value of SMB sarl. These are also human rights violations (such as cases of murder or assault);
  • Anything related to corruption, extortion, bribe, violation of the company’s accounting principles, etc.;
  • Any question of the law and environmental principles;
  • Any violation of the laws and principles that undermine the proper functioning of the SMB;

3. Policy

3.1. Formulation, receipt and processing of complaints

3.1.1. From the formulation
By this policy, SMB encourages its employees, collaborators, suppliers or customers, and the public, to bring to the attention of the company any case of violation or deviation that could be identified or presumed in the course of its activities. However, it insists that any claim must be made “in good faith”, in order to fight against fanciful or slanderous claims.

Complaints, complaints or denunciations are made through the means of contact determined within the framework of this policy. This is a phone number (per call or mobile messaging or WhatsApp), an email address, personal contacts as well as mailboxes. See Appendix.

3.1.2. Warranties upon receipt and processing of claims anonymity
Claims are treated anonymously. Throughout the process, the identity / identities of the individual or group of individuals who have or have filed a claim must not be disclosed. Anonymity reduces the risk to the person who denounces or claims to be known by the person against whom the complaint or complaint is made. La mise en sécurité
The person making a claim or an information must be protected against any risk of reprisal. If it is primarily an agent of the SMB Sarl, it must be protected against any risk, including the risk of losing his job.
This protection applies only to an agent who claims or denounces in good faith. An agent who claims or denounces maliciously can not benefit from the protection of society. He may, if necessary, be disciplined. The surveys
Whenever a complaint or denunciation is made, investigations must be opened and ordered. They provide reassurance on the veracity of the facts alleged. They also allow, therefore, not to undertake disciplinary proceedings against agents who are the subject of malicious complaints or denunciations.

During the investigation, any agent of SMB, according to his skills, may be invited to contribute to the manifestation of the truth. However, the investigation remains secret. And the non-respect of this secrecy can be sanctioned disciplinarily.

If at the conclusion of the investigation, it is established that an agent or any person involved in the activities of the SMB Sarl has committed violations of the rules or principles governing the company, appropriate and proportionate measures are immediately taken. It may be a reprimand or a warning, a suspension, or a dismissal, depending on the legislation in force.

However, during or after the investigations, certain aspects reveal or suggest the commission of an offense, the competent public authorities are alerted to follow the case. In other words, the disciplinary procedure in progress in society can not constitute an obstacle or an obstacle to legal action.

4. Management and Claims Processing

At SMB, complaints are handled by the Communication Department. It is at this level that are managed the phone number (for call or SMS claim), the WhatsApp account, the email address and the mailbox provided for this purpose. It is also within this body complaints received by any other person – agent of the SMB or not – are reported

5. Validity of the policy

This policy takes effect on the date of its signature. It may be modified or improved as needed.




1. Telephone and SMS
There is a phone number set up to receive calls and SMS complaints and whistleblowing. This is a number of a local network, accessible to everyone.
Number: +243 897 225 724

2. Letter (Mailbox)
Complaints and denunciations can also be made by letters deposited in the mailboxes available on the sites and at each office of the SMB Sarl.

3. E-mail
Complaints, denunciations or any report can be made to the address

4. WhatsApp Network
Complaints and complaints can also be made via via WhatsApp at the following number: +243 897 225 724

5. Anyone
A person who wants to make a complaint or a complaint may, if he can not use one of the aforementioned means, confide in another who is able to report it to the Department of Communication SMB Sarl in confidence.

The reports are not subject to any formal requirements. People who want to do so do so freely, with only respect for good faith and secrecy.