Responsible Sourcing Policy

1. Conflict-Free Sourcing

We will not knowingly source gold or other minerals that directly or indirectly finance armed groups or contribute to serious violations of human rights. We apply a mapping and risk assessment process to identify countries and mines of origin for all sourced materials.

2. Supply Chain Mapping

• Country and region of mineral origin
• Names and identities of all upstream supply chain actors
• Mine-site identification and validation where applicable
• Chain-of-custody documentation from mine to point of export
• Independent assay and weight certificates for all physical deliveries

3. Risk Assessment and Management

We assess supply chain risks using recognised risk frameworks. Identified risks are subject to escalating management responses: low risk — standard monitoring; medium risk — enhanced due diligence; high risk — suspension pending investigation and remediation.

4. Third-Party Audits

We commission independent third-party audits of key supply chain actors operating in high-risk areas. Audit findings are reviewed by senior management and acted upon within defined remediation timelines.

5. Transparency and Reporting

We report annually on our responsible sourcing programme. This report is made available to our counterparties and stakeholders on request.