The law we hold ourselves to

Our business runs through mine sites, checkpoints, customs posts and ministries in places where a small payment is often expected. We do not make it. The rule covers cash, gifts, hospitality, jobs for relatives, charitable donations and any other advantage. It applies whoever asks: a public official, a soldier, a police officer, a traditional authority or a private buyer. A refused payment that delays a truck is a cost we accept.

We hold ourselves to the United States Foreign Corrupt Practices Act, the UK Bribery Act 2010 and the Congolese, Tanzanian and Angolan criminal codes. We keep the adequate procedures the Bribery Act expects: risk assessment, due diligence on agents and intermediaries, written approval of gifts and hospitality, training and monitoring. Agents, brokers and security contractors sign our anti-bribery terms before they act for us, and we can audit them and end the relationship.

Books and records matter as much as the rule. Every royalty, tax, fee and levy is paid through official channels against an official receipt, and every payment is booked to a named recipient and purpose. We disclose payments to public bodies where a host-state transparency regime asks for them. We cooperate with the Agence de Prévention et de Lutte contre la Corruption and any other competent authority.

Our sites sit in places where security forces, public and private, have a history of abuse. We work to the UN Guiding Principles on Business and Human Rights and the Voluntary Principles on Security and Human Rights. Before a gate opens we assess the human rights risks of the site, the armed actors around it and the units we may have to deal with. The result is written into the site security plan.

Private security contractors sign use-of-force rules that permit force only when necessary and proportionate, and never to enforce a sale or a price. Every guard is age-verified and background-checked. Where we work alongside state security units we vet them to the standard of the US Leahy Laws. We do not employ, equip or train any unit that recruits or uses children, and we give public forces no more than the law allows.

Abuses are reported, recorded and remedied. Any credible allegation against a guard, a contractor or a public unit stops our cooperation with that person or unit while it is investigated. It is also reported to the competent authorities. Miners, workers and neighbours can raise a concern at any site office or by email, and we protect them from retaliation for doing so.

Congolese law treats anyone under 18 as a child and names work in mines among the worst forms of child labour. So do the ILO conventions we apply and the child protection laws of Tanzania and Angola. Our minimum age for employment is 18 everywhere we operate, whatever a local rule may allow. Nobody under 18 does hazardous work anywhere in our operations.

At the purchase gate age is verified against a miner card, cooperative register or identity document before a delivery is weighed. A delivery from a person who cannot show age is refused. A site where minors are found working is suspended from purchasing until the cooperative and the state mining service confirm the problem is resolved. Our field teams and the SAEMAPE agents at each gate record what they see.

Removing a child from work without replacing the household's income sends the child to a worse site. Where we find child labour we work with the cooperative, the family and local authorities on a remediation plan. That means school enrolment and, where possible, adult work for a household member at a published price. We fund school places rather than looking away, and we report on these cases.

The eastern DRC is a conflict-affected and high-risk area by any definition. We align our management systems, risk identification, risk response, audit and public reporting to the five steps of the OECD Due Diligence Guidance, with its 3T and Gold Supplements. Congolese law itself requires this of every operator, trader and exporter. The Annex II risks are restated in our sourcing policy and in every supplier contract.

We source only from sites validated green under the DRC and ICGLR mine-site validation process, and we suspend purchases from any site that turns yellow or red. Our exports carry the certificates the Regional Certification Mechanism and the Centre d'Expertise, d'Évaluation et de Certification issue. Every gold and gemstone export is submitted to CEEC. Rough diamonds move only under a Kimberley Process certificate, and we do not trade them outside the scheme.

Our in-house gold refining is aligned to the LBMA Responsible Gold Guidance and our processing plants to the Responsible Minerals Initiative's assurance standards. We will seek independent assessment as volumes justify it. Customers filing under Dodd-Frank section 1502 or Regulation (EU) 2017/821 receive mine-of-origin, custody and refiner data on request. We publish an annual due diligence report.

Traceability is not a certificate we buy; it is how we run a site. At the purchase gate a clerk records each delivery against the miner or cooperative, the site, the weight, the sample and the assay, and issues a tagged, sealed bag. The same record follows the bag through processing, consolidation, the refinery and export. Every hand-over between two people is a logged custody transfer with a time, a place and two signatures.

Crops and timber follow the same discipline: a plot, a grower, a harvest date, a lot number, a drying and storage record, a transport record and a customs record. Gold follows the record through the refinery whether it is vaulted or sold, and every consignment is assayed and XRF-tested so the paper matches the metal. Chain of custody and chain of ownership stay unbroken to the buyer.

Records are retained for at least six years, or longer where a customer, a regulator or a lender asks. They are available to customs authorities, banks, auditors, the ICGLR and state mining services on request. The scheme is designed so that a customer's Form SD inquiry, an EU importer's due diligence, a CBP detention or a journalist's question can be answered with the same evidence.

Gold and gemstones are a classic vehicle for laundering money, and minerals of unknown origin may be criminal property. We maintain a written, risk-based anti-money-laundering programme with a named compliance officer, staff training and independent review. It follows the form the US Bank Secrecy Act requires of dealers in precious metals and stones. We apply it in every country we operate in, whether or not local law reaches us.

Know-your-counterparty checks are done before the first transaction and refreshed on a schedule. They cover identity, licence or cooperative approval, beneficial ownership, politically exposed persons, sanctions status and source of funds, with enhanced checks where risk is higher. Minerals whose origin cannot be shown are refused. We do not accept cash above the thresholds in UK and DRC law, and we report large cash receipts where US law requires.

Purchase gates run on cash controls. Every payment is logged to a named miner or cooperative against a weighed, assayed delivery, and paid by mobile money or bank transfer wherever possible. Dual authorisation, daily reconciliation and counted floats apply at every gate. Suspicious transactions are reported to the financial intelligence unit of the country concerned: CENAREF, Tanzania's FIU, Angola's UIF, the UK National Crime Agency or FinCEN.

A compliance programme is only as good as the reports that reach it. Concerns about bribery, forced or child labour, security conduct, safety, environmental harm, fraud, discrimination, harassment, data misuse or any other breach of law or of these commitments can be raised. Reports are taken in French, Swahili, Lingala, Portuguese or English, by email, in writing, in person at a site office or through a site clerk, with or without a name.

Every report is logged, acknowledged, assessed and, where warranted, investigated by people independent of the matter. The outcome is reported back to the person who raised it where we can reach them. Serious matters are reported to the board and, where the law requires, to the competent authority. Grievances from communities follow the same process, and a remedy is offered where we have caused or contributed to harm.

We prohibit retaliation, threats, dismissal, demotion, loss of purchasing access or any other detriment against a person for raising a concern in good faith or cooperating with an investigation. We treat retaliation as misconduct. We never use confidentiality or contract terms to prevent a report to a regulator, a law-enforcement agency or a court. We protect reporters to the standard of the UK Public Interest Disclosure Act, US whistleblower law and the EU Whistleblowing Directive.