Purpose

To describe governance, approval, review cadence, and accountability expectations for AuHandel/Balmeringa GmbH public policy statements and related internal procedures.

Scope

• Applies to all AuHandel/Balmeringa GmbH policies published on this website and related internal procedures.

Commitments / controls

• Maintain management oversight of published policies and ensure implementation through procedures and controls appropriate to operations.
• Review policies at least annually and when material changes occur (regulatory, operating model, risk profile, incidents, or learnings).
• Provide a grievance channel for stakeholders and apply non-retaliation principles for good-faith reporting.

Purpose

AuHandel is committed to responsible sourcing of gold and to conducting business with integrity, transparency, and respect for human rights. We seek to prevent, identify, and address risks of adverse impacts connected to gold sourcing and trade, including risks related to conflict, money laundering, terrorism financing, bribery, fraud, and serious human rights abuses. This policy is implemented through a risk-based due diligence system aligned to internationally recognised guidance for minerals from conflict-affected and high-risk areas, including the OECD due diligence framework and expectations reflected in RJC-aligned practice.

Scope

• AuHandel operates as a brokerage / principal trading counterparty in the physical gold market.
• AuHandel does not refine and does not claim to be a refiner.
• This policy covers:
• Gold-bearing materials and refined gold products that AuHandel buys, sells, arranges, or finances (where applicable),
• All counterparties (suppliers, intermediaries, logistics, service providers) involved in AuHandel transactions,
• All jurisdictions in which AuHandel operates or sources from.

Commitments / controls

• Respect human rights in line with international expectations and apply due diligence to identify, prevent, mitigate, and account for adverse human rights impacts.
• Implement a risk-based due diligence program consistent with the OECD 5-step framework (management systems, risk assessment, risk management, independent review/verification where applicable, and reporting).
• Apply enhanced scrutiny for Conflict-Affected and High-Risk Areas (CAHRAs) and other elevated-risk contexts, using credible sources and documented assessment.
• Maintain zero tolerance for severe abuses, corruption, and illicit finance connected to gold.
• Provide a grievance mechanism that is accessible, protects confidentiality, and supports responsible follow-up and remediation.
• Continuously improve our responsible sourcing program through periodic review, training, and updates when risk context changes.

Purpose

AuHandel respects internationally recognised human rights and is committed to:

Scope

• AuHandel’s operations and decision-making,
• Counterparty onboarding and transaction execution processes, and
• Relevant business relationships connected to AuHandel’s gold trading and sourcing activities.
• AuHandel does not refine gold and does not engage in retail bullion sales.

Commitments / controls

• Avoid causing or contributing to adverse human rights impacts through our activities, and
• Seeking to prevent or mitigate adverse impacts directly linked to our operations, products, or services through business relationships, even if we have not contributed to those impacts.
• We apply a risk-based approach and will prioritise heightened scrutiny where human rights risks are more likely to occur.

Purpose

The purpose of this policy is to define how AuHandel:

Scope

• Gold and gold-bearing materials involved in AuHandel’s activities (buying, selling, brokering, arranging, or otherwise facilitating institutional transactions), and
• All relevant counterparties and service providers involved in those transactions (including intermediaries, logistics, custody, and other service providers).
• AuHandel does not refine gold and does not engage in retail bullion sales.

Commitments / controls

• Risk-based: depth of checks increases with risk indicators
• Proportionate: commensurate with our role and available visibility
• Documented: decisions and evidence are recorded
• Escalation-driven: elevated risk requires senior review
• Continuous: periodically reviewed and improved

Purpose

To identify and manage CAHRA-related risks in gold transactions and related business relationships, ensure heightened scrutiny and senior oversight for elevated-risk contexts, and prevent contributing to conflict, serious human rights abuses, or illicit financing.

Scope

• Applies to all directors, employees, contractors, and third parties acting for or on behalf of AuHandel; and informs expectations of counterparties.
• Applies to gold transactions and business relationships with actual or potential exposure to CAHRA-related risks (counterparties, sourcing footprints, transport routes, and transaction structures).
• AuHandel is an institutional gold brokerage/trading counterparty and does not refine gold.

Commitments / controls

• Apply enhanced due diligence (EDD) where CAHRA indicators are present.
• Escalate CAHRA-related cases to senior management for documented review and decision.
• Decline or disengage where credible risks cannot be mitigated, including indicators of severe abuses or support to armed groups.
• Maintain documentation of screening inputs, assessment rationale, mitigation measures, and decisions.

Purpose

To prevent and mitigate money laundering and terrorism financing risks, conduct risk-based counterparty due diligence (KYC) and monitoring, identify and escalate suspicious activity indicators, and maintain appropriate records for audit readiness and legal compliance.

Scope

• Applies to all directors, employees, contractors, and any third parties acting for or on behalf of AuHandel; and informs expectations of counterparties.
• Applies to all transactions and business relationships involving AuHandel, including brokerage/execution arrangements and institutional gold trading activity.
• Applies to counterparties (suppliers, buyers, intermediaries) and relevant service providers (e.g., logistics/custody/payment-related service providers where relevant).
• AuHandel does not engage in retail bullion sales.

Commitments / controls

• Apply risk-based counterparty due diligence and transaction review commensurate with risk.
• Identify and escalate higher-risk relationships and apply enhanced due diligence (EDD) as needed.
• Decline or disengage where risks cannot be mitigated to an acceptable level, where information is materially inconsistent, or where there are credible indicators of illicit finance.
• Maintain appropriate records and documentation supporting onboarding and transaction decisions.
• Train relevant personnel on AML/CTF red flags and escalation procedures.

Purpose

To prevent bribery and corruption in all forms, manage gifts/hospitality and conflicts appropriately, ensure third parties meet equivalent standards, and provide a safe channel for raising concerns.

Scope

• Applies to all directors, employees, contractors, and any third parties acting for or on behalf of AuHandel; and informs expectations of counterparties and intermediaries.
• Applies to all AuHandel business activities and relationships, including interactions with public officials and private parties.
• Covers gifts, hospitality, sponsorships, charitable contributions, and any benefits provided or received in connection with AuHandel’s activities.

Commitments / controls

• Conduct business ethically and lawfully and prohibit bribery and corruption in any form.
• Maintain proportionate controls to identify and manage corruption risks in relationships and transactions.
• Require third parties and counterparties (where appropriate) to meet integrity expectations and cooperate with due diligence.
• Escalate, investigate, and take action on credible concerns without retaliation.

Purpose

To support responsible environmental practices in business relationships connected to AuHandel’s gold transactions, consider environmental risk indicators where relevant, operate our own activities responsibly, and promote continuous improvement.

Scope

• Applies to all directors, employees, contractors, and any third parties acting for or on behalf of AuHandel; and informs expectations of relevant counterparties.

Commitments / controls

• Comply with applicable environmental laws and regulations relevant to our operations.
• Consider environmental risks and red flags as part of our risk-based due diligence where relevant to the transaction context.
• Prefer engagement with counterparties who demonstrate lawful compliance and responsible environmental management.
• Encourage transparency and continuous improvement where feasible and appropriate.
• Maintain documentation of environmental risk considerations where they are material to due diligence decisions.

Purpose

To protect the health, safety, and wellbeing of our personnel, and to identify and manage hazards and risks across office work, meetings, travel, and any site visits connected to transactions.

Scope

• Applies to all AuHandel work activities, including office work, meetings, travel, and any visits to third-party sites or facilities.
• Applies to all personnel and representatives acting for AuHandel.

Commitments / controls

• Provide and maintain a safe work environment and safe systems of work appropriate to our activities.
• Identify hazards and implement reasonable controls to reduce risk.
• Comply with applicable workplace health and safety laws and regulations relevant to our operations.
• Encourage timely reporting of hazards, incidents, and near misses.
• Prohibit retaliation against personnel who raise health and safety concerns in good faith.

Purpose

To set out who can raise concerns, what can be reported, how reports are handled, and AuHandel’s non-retaliation commitments.

Scope

• Applies to AuHandel/Balmeringa GmbH and any third parties acting on our behalf.
• Available to employees, contractors, counterparties, service providers, and external stakeholders (including impacted parties) who wish to raise concerns.

Commitments / controls

• Accessibility, predictability, confidentiality, and protection against retaliation for good-faith reporting.
• Fair and impartial assessment, proportional to severity and credibility.
• Learning-oriented approach: outcomes used to improve due diligence and controls.