A2B GOLD DMCC Supply Chain Policy

1. Introduction
A2B GOLD DMCC is committed to ensuring that all gold and other precious metals sourced and traded within our supply chain are done so responsibly, ethically, and in compliance with applicable laws, including UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs). This policy outlines the procedures and risk mitigation measures A2B GOLD DMCC employs to assess its gold supply chain, including the activities and relationships of its suppliers.

2. Scope
This policy applies to all entities and individuals involved in the gold supply chain of A2B GOLD DMCC, including, but not limited to, customers, suppliers, vendors, transporters, refiners, and employees involved in sourcing, procurement, and compliance. The policy governs the due diligence, risk assessment, and ongoing monitoring of these entities to ensure adherence to legal, regulatory, and ethical standards.

3. Roles and Responsibilities
3.1 Employees
All employees must follow this policy and report any concerns or suspicious activities within the supply chain to the Compliance Officer. Employees involved in procurement, supply chain management, or compliance are required to apply the Know Your Counterparty (KYC) and due diligence measures outlined in this policy.

3.2 Compliance Officer
The Compliance Officer, currently Dr. Mark Shternberg, PhD, serves as the Nominated Compliance Officer and Money Laundering Reporting Officer (MLRO) and is responsible for overseeing the implementation of this policy. The Compliance Officer ensures the company’s adherence to AML/CFT regulations and industry best practices.

3.3 Board of Directors
The Board of Directors is responsible for approving this policy and any significant updates. They oversee the overall supply chain risk management framework and ensure that the company maintains appropriate internal controls to mitigate risks associated with the gold supply chain.

3.4 Management
Management is responsible for ensuring that employees are adequately trained on the policy and that the necessary resources and systems are in place to support effective supply chain due diligence and risk mitigation.

4. Know Your Counterparty (KYC) and Customer Due Diligence Measures
4.1 Identification and Verification
A2B GOLD DMCC conducts thorough Know Your Counterparty (KYC) procedures for all suppliers, customers, and other business partners to identify and assess any potential risks related to money laundering, terrorism financing, or ethical concerns such as human rights abuses and environmental harm.

  • For Individual Counterparties:
  • Valid identification (passport, national ID, or driver’s license).
  • Proof of residential address (utility bill, bank statement).
  • Politically Exposed Person (PEP) status check.

  • For Corporate Entities:
  • Certificate of incorporation and business registration documents.
  • Memorandum and Articles of Association.
  • Identification of beneficial owners holding 25% or more ownership.
  • Proof of company address and directors' identification.

4.2 Enhanced Due Diligence (EDD)
For counterparties identified as high-risk (e.g., operating in Conflict-Affected and High-Risk Areas (CAHRAs) or complex ownership structures), Enhanced Due Diligence (EDD) is conducted. This may include site visits, third-party audits, and additional verification of the supply chain up to the source of the gold.

4.3 Screening Tools
A2B GOLD DMCC uses tools such as NameScan.io to screen all counterparties against global sanctions lists, PEP lists, adverse media, and the UAE FIU blacklist. Local verification is also conducted through the UAE International Export Control (IEC) platform to ensure compliance with UAE regulations.

5. Supply Chain Risk Assessment and Risk Mitigation
5.1 Risk Assessment
A2B GOLD DMCC applies a risk-based approach to all counterparties and transactions within the supply chain. Risk factors considered include the geographic location of suppliers, the nature of the supply chain, the political and security context in CAHRAs, and any previous compliance history of the counterparty.

5.2 Risk Mitigation
In the event risks are identified, A2B GOLD DMCC will take the following steps:
  • Engage with the Supplier: Work with the supplier to develop and implement a risk management plan, including corrective actions.
  • Suspend the Relationship: If the risks are not adequately addressed, the business relationship will be suspended.
  • Terminate the Relationship: If the supplier fails to comply with corrective actions or if the risks are deemed too significant, A2B GOLD DMCC will terminate the relationship.

5.3 Conflict-Affected and High-Risk Areas (CAHRAs)
A2B GOLD DMCC conducts enhanced supply chain due diligence for any gold sourced from CAHRAs. This includes verifying the legitimacy of the source and ensuring that the materials do not contribute to conflict financing or human rights abuses. Suppliers must provide documentation verifying the origin of the gold and cooperate with independent audits when required.

6. Ongoing Monitoring Measures
A2B GOLD DMCC continuously monitors all counterparties and transactions within its supply chain to identify any changes in risk profiles. This includes:

  • Transaction Monitoring: Automated systems flag unusual or suspicious transactions for further review.
  • Periodic Review: Counterparty information is reviewed periodically (at least annually), with more frequent reviews for high-risk suppliers.
  • Continuous Engagement: Regular communication and site visits are conducted for high-risk suppliers to ensure ongoing compliance with our ethical and legal standards.

7. Independent Audit Mechanism
A2B GOLD DMCC is subject to annual independent audits to assess compliance with this policy, the OECD Due Diligence Guidance, and UAE regulations. These audits:

  • Evaluate the company’s due diligence processes, chain of custody procedures, and risk mitigation measures.
  • Ensure that the supply chain is free from conflict financing and human rights abuses.
  • Provide recommendations for improving supply chain practices.

The results of these audits are reported to the Board of Directors and, where necessary, corrective actions are implemented immediately.

8. Record Retention Requirements
A2B GOLD DMCC maintains accurate records of all supply chain due diligence, KYC checks, transaction documentation, and audit reports for a minimum of five years from the date of the last transaction or termination of the business relationship. These records are securely stored and are accessible only to authorized personnel.

9. Training Program
A2B GOLD DMCC provides mandatory training to all employees involved in supply chain management, procurement, and compliance functions. The training program includes:

  • AML/KYC Training: Employees are trained on how to conduct KYC checks, identify red flags, and report suspicious activities.
  • OECD Guidance: Employees are educated on the OECD Due Diligence Guidance and how to apply its principles in day-to-day operations.
  • goAML Training: Employees responsible for reporting suspicious activities are trained on using the goAML platform to file Suspicious Transaction Reports (STRs) with the UAE Financial Intelligence Unit (FIU).

Training is updated regularly to reflect changes in regulations and emerging risks in the gold supply chain.

10. Policy Review and Updates
This policy is reviewed annually or in response to significant regulatory changes to ensure it remains effective and compliant with current laws, regulations, and industry best practices. Amendments are communicated to all relevant stakeholders, including employees and supply chain partners.

11. Contact Information
For any questions or concerns regarding this policy, or to report suspicious activities, please contact our Compliance Officer at compliance (at) a2bgold.com.