Responsible Sourcing Policy

GCI will only coordinate transactions in gold that is lawfully mined, lawfully held and lawfully exported, and whose origin and chain of custody can be documented.

We reference the OECD Due Diligence Guidance and its Gold Supplement, and the model supply chain policy in Annex II of that guidance. Referencing these frameworks does not imply OECD membership, certification, audit or endorsement of GCI.

• Gold that directly or indirectly finances or benefits armed groups or their affiliates.
• Gold associated with torture, cruel or degrading treatment, forced or compulsory labour, or the worst forms of child labour.
• Gold linked to war crimes, serious human rights abuses or violations of humanitarian law.
• Gold obtained through illegal mining, illegal taxation, extortion or theft.
• Gold whose export breaches permit, licensing, royalty, customs or sanctions requirements.
• Gold connected to bribery, misrepresentation of origin or money laundering.
• Gold that cannot be traced to a documented, lawful source.

The Director owns supply chain due diligence, maintains counterparty and transaction records for at least seven years, and operates a grievance channel at notifygoldcapitalexchange@gmail.com.

Suppliers must accept this policy as a condition of engagement, and our agreements incorporate responsible sourcing obligations.

We assess the country and region of origin, the mine or aggregation point, the transport route, the parties in the chain and the credibility of documentation.

Material from conflict-affected and high-risk areas triggers enhanced enquiry, including origin verification, adverse media screening and, where warranted, third-party inspection before any commitment.

Identified risks are escalated to the Director, who decides whether to proceed with mitigation, suspend pending further information, or disengage.

Where mitigation is appropriate, we set measurable improvement expectations with timeframes and monitor them. We disengage immediately where an Annex II "zero tolerance" risk is identified.

We support independent assay, inspection and, where available, refinery-led assurance programmes. We prefer counterparties whose material is processed by refiners operating recognised responsible sourcing standards.

GCI itself is not currently subject to third-party audit of its due diligence, and we do not claim accreditation or certification by any assurance scheme.

We report transparently to counterparties on origin and due diligence findings relevant to their transaction, and publish this policy so expectations are clear before engagement begins.

• Completed supplier questionnaire, certificate of incorporation, mining or trading licence, tax registration and evidence of lawful export authority.
• Identification of directors, authorised signatories and all beneficial owners holding 25% or more, with certified identity documents.
• Sanctions, PEP and adverse-media screening on the entity, its owners and its signatories before any introduction is made.
• Documented source of gold: mine site or collection point, licence reference, production or purchase records and the full chain of custody to the point of sale.
• Site or operational information proportionate to risk, including photographs, production data and, where warranted, a third-party site visit or inspection report.
• Signed acceptance of this policy, the anti-bribery policy and the modern slavery obligations, plus consent to ongoing monitoring and periodic re-screening.
• No introduction, sample, inspection or transaction proceeds until onboarding is complete and formally approved.

• Material of unknown, undocumented or unverifiable origin, or where chain-of-custody documents conflict with each other.
• Material connected to armed groups, public or private security forces exercising illegal control, conflict financing or serious human rights abuse.
• Material linked to forced labour, bonded labour, child labour or unlawful working conditions.
• Material from, or transiting, jurisdictions or entities subject to applicable sanctions, or offered by a sanctioned or listed party.
• Material offered with fabricated, altered, notarised-but-unverifiable or template documentation, or accompanied by advance-fee, upfront-payment or unusual escrow demands.
• Material connected to smuggling, tax or customs evasion, illegal mining, or where the supplier refuses due diligence, site verification or independent assay.

Where material originates in, or transits, a conflict-affected or high-risk area, a jurisdiction with weak governance or a country flagged by FATF or applicable sanctions regimes, enhanced due diligence applies in addition to standard onboarding.

• Independent verification of the mining or export licence with the issuing authority where feasible.
• Documented mine-to-export chain of custody with dated transfer records for each stage.
• Expanded adverse-media and litigation screening in local and international sources, repeated before each transaction.
• Third-party inspection, assay and, where warranted, an on-site assessment before any consignment is progressed.
• Enhanced source-of-funds and source-of-wealth review on the counterparty and its owners.
• Transaction-level monitoring, with shorter re-screening intervals and a written risk assessment retained on file.

Any red flag identified at onboarding, screening or transaction stage is escalated immediately to the Director, who is the approval authority for this policy. Progress is suspended while the matter is assessed.

The Director may approve with conditions, require further evidence, suspend the relationship or decline and terminate it. Approvals, conditions and rejections are recorded in writing with the reasons and the evidence relied on, and are retained for at least seven years.

Only the Director may approve a high-risk counterparty, and no member of GCI or any contractor may waive a due diligence requirement. Where a suspicious matter reporting obligation may arise, GCI takes independent legal advice and does not tip off the counterparty.

• Mining, dealing and export licences valid in the country of origin.
• Certificate of origin and, where applicable, Great Lakes regional certification.
• Export permit and customs documentation consistent with the consignment.
• Assay and refinery certificates from recognised laboratories.
• Evidence of lawful title and of the chain of custody from source to export point.

We do not exclude artisanal and small-scale mining. Legitimate ASM is a vital livelihood, and responsible engagement supports formalisation and better conditions.

ASM-origin material must still be lawfully licensed, documented and free of the Annex II risks, and receives enhanced scrutiny of labour conditions and mercury use.

Concerns about the origin or conditions of material connected to a GCI transaction can be raised confidentially at notifygoldcapitalexchange@gmail.com with the subject line "Sourcing Grievance". We acknowledge within 5 business days, investigate proportionately and record the outcome.

This policy is reviewed at least annually and after any material change to our sourcing footprint or to applicable law and guidance.