PALM - Gold Refinery FZE

Responsible Sourcing Policy

 

RESPONSIBLE SOURCING POLICY FOR

PALM GOLD REFINERY FZE

Effective Date: 10/12/2024

At Palm Gold Refinery FZE ("we", "our", "us"), we are committed to ensuring that our gold refining operations adhere to the highest ethical standards, comply with the legal requirements of the United Arab Emirates (UAE), and contribute to responsible sourcing practices. This Responsible Sourcing Policy sets forth our principles, practices, and commitment to sourcing gold responsibly, with a focus on human rights, anti-money laundering (AML), environmental impact, and compliance with applicable UAE regulations.

We are committed to sourcing gold in a way that fosters transparency, integrity, and accountability across our supply chain, and we require the same commitment from our suppliers, partners, and stakeholders.

  1. Objective

The objective of this policy is to establish guidelines and principles that ensure that the gold we refine is sourced responsibly and in full compliance with the applicable laws of the UAE, including anti-money laundering (AML) and anti-terrorism financing laws, human rights standards, environmental sustainability, and other related regulations.

  1. Compliance with UAE Regulations

We ensure that our operations comply with all relevant UAE laws and international standards, including:

  • UAE Anti-Money Laundering Law: We adhere to the UAE’s AML regulations, ensuring that our supply chain is free from money laundering, terrorist financing, and other illicit financial activities. This includes conducting thorough due diligence (Know Your Customer or KYC) and ensuring the source of the gold is legitimate.
  • UAE Central Bank Regulations: Compliance with regulations issued by the UAE Central Bank on gold transactions and anti-money laundering measures.
  • UAE Federal Law on Commercial Companies: Compliance with laws governing businesses operating in the UAE, including those related to corporate governance and responsible business practices.
  • International Standards: We adhere to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and the UN Guiding Principles on Business and Human Rights.
  1. Due Diligence and Transparency

We require our suppliers to provide full transparency regarding the source of the gold and conduct extensive due diligence on all suppliers and traders in our supply chain. Our due diligence process includes:

  • Risk Assessment: Regularly assessing and identifying any risks related to human rights abuses, environmental damage, and compliance violations associated with gold sourcing.
  • Know Your Customer (KYC): We collect and verify detailed information from suppliers to confirm that the gold is sourced responsibly and legally, including documentation such as mining licenses, proof of origin, and financial statements.
  • Chain of Custody: We ensure the traceability of gold from its source, including maintaining records of all transactions involving gold from extraction to refining.
  • Third-Party Audits: We conduct periodic third-party audits and inspections to verify compliance with this policy and assess the overall transparency of our supply chain.
  1. Human Rights and Ethical Standards

We uphold the principles of the UN Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights. Our commitment includes:

  • Prohibition of Child Labor and Forced Labor: We do not tolerate child labor, forced labor, or any form of human trafficking in the supply chain. We ensure that all workers involved in the mining and extraction process are treated with dignity and respect.
  • Fair Working Conditions: We require suppliers to provide fair wages, safe working conditions, and adherence to health and safety standards.
  • Respect for Indigenous Peoples and Local Communities: We ensure that the rights of indigenous peoples and local communities are respected, and we require our suppliers to avoid activities that may harm these groups or violate their land rights.
  1. Environmental Responsibility

We are committed to sourcing gold in a manner that minimizes environmental harm and promotes sustainability. Our practices include:

  • Environmental Impact Assessments: We require that suppliers conduct environmental impact assessments before engaging in mining operations and adopt measures to minimize negative environmental effects.
  • Sustainable Mining Practices: We encourage the use of responsible mining methods that protect ecosystems, conserve water resources, reduce pollution, and ensure proper waste management.
  • Recycling and Responsible Sourcing: We promote gold recycling as a key part of our supply chain, reducing the demand for newly mined gold and minimizing the environmental footprint of gold production.
  1. Anti-Corruption and Anti-Bribery

We have a zero-tolerance policy toward corruption and bribery. We require all suppliers, partners, and employees to comply with anti-corruption laws and ethical business practices. Any attempts to bribe or corrupt our staff or suppliers will result in immediate suspension of business dealings and potential legal action.

  1. AML and KYC Compliance

In line with UAE law and international best practices, we take a strong stance on anti-money laundering (AML) measures, which include:

  • Source of Gold Verification: We verify the legitimate source of all gold supplied to us, ensuring that it does not originate from illegal or suspicious sources.
  • Transaction Monitoring: We monitor all transactions for signs of money laundering or terrorist financing and report any suspicious activity to the relevant authorities as required by law.
  • Record Keeping: We maintain detailed records of all transactions and conduct ongoing monitoring of our suppliers' compliance with KYC and AML regulations.
  1. Supplier Expectations

We expect all of our suppliers to:

  • Implement Responsible Practices: Adopt responsible sourcing practices that align with the principles outlined in this policy.
  • Provide Documentation: Provide all necessary documentation to support the traceability and legitimacy of the gold being supplied, including chain-of-custody certificates, environmental certifications, and evidence of ethical labor practices.
  • Comply with Laws and Regulations: Comply with all applicable laws and regulations, including those relating to environmental protection, labor rights, and anti-money laundering.
  1. Training and Awareness

We are committed to educating our employees and suppliers on responsible sourcing practices and compliance with UAE regulations. Regular training sessions on ethical business practices, AML laws, human rights, and environmental sustainability are conducted to ensure that our staff and suppliers are informed and equipped to meet our standards.

  1. Reporting and Grievance Mechanism

We provide a platform for employees, suppliers, and stakeholders to report any concerns regarding the sourcing of gold, human rights violations, or other ethical issues. We ensure that all reports are taken seriously and investigated promptly. Any retaliatory actions against individuals who report violations will not be tolerated.

  1. Policy Review and Updates

This policy will be reviewed and updated regularly to reflect changes in regulations, best practices, and our business operations. Any significant changes to this policy will be communicated to our stakeholders.

  1. Contact Us

For any inquiries regarding this Responsible Sourcing Policy or to report concerns, please contact us at:

Email Address: info@thepgr.ccom

Phone Number: 00971 65436 916

Company Address: Warehouse, Q4 271, 272, SAIF Zone, Sharjah, U.A.E.

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