The Clean Gold Initiative

Preamble

As a signer of the Clean Gold Initiative (this "Agreement"), GoldChain recognizes the need for strict international standards for human rights, fair trade, and compliance with OECD regulations for gold mining and trading, and guided by the principles of equity and responsibility, hereby agrees to abide by the Clean Gold Initiative, in pursuit of the objective of responsible and sustainable gold production and trade, and in recognition of the specific needs and special circumstances of developing country parties and vulnerable communities affected by gold mining, and affirming the importance of transparency, education, public participation, and cooperation at all levels to achieve this objective, has agreed to the practices as follows:

1. On Conflict-Affected and High-Risk Areas

Seek to generate income, growth, and prosperity, but also to sustain livelihoods and foster local development in Conflict-affected and high-risk areas (CAHRAs).

CAHRAs are identified by the presence of armed conflict, widespread violence or other risks of harm to people. Armed conflict may take a variety of forms, such as a local or international conflict, which may involve two or more states, or may consist of wars of liberation, insurgencies, or civil wars. High risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure, and widespread violence. Such areas are often characterized by civil wars and violations of national and international laws. In such locales, companies may be at risk of contributing to or being associated with significant adverse impacts, including serious human rights abuses and conflict.

2. Supply Chain Due Diligence

Apply due diligence as an on-going, proactive and reactive process through which Parties can ensure that they respect human rights and do not contribute to conflict. Through world-class due diligence, this Agreement ensures parties observe international law and comply with domestic laws, including those governing the illicit trade in minerals and United Nations sanctions.

Risk-based due diligence refers to the steps we take to identify and address actual and potential inherent risks in order to prevent or mitigate adverse impacts associated with its activities or sourcing decisions.

Due diligence is structured around the steps that Parties take to:

Identify the factual circumstances involved in the extraction, transport, handling, trading, processing, smelting, refining and alloying, manufacturing or selling of products that contain minerals originating from conflict-affected and high-risk areas
Identify and assess any actual or potential risks by evaluating the factual circumstances against standards set out in the company's supply chain policy
Prevent or mitigate the identified risks by adopting and implementing a risk management plan. These may result in a decision to continue trade throughout the course of risk mitigation efforts, temporarily suspend trade while pursuing ongoing risk mitigation, or disengage with a supplier either after failed attempts at mitigation or where the company deems mitigation not feasible or the risks unacceptable

3. Risk Management

Manage risk throughout the supply chain. Inherent risks are defined in relation to the potentially adverse impacts of gold mining and trading operations, which result from activities or relationships within the industry, including suppliers and other entities in the supply chain. Adverse impacts may include harm to people (i.e. external impacts), or reputational damage or legal liability for the company (i.e. internal impacts), or both.

Such internal and external impacts are often interdependent, with external harm coupled with reputational damage or exposure to legal liability. This risk-based approach also helps to scale the due diligence exercise to the size of our activities or supply chain relationships.

4. Self-Certification Mechanism (SCM)

Development of a proprietary Upstream & Downstream Chain of Custody Supply Chain Management System, Anti Money Laundering Compliance Program, and SCM, which ensures that all strategic minerals and precious metals are sourced in adherence with international standards.

An SCM ensures consistent implementation of due diligence and risk control requirements including:

Scope, clear responsibilities, and escalation channels
Identification, assessment, and criteria for high-risk gold supply chain
Know-Your-Customer (KYC) process
Monitoring and surveillance of transactions
Mandatory trainings for relevant staff who are exposed directly in the supply chain

All staff involved in the supply chain must strictly implement and comply with this policy.

5. International Compliance Standards

Adherence to the following international compliance standards:

Annex II of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from CAHRAs
Section 1502 of U.S. Dodd-Frank Act
Regional Certification Mechanism (RCM) of the International Great Lakes Region (ICGLR) 2nd Ed.
Responsible Jewelry Council (RJC) Standards
DMCC Practical Guidance for Market Participants in the Gold and Precious Metals Industry v.1 (the "DMCC Guidance")
DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain (the "DMCC Rules for RBD-GPM")
LBMA Responsible Gold Guidance
Federal Decree-law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Illegal Organisations & Cabinet Decision No. 10 of 2019

6. Non-State Armed Groups

Ensuring the mineral supply chain is free of support for non-state armed groups and public or private security forces, including international armed forces who:

Illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain
Illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded
Illegally tax or extort intermediaries, export companies or international traders

7. Human Rights

Targeting the following serious human rights abuses:

Any forms of torture, cruel, inhuman and degrading treatment
Any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily
The worst forms of child labor
Other gross human rights violations and abuses such as widespread sexual violence
War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide

8. Five Step Framework

Review the choice of suppliers and sourcing decisions integrating the following 5-step framework into our risk-based due diligence SCM for responsible supply chains of minerals from CAHRAs:

#1. Establish Strong Company Management Systems

Adopt and clearly communicate to suppliers and the public a Company policy for the supply chain of minerals originating from CAHRAs, consistent with Annex II of the OECD Due Diligence Guidance and the RCM of the ICGLR 2nd Ed.
Structure internal management to support supply chain due diligence
Establish a system of controls and transparency over the mineral supply chain, including chain of custody or traceability systems
Strengthen company engagement with suppliers and incorporate supply chain policy into contracts and agreements
Establish a Company-level or industry-wide grievance mechanism as an early-warning risk-awareness system

#2. Identify & Assess Risk in the Supply Chain

Identify risks in the supply chain as recommended in Annex II of the OECD Due Diligence Guidance and the RCM of the ICGLR 2nd Ed.
Assess risks of adverse impacts in light of supply chain policy standards consistent with due diligence recommendations

#3. Design & Implement Risk Response Strategy

Report findings of the supply chain risk assessment to designated senior management
Devise a strategy for risk management: continue trade with measurable risk mitigation, temporarily suspend trade while pursuing mitigation, or disengage with a supplier after failed attempts
Implement the risk management plan, monitor and track performance, and report back to senior management
Undertake additional fact and risk assessments for risks requiring mitigation or after a change of circumstances

#4. Facilitate Third-Party Supply Chain Audit

Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain, within the scope of the RCM of the ICGLR 2nd Ed. Such audits shall be verified by an independent institutionalized mechanism.

#5. Report on Supply Chain Due Diligence

Report on supply chain due diligence in accordance with the RCM of the ICGLR 2nd Ed., publicly reporting on supply chain due diligence policies and practices through sustainability, corporate social responsibility, or annual reports.

9. Five Point ASM Due Diligence

Perform comprehensive ASM due diligence regarding:

#1. Serious abuses associated with mineral trading

While sourcing from, or operating in CAHRAs, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:

Any forms of torture, cruel, inhuman and degrading treatment
Any forms of forced or compulsory labor
The worst forms of child labor
Other gross human rights violations and abuses such as widespread sexual violence
War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide

#2. Support of non-state armed groups

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of minerals, including but not limited to procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to non-state armed groups or their affiliates who illegally control mine sites, transportation routes, or points of trade, or who illegally tax or extort money or minerals at any point in the supply chain.

#3. Public or private security forces

Eliminate direct or indirect support to public or private security forces who illegally control mine sites, transportation routes, or upstream actors in the supply chain
Recognize that the role of security forces should be solely to maintain the rule of law, safeguard human rights, and protect mine sites and transportation routes from interference with legitimate extraction and trade
Require that contracted security forces be engaged in accordance with the Voluntary Principles on Security and Human Rights, including screening policies to prevent hiring individuals responsible for gross human rights abuses
Support efforts to improve transparency, proportionality, and accountability in payments made to public security forces
Take steps to avoid or minimize exposure of vulnerable groups, particularly artisanal miners, to adverse impacts associated with security force presence

#4. Fraud, money laundering, and government fees

Not offer, promise, give, or demand any bribes to conceal or disguise the origin of minerals or misrepresent taxes, fees, and royalties paid to governments
Support the effective elimination of money laundering connected to the extraction, trade, handling, transport or export of minerals
Ensure all taxes, fees, and royalties related to mineral extraction, trade and export from CAHRAs are paid to governments, in accordance with the Extractive Industry Transparency Initiative (EITI)

#5. Risk management in ASM due diligence

Immediately suspend upstream suppliers where there is reasonable risk of sourcing from parties committing serious abuses or providing support to non-state armed groups
Devise and implement a risk management plan to prevent or mitigate risk of support to public or private security forces, suspending or discontinuing engagement after failed mitigation within six months
Engage with suppliers, governmental authorities, international organizations, civil society and affected third parties to improve and track performance through measurable steps

10. The Clean Gold Pledge

We value the trust our organization has earned and take pride in our commitment to The Clean Gold Initiative through our Proprietary Upstream & Downstream Chain of Custody Supply Chain Management System, Anti-Money Laundering Compliance Program, and SCM.

We recognize that risks of significant adverse impacts may be associated with extracting, trading, handling, and exporting minerals from CAHRAs, and we recognize that we have the responsibility to respect human rights and not contribute to conflict. We commit to adopt, widely disseminate, and incorporate into contracts and agreements with suppliers a policy on responsible sourcing of minerals from CAHRAs, as representing a common reference for conflict-sensitive sourcing practices and suppliers' risk awareness from the point of extraction until end user.

We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions, RCM of the ICGLR 2nd Ed., OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from CAHRAs or, where applicable, domestic laws implementing such mechanisms, standards, and resolutions. This acknowledgement further covenants that it is compliant and incorporates by reference the DMCC Guidance and the DMCC Rules for RBD-GPM.