Governance

Policies

These policies apply to the activities of AuHandel, a trading name of AU HANDEL LTD, and inform the expectations of relevant counterparties and service providers. They are approved by senior management, reviewed at least annually, and published here for counterparties, banks, auditors, and other stakeholders.

To report a concern — including anonymously — see the grievance mechanism or write to complaints@auhandel.com.

How to report

Reports can be submitted by email to complaints@auhandel.com. Anonymous reporting is permitted where legally and practically feasible — if you report anonymously, please provide enough detail for us to assess and respond.

You are not required to prove your concern. Raise it in good faith with whatever information you have: a description of the concern, involved parties if known, dates and transaction context if relevant, any supporting documents, and a preferred contact method if you want a response.

What can be reported

Responsible sourcing concerns — origin misrepresentation, CAHRA risk, supply chain integrity issues
Human rights concerns — forced labour, child labour, trafficking, severe abuses
Bribery and corruption — bribes, facilitation payments, kickbacks, improper gifts or hospitality
AML/CTF concerns — suspicious settlement structures, unexplained third-party payments, illicit finance indicators
Fraud or misrepresentation — false documentation, identity deception, tax or royalty evasion indicators
Environmental or safety concerns connected to our business relationships
Any other serious compliance or ethical concern connected to AuHandel’s operations or business relationships

Non-retaliation

AuHandel prohibits retaliation against any person who raises a concern in good faith, participates in an investigation, or refuses to engage in unlawful or unethical conduct. Retaliation — threats, harassment, discrimination, demotion, termination, intimidation, or any adverse treatment connected to reporting — is itself treated as a serious compliance breach.

Reports made in good faith will not be penalised even if unsubstantiated. Deliberate false reporting made maliciously may be treated as misconduct.

What happens next

Receipt & acknowledgement — we acknowledge receipt where contact details are provided; matters indicating immediate risk of harm are prioritised
Triage & assessment — the report is assessed for credibility, severity, and urgency, and categorised; conflicts of interest are considered and escalated where needed
Proportionate investigation — additional information requests, review of transaction records and due diligence files, interviews, and external advisors where necessary
Outcome & corrective action — risk mitigation, suspension or refusal of transactions, disengagement, strengthened controls, or referral to authorities where legally required
Communication & closure — where possible, we provide a response or closure notice consistent with confidentiality and legal constraints

Confidentiality

Reports are treated confidentially and shared only with those who need the information to assess and respond, to comply with legal obligations, or to protect individuals from harm. High-severity matters are escalated to senior management. Personal data is handled in accordance with applicable privacy requirements.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose

AuHandel is committed to responsible sourcing of gold and to conducting business with integrity, transparency, and respect for human rights. We seek to prevent, identify, and address risks of adverse impacts connected to gold sourcing and trade, including risks related to conflict, money laundering, terrorism financing, bribery, fraud, and serious human rights abuses.

This policy is implemented through a risk-based due diligence system aligned to internationally recognised guidance for minerals from conflict-affected and high-risk areas, including the OECD due diligence framework and expectations reflected in RJC-aligned practice.

Scope and operating model

AuHandel operates as a brokerage / principal trading counterparty in the physical gold market. AuHandel does not refine and does not claim to be a refiner.

Gold-bearing materials and refined gold products that AuHandel buys, sells, arranges, or finances (where applicable)
All counterparties — suppliers, intermediaries, logistics, and service providers — involved in AuHandel transactions
All jurisdictions in which AuHandel operates or sources from

Commitments & controls

Respect human rights and apply due diligence to identify, prevent, mitigate, and account for adverse impacts
Implement a risk-based due diligence program consistent with the OECD five-step framework
Apply enhanced scrutiny for conflict-affected and high-risk areas (CAHRAs) using credible sources and documented assessment
Maintain zero tolerance for severe abuses, corruption, and illicit finance connected to gold
Provide an accessible grievance mechanism with confidentiality protections and responsible follow-up
Continuously improve the program through periodic review, training, and updates when the risk context changes

Prohibited conduct (zero tolerance)

AuHandel will not tolerate, profit from, contribute to, assist with, or facilitate any party’s involvement in:

Torture, cruel, inhuman, or degrading treatment
Forced or compulsory labour, or the worst forms of child labour
Widespread sexual violence or other gross human rights abuses
War crimes, serious violations of international humanitarian law, crimes against humanity, or genocide
Direct or indirect support to illegitimate armed groups or illegitimate security forces
Bribery (including facilitation payments), fraud, and misrepresentation of gold origin or documentation
Transactions carrying a reasonable risk of money laundering or terrorism financing

Reporting & escalation

Stakeholders — including employees, suppliers, logistics partners, and impacted parties — may raise concerns about responsible sourcing risks. Reports may be made in good faith and may be anonymous where allowed by law. Contact: david@auhandel.com, or see the Whistleblower & Grievance Mechanism below.

Due diligence records — onboarding, risk assessments, transaction documentation, decisions, and incident logs — are retained consistent with legal and operational requirements and in a way that supports audit readiness.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose

AuHandel respects internationally recognised human rights. We are committed to avoiding causing or contributing to adverse human rights impacts through our activities, and to seeking to prevent or mitigate adverse impacts directly linked to our operations, products, or services through business relationships, even if we have not contributed to those impacts.

Scope

AuHandel does not refine gold and does not engage in retail bullion sales.

AuHandel’s operations and decision-making
Counterparty onboarding and transaction execution processes
Relevant business relationships connected to AuHandel’s gold trading and sourcing activities

Zero tolerance for severe abuses

AuHandel maintains zero tolerance for the most severe forms of human rights abuse, including:

Forced or compulsory labour
The worst forms of child labour
Human trafficking
Torture, cruel, inhuman, or degrading treatment
Widespread sexual violence
War crimes, serious violations of international humanitarian law, crimes against humanity, or genocide

Due diligence approach

We apply human rights due diligence commensurate with our role and risk exposure, consistent with the identify – prevent/mitigate – account logic of human rights due diligence guidance. Where credible indicators of severe abuse exist and risk cannot be mitigated, AuHandel will decline or disengage from the relationship or transaction.

Human rights considerations incorporated into onboarding and transaction review
Screening for high-risk jurisdictions and conflict-affected contexts
Heightened scrutiny where upstream visibility is limited, including where artisanal and small-scale mining (ASM) may be involved
Records of due diligence decisions and periodic review of control effectiveness

Reporting & escalation

Concerns about human rights, including potential adverse impacts connected to AuHandel’s business relationships, may be reported to complaints@auhandel.com. Reports are treated discreetly, retaliation against good-faith reporting is prohibited, and credible severe allegations are escalated to senior management.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose

This policy defines how AuHandel establishes governance and controls for responsible gold supply chains; identifies and assesses risks in gold transactions and related business relationships; prevents, mitigates, or ceases engagement where risks are unacceptable; maintains appropriate records and transparency; and provides an accessible grievance channel.

Scope & principles

Applies to gold and gold-bearing materials involved in AuHandel’s activities and to all relevant counterparties and service providers, including intermediaries, logistics, and custody. Our due diligence is:

Risk-based — depth of checks increases with risk indicators
Proportionate — commensurate with our role and available visibility
Documented — decisions and evidence are recorded
Escalation-driven — elevated risk requires senior review
Continuous — periodically reviewed and improved

OECD five-step framework

Step 1 — Strong management systems: governance and accountability (Compliance Lead / Responsible Sourcing Officer), published policies, counterparty onboarding, training, and record-keeping
Step 2 — Identify and assess risks: identity and ownership, geographic and CAHRA exposure, supply chain integrity, transaction structure, integrity, human rights, and ASM-related risks
Step 3 — Respond to risks: additional corroboration, enhanced due diligence with management approval, conditions and controls, suspension pending investigation, or disengagement
Step 4 — Assurance and verification: reliance on reputable audit reports, certifications, or equivalent assurance where proportionate to risk
Step 5 — Reporting and transparency: published policy commitments, a grievance channel, and appropriate internal records of decisions and risk responses

Zero tolerance & immediate escalation

The following require immediate escalation to senior management and will typically result in suspension or refusal unless risks can be clearly ruled out:

Credible indicators of severe human rights abuses (forced labour, child labour, trafficking, torture, widespread sexual violence)
Credible indicators of conflict financing or support to armed groups
Bribery or corruption demands or evidence
Material misrepresentation of origin or documentation
Suspicious transaction structures consistent with money laundering or terrorism financing

Counterparty expectations

Depending on risk, AuHandel may request entity registration details, beneficial ownership and control information, authorised signatories, supply chain role and sourcing footprint, origin-related and logistics documentation, settlement information, and compliance program evidence. Failure to provide reasonable information may result in refusal or disengagement.

Reporting & escalation

Concerns connected to AuHandel’s gold supply chain activities may be reported to complaints@auhandel.com. Reports are handled discreetly, retaliation for good-faith reporting is prohibited, and concerns are investigated proportionately.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose

This policy defines AuHandel’s approach to identifying and managing risks related to conflict-affected and high-risk areas (CAHRAs) in gold transactions and related business relationships; ensures heightened scrutiny and senior oversight for elevated-risk contexts; and prevents AuHandel from contributing to conflict, serious human rights abuses, or illicit financing.

Scope & definition

Applies to all gold transactions and business relationships with actual or potential CAHRA exposure — through counterparties, sourcing footprints, transport routes, or transaction structures.

CAHRAs include areas experiencing armed conflict, widespread violence, fragile post-conflict settings, weak governance, or systematic violations of international law or human rights, and areas where corruption, criminality, and illicit finance risks are elevated. AuHandel uses credible, current sources for CAHRA screening and treats the classification as dynamic.

Commitments & controls

Apply enhanced due diligence (EDD) where CAHRA indicators are present — additional corroboration, heightened integrity checks, and verification of logistics and settlement structures
Escalate CAHRA-exposed transactions to senior management for documented review and decision before proceeding
Impose conditions and controls where engagement is permitted — payment channel restrictions, additional documentary requirements, transaction limits, defined mitigation timelines
Maintain documentation of screening inputs, assessment rationale, mitigation measures, decisions, and monitoring outcomes

Disengagement triggers

AuHandel will typically decline or disengage where any of the following are present and cannot be credibly ruled out:

Credible indicators of severe abuses — forced labour, worst forms of child labour, trafficking, torture, widespread sexual violence, war crimes
Direct or indirect support to illegitimate armed groups or abusive security forces
Bribery or kickback demands, material fraud, or misrepresentation of origin or routing
Credible money laundering or terrorism financing risks
Non-cooperation with due diligence, repeated inconsistencies, or attempts to circumvent controls

Reporting & escalation

Concerns related to CAHRA exposure or adverse impacts may be reported to complaints@auhandel.com. Reports are handled discreetly and retaliation for good-faith reporting is prohibited.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose

AuHandel recognises that precious metals supply chains can be exposed to elevated money laundering and terrorism financing risks. We apply a risk-based approach to counterparty onboarding, transaction review, and record-keeping to reduce AML/CTF risk and support lawful, transparent execution consistent with applicable legal obligations.

Scope

Applies to all transactions and business relationships involving AuHandel, including brokerage and execution arrangements and institutional gold trading activity, and to all counterparties and relevant service providers. AuHandel does not engage in retail bullion sales.

Commitments & controls

Risk-based counterparty due diligence (KYC): verification of legal entity and authority to transact, ownership and control where applicable, purpose and expected activity, and risk screening including geographic, CAHRA, adverse information, and sanctions considerations
Enhanced due diligence (EDD) where higher-risk indicators exist — high-risk jurisdictions, opaque settlement structures, unexplained third-party payments, or documentation inconsistencies
Settlement transparency: cash-intensive structures, unexplained third-party payments, and unusual routing without credible justification may be declined
Documentation integrity review and risk-based ongoing monitoring of counterparties and activity
Training for relevant personnel on AML/CTF red flags and escalation procedures

Reporting & escalation

Elevated risks follow a documented escalation path: front-line identification, compliance review, and senior management decision where required — approve, conditionally approve, suspend pending investigation, or decline. Where suspicious activity is identified, AuHandel acts in accordance with applicable legal obligations, which may include reporting to relevant authorities and refusing the transaction.

Concerns relating to illicit finance risks may be reported to complaints@auhandel.com.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Purpose & scope

AuHandel maintains a zero-tolerance approach to bribery and corruption and expects integrity, transparency, and lawful conduct in all business dealings. This policy applies to all AuHandel business activities and relationships, interactions with public officials and private parties, gifts and hospitality, and all third parties acting for or on behalf of AuHandel.

Prohibited conduct (zero tolerance)

Bribes — offering, promising, giving, requesting, or accepting anything of value to improperly influence a decision
Kickbacks and undisclosed improper payments connected to awarding business
Facilitation payments — prohibited without exception
Improper benefits — gifts, travel, hospitality, or offers intended to influence decisions
False documentation — misrepresenting origin, taxes, fees, or compliance status
Indirect bribery through agents, consultants, introducers, or intermediaries

Controls

Gifts and hospitality: only modest, infrequent, transparent, and lawful courtesies; never cash or equivalents; never during sensitive decision periods
Enhanced scrutiny for interactions with public officials and high-risk government-facing touchpoints
Risk-based due diligence on intermediaries, contractual compliance commitments, and refusal of engagements involving unvetted intermediaries
Disclosure and management of actual or potential conflicts of interest
Records of approvals, third-party due diligence, and investigation outcomes

Reporting & escalation

Concerns about bribery, corruption, fraud, or improper conduct may be reported to complaints@auhandel.com. Reports are treated discreetly, retaliation is prohibited, and credible allegations are escalated to senior management. Breaches may result in refusal or termination of business relationships, disciplinary action, and reporting to authorities where required by law.

Governance & review

Approved by senior management of AU HANDEL LTD prior to publication. Reviewed at least annually, and whenever the legal, regulatory, or risk context changes materially.

Accountability

Policy governance & review

AuHandel’s policies are overseen by senior management of AU HANDEL LTD. A designated Compliance Lead / Responsible Sourcing Officer maintains policy documentation, coordinates training, manages escalation, and monitors implementation. All published policies are approved by management prior to publication and reviewed at least annually — and whenever there is a material change in legal or regulatory requirements, operating footprint, sourcing risk profile, or lessons learned from implementation and grievances.

AuHandel’s policies are published to describe our commitments and approach. They do not create contractual rights for third parties and do not constitute an offer, quotation, or solicitation. Any transaction is subject to due diligence, internal approvals, and contractual agreement.