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.

• 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.

AuHandel commits to:

• 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.

AuHandel will not tolerate, profit from, contribute to, assist with, or facilitate any party’s involvement in:

• 4.1 Severe abuses associated with extraction, transport, or trade
• Torture, cruel, inhuman, or degrading treatment
• Forced or compulsory labour
• Worst forms of child labour
• Widespread sexual violence or other gross human rights abuses
• War crimes, serious violations of international humanitarian law, crimes against humanity, or genocide
• 4.2 Support to illegitimate armed groups or illegitimate security forces
• AuHandel will not directly or indirectly support illegitimate non-state armed groups or illegitimate public/private security forces through sourcing, payments, logistics, or material assistance linked to illegal control, taxation, or extortion at mine sites, routes, or trading points.
• 4.3 Bribery, fraud, and misrepresentation
• AuHandel prohibits offering, promising, giving, requesting, or accepting bribes (including facilitation payments), and prohibits fraudulent misrepresentation of gold origin, documentation, taxes, fees, or royalties.
• 4.4 Money laundering and terrorism financing
• AuHandel will not engage in transactions where there is a reasonable risk of money laundering or terrorism financing, and will apply risk-based controls and escalation consistent with applicable AML/CTF expectations.

• AuHandel implements a risk-based program aligned to the OECD 5-step approach.
• Step 1 — Establish strong management systems
• AuHandel will:
• Maintain documented responsible sourcing governance and clear accountability (e.g., Compliance Lead / Responsible Sourcing Officer).
• Maintain counterparty onboarding procedures and retain records.
• Provide periodic training to relevant personnel on responsible sourcing, red flags, and KYC/KYP principles.
• Communicate this policy to counterparties and require cooperation with due diligence requests.
• Step 2 — Identify and assess risks in the supply chain
• AuHandel will assess risks proportionate to the transaction and counterparty profile, which may include:
• Counterparty identity, beneficial ownership, and legitimacy (KYC),
• Source of gold, chain of custody/traceability information to the extent available,
• Geography-based risks, including CAHRA screening and sanctions-related checks,
• Red flags related to corruption, cash-intensive structures, inconsistent documentation, unusual routes, or origin discrepancies,
• Human rights and labour risks associated with upstream contexts, especially where artisanal and small-scale mining (ASM) is involved.
• Step 3 — Design and implement a strategy to respond to risks
• Where risks are identified, AuHandel will implement a documented risk response that may include:
• Requesting additional documentation and clarifications,
• Enhanced due diligence (EDD) and senior management sign-off,
• Risk mitigation measures with defined timelines,
• Temporary suspension while investigating,
• Disengagement where risks are unacceptable or cannot be mitigated.
• Step 4 — Independent review / verification (as applicable)
• AuHandel will support credible assurance of due diligence where proportionate and applicable, including:
• Using reputable third-party audit reports, certifications, or equivalent assurance from counterparties where available,
• Periodic internal review of the due diligence program effectiveness and controls.
• (Notes: Your RJC toolkit materials emphasise the value of third-party assurance and audited systems as a source of confidence in supplier controls.)
• Step 5 — Reporting and transparency
• AuHandel will maintain appropriate transparency by:
• Keeping records of due diligence activities and decisions,
• Publishing a policy statement (this document) and periodically reviewing it,
• Where appropriate for the business, issuing a periodic high-level summary of responsible sourcing implementation and improvements (without disclosing sensitive counterparty information).

AuHandel expects counterparties to:

• Provide accurate, complete information related to identity, ownership, and the transaction,
• Not engage in the prohibited conduct outlined in Section 4,
• Maintain basic controls to manage risks in their own supply chains and cooperate with risk inquiries,
• Notify AuHandel of any material changes in ownership, operating model, or sourcing footprint.

• AuHandel maintains channels for stakeholders (including employees, suppliers, logistics partners, and impacted parties) to raise concerns about responsible sourcing risks.
• Reports may be made in good faith and may be anonymous where allowed by law. AuHandel will:
• Acknowledge receipt where feasible,
• Assess the concern and determine escalation and investigation steps,
• Protect confidentiality and prohibit retaliation,
• Where appropriate, develop an action plan for resolution and prevention.
• Contact / email (to publish): david@auhandel.com

AuHandel provides periodic training to relevant staff on:

• Responsible sourcing red flags and escalation,
• KYC/KYP principles and documentation integrity,
• Bribery/corruption risks,
• CAHRA risk awareness and information sources.

AuHandel retains due diligence records (onboarding, risk assessments, transaction documentation, decisions, and incident logs) for a period consistent with legal and operational requirements, and in a way that supports audit readiness.

This policy and the supporting procedures are reviewed at least annually and whenever risk context changes materially (e.g., new jurisdictions, new product forms, significant regulatory changes, or significant incidents). Continuous improvement is a core expectation of responsible business practices.