Anti-Money Laundering Policy

1. AML Programme Components

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for higher-risk relationships
• Beneficial ownership identification and verification for all corporate counterparties
• Ongoing monitoring of business relationships and transaction patterns
• Suspicious Activity Reporting (SAR) to relevant Financial Intelligence Units
• Record-keeping of all customer identification and transaction data for a minimum of five years
• Regular AML risk assessments of our client base, products, geographies, and transaction channels
• Independent internal AML audits and regulatory compliance reviews

2. Customer Risk Assessment

Each prospective and existing counterparty is assessed against a risk matrix that considers geographic risk, product/service risk, customer type, and transaction risk. Higher-risk relationships — including politically exposed persons (PEPs) and transactions involving high-risk jurisdictions — are subject to Enhanced Due Diligence and senior management approval.

3. Transaction Monitoring

KGML monitors all commodity transactions for patterns consistent with money laundering, including unusual transaction volumes, inconsistent pricing, and unusual delivery routes. Automated and manual monitoring controls are applied across all trading activity.

4. Suspicious Activity Reporting

All employees are required to report suspicious activity to the designated Compliance Officer without tipping off the subject. KGML will not proceed with a transaction where there is reasonable suspicion of money laundering or terrorist financing.

5. Training and Awareness

All staff receive mandatory AML training on commencement of employment and annually thereafter. Our Compliance Officer holds relevant professional AML qualifications.

6. Regulatory Compliance

KGML registers and reports to relevant authorities in each operating jurisdiction as required. We cooperate fully with all lawful regulatory enquiries and investigations.