This policy sets out AuHandel’s commitments to:

• Support responsible environmental practices in business relationships connected to AuHandel’s gold transactions.
• Consider environmental risk indicators within our risk-based due diligence where relevant.
• Operate our own activities in a responsible manner.
• Promote continuous improvement.

This policy applies to:

• AuHandel’s internal operations (administrative activities and any business travel).
• Counterparty onboarding and transaction review where environmental risk is relevant to sourcing footprint or transaction profile.
• Relevant service providers (e.g., logistics/custody providers) where environmental performance may affect risk or reputational exposure.
• AuHandel does not own or operate mining or refining facilities and does not claim direct operational control over upstream environmental impacts. This policy therefore focuses on expectations, screening, and engagement consistent with AuHandel’s role.

AuHandel commits to:

• 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.

Depending on the transaction and risk profile, AuHandel may consider:

• Whether the counterparty operates in or sources from areas with known elevated environmental risk.
• Whether credible information indicates serious environmental harm or repeated regulatory non-compliance.
• Whether environmental performance issues may be linked to broader integrity or human rights risks (e.g., unsafe practices, illegal operations).
• Examples of environmental red flags (non-exhaustive):
• Credible allegations of illegal dumping, uncontrolled pollution, or significant environmental harm connected to supply chain participants.
• Repeated, serious breaches of environmental regulations.
• Evidence of illegal or unlicensed operations linked to supply chain activities.
• Refusal to provide basic information when environmental risk is relevant and material.
• Environmental red flags may trigger additional inquiries, enhanced due diligence, conditions on engagement, or refusal.

AuHandel expects relevant counterparties to:

• Comply with applicable environmental laws and licensing requirements.
• Maintain reasonable environmental management practices appropriate to their role.
• Cooperate with proportionate due diligence requests where environmental risk is material.
• Notify AuHandel of material incidents or enforcement actions that may affect risk.
• AuHandel may require additional information or credible assurance where the risk profile is elevated.

Within the scope of our own operations, AuHandel aims to:

• Minimise unnecessary travel where practical.
• Use digital documentation and communication to reduce paper use where feasible.
• Choose service providers where environmental responsibility aligns with reliable execution and compliance expectations.
• (These commitments are proportionate to the scale and nature of AuHandel’s operations.)

Concerns relating to environmental harm connected to AuHandel’s business relationships may be reported via:

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

• Senior management is accountable for this policy.
• Environmental considerations are integrated into the risk-based due diligence approach where relevant.
• This policy is reviewed at least annually and updated as needed based on operational changes or evolving risk context.