The purpose of this policy is to define how AuHandel:

• Establishes governance and controls for responsible gold supply chains,
• Identifies and assesses risks in gold transactions and related business relationships,
• Prevents, mitigates, or ceases engagement where risks are unacceptable,
• Maintains appropriate records and transparency, and
• Provides an accessible grievance channel for concerns.

This policy applies to:

• 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.

AuHandel’s due diligence is:

• 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

• Step 1 — Establish strong management systems
• AuHandel maintains management systems to support due diligence, including:
• Governance & accountability: designation of a Compliance Lead / Responsible Sourcing Officer and senior management oversight.
• Policies & procedures: published policies (including Responsible Sourcing and Human Rights) and internal onboarding/transaction procedures.
• Counterparty onboarding: identification/verification of legal entity, ownership/control where applicable, and authority to transact.
• Training: periodic training for relevant personnel on red flags, escalation, and documentation integrity.
• Record-keeping: maintenance of transaction files and due diligence evidence consistent with legal and operational requirements.
• Step 2 — Identify and assess risks in the supply chain
• AuHandel assesses risks at counterparty and transaction level, including (as applicable):
• Identity and ownership risk: verification of entity existence, beneficial ownership (where required), authorised signatories, and legitimacy of business operations.
• Geographic risk: screening for CAHRA exposure and other elevated-risk jurisdictions using credible sources; sanctions considerations where applicable.
• Supply chain integrity: origin plausibility checks to the extent feasible, consistency of documentation, route/handling anomalies.
• Transaction structure risk: unusual settlement methods, third-party payments, cash-intensive structures, or attempts to avoid due diligence.
• Integrity risks: corruption, fraud, misrepresentation of origin, tax/royalty evasion indicators.
• Human rights risks: indicators linked to forced labour, child labour, trafficking, severe abuses, or coercion and extortion.
• ASM-related risks: where artisanal/small-scale mining is relevant, apply heightened scrutiny given known elevated risk profiles in some contexts.
• Red flags that may trigger enhanced due diligence include:
• inconsistent or incomplete documentation
• resistance to routine due diligence
• implausible origin narratives
• unusual routing or custody arrangements
• urgency or pressure to execute without checks
• opaque ownership/control structures
• Step 3 — Design and implement a strategy to respond to risks
• Where risks are identified, AuHandel implements a documented risk response. Potential responses include:
• Request additional information and corroboration (documentation, representations, assurance materials).
• Apply enhanced due diligence (EDD) and management approval for elevated risk.
• Impose conditions/controls (e.g., limitations on payment channels, additional documentary requirements, restricted structures).
• Suspend a transaction pending investigation.
• Disengage/decline where:
• severe abuse indicators exist,
• credible risk cannot be mitigated to an acceptable level,
• information is materially inconsistent, or
• there is non-cooperation with due diligence.
• AuHandel documents the rationale for approvals, conditional approvals, suspensions, and disengagements.
• Step 4 — Support appropriate assurance / verification (as applicable)
• AuHandel may rely on, request, or consider credible assurance where proportionate to risk, such as:
• reputable audit reports, certifications, or equivalent assurance from counterparties,
• documented compliance programs and control evidence,
• independent documentation verification where feasible.
• Where third-party assurance is unavailable or insufficient for the risk context, AuHandel may increase scrutiny, impose additional conditions, or decline engagement.
• Step 5 — Reporting and transparency
• AuHandel supports transparency by:
• Publishing high-level policy commitments (including this policy),
• Maintaining a grievance channel for concerns, and
• Keeping appropriate internal records of due diligence, decisions, and risk responses.
• Where appropriate for the business, AuHandel may periodically summarise program improvements and learnings (without disclosing sensitive counterparty information).

The following require immediate escalation to senior management and will typically result in suspension or refusal unless risks can be clearly ruled out:

• credible indicators of severe human rights abuses (forced labour, child labour, trafficking, torture, widespread sexual violence)
• credible indicators of conflict financing or support to armed groups
• bribery/corruption demands or evidence
• material misrepresentation of origin/documentation
• suspicious transaction structures consistent with money laundering or terrorism financing
• (See also: Responsible Sourcing Policy and CAHRA Policy.)

Depending on risk, AuHandel may request:

• Entity registration details and operating address (as required for verification)
• Beneficial ownership and control information (as applicable)
• Authorised signatories and authority to transact
• Description of supply chain role and sourcing footprint
• Origin-related documentation to the extent available (and not misleading)
• Logistics/custody documentation where applicable
• Settlement information (beneficiary accounts, rationale for payment structure)
• Compliance program overview and relevant assurance
• Failure to provide reasonable information may result in refusal or disengagement.

AuHandel maintains transaction files and due diligence records (including onboarding evidence, risk assessments, risk responses, and decision approvals) consistent with:

• applicable legal requirements, and
• operational needs for audit readiness and accountability.

AuHandel provides periodic training to relevant personnel on:

• recognising red flags,
• CAHRA awareness and escalation,
• documentation integrity and fraud prevention,
• AML/CTF risk indicators and reporting obligations.

Stakeholders may report concerns connected to AuHandel’s gold supply chain activities through:

• Email: [Insert grievance/compliance email]
• Web form (optional): [Insert link]
• AuHandel handles concerns discreetly, prohibits retaliation for good-faith reporting, and will investigate proportionately.

This policy and supporting procedures are reviewed periodically (at least annually) and updated as needed based on:

• changes in operating footprint,
• changes in risk context (jurisdictional, regulatory, geopolitical), and
• lessons learned from implementation and reported concerns.