The purpose of this policy is to:

• Define AuHandel’s approach to identifying and managing CAHRA-related risks in gold transactions and related business relationships.
• Ensure heightened scrutiny and senior oversight for elevated-risk contexts.
• Prevent AuHandel from contributing to conflict, serious human rights abuses, or illicit financing.

This policy applies to:

• All gold transactions and business relationships where there is actual or potential exposure to CAHRA-related risks, including through counterparties, sourcing footprints, transport routes, and transaction structures.
• AuHandel is an institutional gold brokerage/trading counterparty and does not refine gold.

Conflict-affected and high-risk areas (CAHRAs) include areas experiencing armed conflict, widespread violence, fragile post-conflict settings, weak governance, or systematic violations of international law or human rights, and areas where corruption, criminality, and illicit finance risks are elevated.

• (Practical note: AuHandel uses credible and current sources to inform CAHRA screening and will treat the classification as dynamic.)

AuHandel commits to:

• 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 where there are indicators of severe abuses or support to armed groups.
• Maintain documentation of CAHRA screening, assessment rationale, mitigation measures, and decisions.

AuHandel screens for CAHRA-related risks using a combination of:

• Counterparty information (jurisdiction, sourcing footprint, operating profile).
• Transaction context (routes, custody/logistics, settlement structure).
• Credible external sources (e.g., reputable multilateral guidance, government advisories, recognised risk indices, and other credible information providers).
• Internal red flags and risk intelligence.
• Examples of CAHRA-related indicators include:
• Supply chain links to jurisdictions with armed conflict, widespread violence, or systemic abuses.
• Evidence or credible allegations of extortion, illegal taxation, or coercion along routes.
• Attempts to obscure origin, routing, or chain-of-custody information.
• Unusual or opaque settlement structures consistent with illicit finance risk.
• Any credible association with armed groups or abusive security forces.

When CAHRA indicators exist, AuHandel will apply EDD measures proportionate to risk, which may include:

• 6.1 Additional information and corroboration — more detailed counterparty ownership/control checks (where applicable); additional transaction documentation and explanations; additional origin-related information to the extent feasible and not misleading; additional verification of logistics/custody arrangements; clear explanation of payment/settlement structure and beneficiaries.
• 6.2 Heightened integrity checks — expanded screening for adverse information; bribery/corruption risk scrutiny (including any facilitation payment requests); verification of documentation consistency and plausibility checks.
• 6.3 Senior management escalation and approval — CAHRA-exposed transactions require senior review before proceeding; decisions must be documented including rationale and any mitigation plan.
• 6.4 Conditions and controls (risk mitigation plan) — restrictions on payment channels (e.g., no third-party payments without documented justification); additional documentary requirements; limits on transaction size/frequency pending satisfactory performance; defined timelines for risk mitigation and follow-up checks. AuHandel documents mitigation measures and monitors performance.

AuHandel will typically decline or disengage where any of the following are present and cannot be credibly ruled out:

• 7.1 Severe abuses — credible indicators of forced labour, worst forms of child labour, trafficking; torture, cruel/inhuman treatment, widespread sexual violence; war crimes, crimes against humanity, genocide.
• 7.2 Support to armed groups or abusive security forces — credible indicators of direct or indirect support to illegitimate non-state armed groups, or illegitimate public/private security forces through sourcing, payments, extortion, or material assistance connected to gold trade.
• 7.3 Corruption and illicit finance — bribery or kickback demands; material fraud or misrepresentation of origin/routing; credible money laundering or terrorism financing risks.
• 7.4 Non-cooperation with due diligence — refusal to provide reasonable information; repeated inconsistencies; attempts to circumvent controls.

For CAHRA-related reviews, AuHandel maintains records of:

• CAHRA screening inputs and sources used.
• Risk assessment and classification.
• EDD steps taken and evidence received.
• Decisions, approvals, and mitigation plans.
• Monitoring actions and outcomes.
• Records are retained consistent with legal and operational requirements.

AuHandel provides periodic training to relevant personnel on:

• CAHRA concepts and risk indicators.
• Escalation triggers and documentation standards.
• Integrity risks (corruption, fraud).
• Interaction with AML/CTF controls.

Concerns related to CAHRA exposure or adverse impacts may be reported via:

• Email:complaints@auhandel.com
• AuHandel handles reports discreetly and prohibits retaliation for good-faith reporting.

This policy is reviewed at least annually and whenever there is a material change in:

• Operating footprint.
• Geopolitical or regulatory environment.
• Risk intelligence relevant to AuHandel’s gold transactions.