Supply Chain Policy

Foreword

As a leading gold trader and exporter, M&C Logistics and Trading Limited conducts all its business to the highest ethical, moral, and social responsibility standards. Integrity, honesty, and transparency are the foundations of our business.

Scope

This Supply Chain Policy applies to all gold sourced and handled by M&C Logistics and Trading Limited and to all of its business partners engaged in mining, refining, manufacturing, and trading of the precious metal. It does not apply to general procurement (e.g., office furniture, food, energy, etc.) or other transactions outside the precious metal supply chain. Our business partners are mostly miners, refiners, metal traders, and jewelers. All material and potential risks are monitored and mitigated in everything we do, from sourcing our gold to trading or exporting.

We are aware of the risks of inadvertent involvement in or contribution to illegal practices that may be associated with the extraction, processing, trading, handling, and exporting of precious metals from any area, particularly from conflict-affected and high-risk areas.

Our Commitment

Our commitment includes, but is not limited to:

• Combatting human rights abuses, including the use of child, forced, or compulsory labour, human trafficking/smuggling, and slavery or servitude, whether involving adults or children associated with the extraction, transportation, or commercialization of minerals.
• Avoiding contributing to any conflict.
• Complying with anti-money laundering (AML) standards.
• Complying with standards on combatting the financing of terrorism (CFT).
• Excluding any direct or indirect support to state and non-state armed groups and/or illegally acting public or private security forces.
• Avoiding bribery and fraudulent misrepresentation of the origin of precious metals.
• Ensuring the payment of taxes, fees, and royalties due to governments.
• Defining clear rules for responsible sourcing.
• Supporting the legitimization, professionalization, and formalization of Artisanal and Small-Scale Mining (ASM) entities and their trading partners.

The Precious Metals Sourcing Process

Regarding the precious metals sourcing process, M&C Logistics and Trading Limited commits to:

• Neither tolerate, nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of serious abuses associated with the extraction, transport, refining, or trade of minerals.
• Not enter into any business relationship, or immediately suspend or discontinue engagement with business partners supplying precious metals where we identify a reasonable risk that they are sourcing from, or are linked to, any party committing serious abuses.
• Not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of precious metals. This includes, but is not limited to, procuring gold from, making payments to, or otherwise providing logistical assistance or equipment to non-state armed groups.
• Not enter into any business relationship, or immediately suspend or discontinue engagement with upstream suppliers, where we identify a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups.
• Recognize that the role of public or private security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment, and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.
• Not offer, promise, give, or demand any bribes, and resist the solicitation of bribes to conceal or disguise the origin of precious metals, to misrepresent taxes, fees, and royalties paid to governments for the purposes of precious metals extraction, refining, trade, handling, transport, and export.
• Support efforts, and/or take steps, to contribute to the effective elimination of money laundering as well as terrorism financing where we identify a reasonable risk of such illegal practices resulting from, or connected to, the extraction, trade, handling, transport, or export of precious metals derived from the illegal taxation or extortion of precious metals at points of access to mine sites, along transportation routes, or at points where precious metals are traded by upstream participants in the supply chain.
• Systematically perform enhanced due diligence practices, including Know Your Customer (KYC), Anti-Money Laundering (AML), and Combating Financing of Terrorism (CFT) control procedures, adopting a risk-based approach, before entering a business relationship with any precious metals supplying or trading business partners and implement a management strategy to respond to identified risks.
• Buy ASM gold, provided that ASM activities are legitimate and that risks are identified and managed accordingly. We will not consider ASM mining activities as legitimate when they contribute to conflict and serious abuses associated with the extraction, refining, transport, or trade of minerals.
• Only deal through official banking channels for financial and precious metals transactions.
• Adequately store and maintain all records and documentation relating to the precious metals supply chain to demonstrate that appropriate and ongoing due diligence has been performed.
• Expect that our suppliers conduct business in a way that protects the environment and minimizes potential environmental impact their activities may generate. They should take a systematic approach allowing them to manage their environmental risks in compliance with applicable environmental laws and regulations and to seek to continuously improve environmental performance. Policies and procedures should be in place to handle any hazardous products and materials and to guide the way they conduct their activities to prevent incidents, and should an incident occur, to mitigate the consequences that may have an impact on the environment.

Training Program

M&C Logistics and Trading Limited has a robust training program to educate employees in implementing and maintaining the company’s Supply Chain Policy Program.