3. Responsible Selling

We believe that adopting a responsible approach to product sales is the key to an enduring customer relationship. Therefore, we are committed to conduct our business in an ethical way, as well as follow responsible practices in communication channels utilized (e.g. sales promotion, marketing practices and corporate communications, either written or verbal).

In July 2018, the Law 4557/2018 came into force and incorporated the 2015/849 EU Directive into the Greek legal system, in order to prevent use of the financial system for money laundering and terrorist financing.

Our customers include Smelters (i.e. metalworking factories which extract metals from their ores), Traders (who resell to smelters) or Agents (who buy our products on behalf of other customers). Although at the moment there is no sector-specific advertising/marketing policy or code and no responsible communication guides to follow, we follow our Corporate Values as a guide in our marketing practices, in order to implement responsible marketing activities and ensure that our communication practices are legal, reasonable, fair, truthful and realistic.

incidents of non-compliance with laws and regulations regarding marketing communications

The supply of raw materials from the mining sector supports a wide variety of industries. The overall increase in global demand has led us to analyze supply-associated risks, which however for the time being are considered as medium or low risk.

As all transactions related to precious metals are considered high-risk transactions according to Law 4557/2018, we are included in the Obliged Entities list and therefore must exercise customer transactions with certain care. In an effort to proactively address Anti-Money Laundering and Counter-Terrorist Financing issues, we implement a KYC (Know Your Customer) approach and examine aspects such as legal accusations, convictions and Politically Exposed Persons, as well as conduct due diligence on specific cases (e.g. when entering a business relationship or when occasional transactions exceed a certain threshold). Furthermore, we are obliged to report any suspicious business relationship or transaction and provide all required information to the competent supervisory authority (i.e. the Independent National Authority of Public Revenue).

of our customers visited and questioned through KYC (Know Your Customer) approach

Eldorado Gold, and by extension Hellas Gold, is guided by industry-specific responsible operation frameworks and standards, which include the Mining Association of Canada’s Towards Sustainable Mining standard, the Euromines membership and the World Gold Council’s Responsible Gold Mining Principles. Therefore, we: • Follow the World Gold Council’s Conflict-Free Gold

Standard to ensure that production of gold does not contribute to unlawful armed conflicts or human rights abuses, which requires from gold-producing sites to undergo human rights assessments • Do not produce any gold and gold-bearing materials in our

Olympias mine which cause, support or benefit unlawful armed conflicts, contribute to serious human rights abuses or breach international humanitarian law and do not accept or externally source gold or gold-bearing materials from third parties • Have assessed our product hazards according to the

UN Globally Harmonized System of Classification and Labeling of Chemicals, which includes various hazard classification criteria (e.g. physical hazards, environmental hazards) and communicate these hazards through appropriate safety data sheets, declarations and labeling • Do not have any proved or probable reserves in or near areas of active conflict (i.e. according to the Uppsala

Conflict Data Program).