Modern Slavery Statement

Gold Capital International (ABN 26 700 429 189) publishes this statement voluntarily. Our consolidated revenue is below the AUD 100 million threshold at which reporting is mandatory under the Australian Modern Slavery Act 2018, and we do not currently meet the turnover threshold under the UK Modern Slavery Act 2015.

We publish it because gold supply chains carry real human rights risk and our counterparties are entitled to know our position. This statement covers the period to 6 August 2026 and will be reviewed annually.

GCI is a small, privately held Australian business providing transaction coordination and counterparty introduction services for physical gold doré and bullion. We do not mine, refine, transport or take custody of material.

Our supply chain exposure arises indirectly through the producers, aggregators, exporters, refiners, inspection agents and logistics providers involved in transactions we coordinate, principally across African producing countries and destination refining markets.

• Forced, bonded and child labour in artisanal and small-scale mining.
• Debt bondage through advance payment and equipment financing arrangements.
• Unsafe working conditions, including mercury exposure and unsupported pit work.
• Human trafficking and exploitation of migrant workers in mining regions.
• Labour exploitation in downstream transport, security and handling services.
• Opaque intermediary chains that obscure the true conditions of production.

This statement operates with our Responsible Sourcing Policy, KYC Policy, AML & CTF Policy, Sanctions Compliance Policy and Anti-Bribery & Anti-Corruption Policy. Together they define who we will and will not do business with.

• OECD-aligned supply chain due diligence proportionate to the origin and risk profile of the material.
• Verification of licences, permits, certificates of origin and chain of custody documentation.
• Counterparty declarations on labour practices, including the absence of forced and child labour.
• Screening for adverse media relating to human rights, labour abuse and community harm.
• Preference for material processed through refiners operating recognised responsible sourcing programmes.
• Support for independent inspection and assay, which increases visibility of the production chain.

Suppliers must confirm that no forced labour, bonded labour, child labour or human trafficking is used in their operations, that workers are lawfully engaged and paid, and that safety obligations are met.

Our agreements require suppliers to cooperate with due diligence enquiries, to disclose material human rights issues, and to permit termination where a credible allegation is not adequately addressed.

Where credible evidence of modern slavery emerges, we suspend the transaction, escalate to the Director and require a remediation plan with defined timeframes.

Where risk to affected people would increase through abrupt withdrawal, we prefer engagement and improvement over immediate exit. Where remediation is refused or fails, we disengage and, where appropriate, report to the relevant authorities.

Personnel involved in sourcing and compliance are briefed on modern slavery indicators in gold supply chains and on the escalation route for concerns.

We track the proportion of transactions with complete origin documentation, the number of concerns raised and how they were resolved, and counterparties declined on human rights grounds. As transaction volume grows we intend to strengthen these measures with independent verification.

Anyone with information about modern slavery connected to a GCI transaction should contact goldcapitalinternational@gmail.com with the subject line "Human Rights Concern". Reports can be made confidentially and we do not tolerate retaliation against anyone who raises a concern in good faith.

This statement is approved by the Director of Gold Capital International, who is responsible for its content and for its annual review.