CODE OF CONDUCT FOR SUPPLIERS & COUNTERPARTIES

PARTICIPATING IN OUR PRECIOUS-METAL-RELATED SALES

A.         PURPOSE AND SCOPE

This Code of Conduct (“Code”) sets out the minimum standards of conduct required of all suppliers, intermediaries and buyers (“Business Partners”) engaging with the Company in the sale of precious-metal-bearing materials and refined precious metals.

This Code is aligned with:

• • • • • • • OECD’s Responsible Supply Chain Due Diligence Guidance
            • Applicable Singapore’s laws on anti-money laundering and countering terrorism and proliferation financing
            • The Company’s Internal Policies, Procedures and Controls established to comply with the above obligations

Compliance with this Code is a condition of doing business with the Company.

B.         CORE PRINCIPLES

Business Partners must operate in accordance with the following principles:

Legal Compliance

• • • • • • • Comply fully with all applicable laws and regulations in jurisdictions of operation
            • Specifically comply with Singapore’s AML/CFT/CPF requirements

Ethical Conduct

• • • • • • • Conduct business with integrity, transparency, and accountability
            • Avoid any conduct that could damage the integrity of the precious-metal-supply-chain

Risk-Based Approach

• • • • • • • Identify, assess, and mitigate risks in their operations and supply chains
            • Cooperate with the Company’s due diligence and monitoring processes

C.        OECD’s RESPONSIBLE SUPPLY CHAIN

Business Partners must ensure their supply chains do not contribute to:

Serious Human Rights Abuses

Including but not limited to:

• • • • • • • Forced or compulsory labour
            • Child labour
            • Torture, cruel or inhuman treatment
            • Sexual violence
            • War crimes or crimes against humanity

Conflict Financing

• • • • • • • No direct or indirect support to non-state armed groups
            • No sourcing from entities linked to conflict or violence

Security Forces Misconduct

• • • • • • • No engagement with security forces involved in illegal control, extortion, or abuse

Bribery and Fraud

• • • • • • • No bribery, corruption, or fraudulent misrepresentation of origin
            • No falsification of chain-of-custody or sourcing documentation

Money Laundering Linked to Minerals

• • • • • • • No involvement in transactions linked to illicit gold/silver or illegal taxation/extortion

D.         SINGAPORE’S AML/CFT/CPF COMPLIANCE OBLIGATIONS

Business Partners must comply with all applicable requirements under Singapore’s law, including:

Customer Due Diligence (CDD)

• • • • • • • Provide accurate and complete identification information
            • Disclose beneficial ownership and control structures
            • Submit supporting documentation upon request

Sanctions and Screening

• • • • • • • Must not be listed on:
              • UN sanctions lists
              • Singapore’s designated individuals/entities lists
              • Terrorist designation lists
            • Must not be owned or controlled by sanctioned individuals

Politically Exposed Persons (PEPs)

• • • • • • • Disclose if any beneficial owner is a PEP
            • Subject to enhanced due diligence where applicable

High-Risk Jurisdictions

• • • • • • • Disclose operations or links to high-risk jurisdictions
            • Cooperate with enhanced due diligence requirements

Transaction Controls

• • • • • • • Avoid cash or cash-equivalent transactions where possible
            • Comply with thresholds and reporting requirements
            • Use traceable banking channels (e.g., interbank transfers)

E.         DUE DILIGENCE REQUIREMENTS

Business Partners agree to:

Participation in Due Diligence

• • • • • • • Undergo onboarding and ongoing due diligence
            • Provide information required for:
              • Beneficial ownership identification
              • Risk screening
              • Supply chain verification

Supply Chain Transparency

• • • • • • • Provide chain-of-custody information where applicable
            • Disclose sources of materials and upstream suppliers

Ongoing Monitoring

• • • • • • • Notify the Company of any material changes in:
              • Ownership
              • Business activities
              • Supply chain structure

Cooperation

• • • • • • • Cooperate with audits, reviews, and information requests
            • Provide timely and accurate responses

F.         PROHIBITED CONDUCT

The Company will not engage with Business Partners involved in:

• • • • • • • Money laundering, terrorism financing, or proliferation financing
            • Sanctions breaches
            • Fraud, bribery, or corruption
            • Supply chains linked to conflict or serious human rights abuses
            • False or misleading disclosures
            • Refusal to provide due diligence information

G.        REPORTING AND WHISTLEBLOWING

Business Partners must:

• • • • • • • Report any suspected breaches of this Code
            • Maintain internal mechanisms for reporting misconduct
            • Not retaliate against whistleblowers

The Company maintains a reporting channel for concerns relating to:

• • • • • • • AML/CFT/CPF risks
            • Supply chain abuses

H.        CONSEQUENCES OF NON-COMPLIANCE

Where a breach is identified, the Company may:

• • • • • • • Suspend transactions immediately
            • Require corrective action within a specified timeframe
            • Terminate the business relationship
            • Report to relevant authorities where required

I.          RECORD KEEPING

Business Partners must:

• • • • • • • Maintain records of transactions and due diligence information
            • Retain such records for a minimum of five years or as required by law

J.          ACKNOWLEDGEMENT

All Business Partners must formally acknowledge:

• • • • • • • Receipt and understanding of this Code
            • Commitment to comply with its requirements
            • Agreement to be subject to due diligence and monitoring