AuHandel respects internationally recognised human rights and is committed to:

• 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.

This policy applies to:

• 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.

AuHandel commits to the following:

• 3.1 Respect and non-discrimination
• We aim to treat people with dignity and respect and do not tolerate discrimination, harassment, or abusive conduct in our operations.
• 3.2 Zero tolerance for severe human rights abuses
• AuHandel maintains zero tolerance for the most severe forms of human rights abuse, including:
• Forced or compulsory labour
• The worst forms of child labour
• Human trafficking
• Torture, cruel, inhuman, or degrading treatment
• Widespread sexual violence
• War crimes, serious violations of international humanitarian law, crimes against humanity, or genocide
• Where credible indicators of such abuses exist and risk cannot be mitigated, AuHandel will decline or disengage from the relationship/transaction.
• 3.3 Responsible security practices
• AuHandel will not support illegitimate armed groups or illegitimate security forces and will treat extortion, illegal taxation, and coercion along supply chains as serious red flags requiring escalation and risk response.
• 3.4 Grievance mechanism and access to remedy
• AuHandel provides channels for raising concerns and is committed to non-retaliation for good-faith reporting. We will review concerns proportionately and take appropriate action, consistent with confidentiality and legal constraints.

AuHandel applies human rights due diligence commensurate with our role and risk exposure, and consistent with the “identify–prevent/mitigate–account” logic that underpins human rights due diligence.

• 4.1 Identify and assess
• We seek to identify human rights risks by:
• Incorporating human rights considerations into counterparty onboarding and transaction review,
• Screening for high-risk jurisdictions and contexts, including conflict-affected and high-risk areas,
• Looking for red flags such as inconsistent origin narratives, unusual transaction structures, or resistance to documentation,
• Considering upstream risk signals (including where artisanal and small-scale mining (ASM) may be involved).
• (Where upstream visibility is limited, AuHandel increases scrutiny and may require additional representations, documentation, or credible assurance from counterparties.)
• 4.2 Prevent and mitigate
• Where risks are identified, AuHandel may:
• Require additional information and corroboration,
• Apply enhanced due diligence and senior management approval,
• Impose conditions, controls, or limitations on engagement,
• Suspend transactions while investigating, or
• Decline/disengage if risks are unacceptable or cannot be mitigated.
• 4.3 Track and account
• AuHandel maintains records of relevant due diligence and decisions and reviews the effectiveness of its controls periodically.

AuHandel expects counterparties and relevant service providers to:

• Respect human rights and comply with applicable laws,
• Avoid involvement in the severe abuses listed in Section 3.2,
• Cooperate with reasonable due diligence requests (including identity/ownership and origin-related information where applicable),
• Notify AuHandel of material changes in ownership, control, or sourcing footprint that may affect risk.
• Failure to cooperate with due diligence, or credible indicators of severe abuse, may result in refusal or disengagement.

• Senior management has overall accountability for this policy.
• Designated personnel (e.g., Compliance Lead / Responsible Sourcing Officer) are responsible for implementing procedures, training, and escalation processes that support this policy.
• This policy is reviewed at least annually and updated as risk context changes.

Concerns about human rights (including potential adverse impacts connected to AuHandel’s business relationships) may be reported via:

• Email:complaints@auhandel.com
• AuHandel:
• Treats reports discreetly,
• Prohibits retaliation against good-faith reporting,
• Will assess and respond proportionately, and
• Will escalate credible severe allegations to senior management.

This Human Rights Policy should be read together with:

• Responsible Sourcing Policy
• Supply Chain Due Diligence Policy
• CAHRA Policy
• AML/CTF Policy
• Anti-Bribery & Corruption Policy
• Whistleblower & Grievance Mechanism