Due diligence

Responsible Sourcing

AuHandel is committed to responsible sourcing of gold and to conducting business with integrity, transparency, and respect for human rights. Our framework is aligned with the RJC Code of Practices and implemented through a risk-based due diligence system consistent with the OECD Due Diligence Guidance for responsible mineral supply chains.

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. AuHandel does not refine, does not mine, and does not claim ownership of supply; our controls are proportionate to our role as a brokerage and execution counterparty.

OECD alignment

Five steps, in plain language

Our due diligence program follows the OECD five-step framework. The depth of each step scales with the risk of the counterparty, geography, and transaction.

  1. 01

    Strong management systems

    Clear accountability — a designated Compliance Lead / Responsible Sourcing Officer, published policies, documented onboarding procedures, staff training, and record-keeping.

  2. 02

    Identify and assess risk

    For each counterparty and transaction we look at who we are dealing with, where the gold comes from to the extent visible, how it moves, and how it is paid for — screening for geographic risk, red flags, and inconsistencies.

  3. 03

    Respond to risk

    Where risks are identified we request more information, apply enhanced due diligence with senior sign-off, impose conditions, suspend while investigating — or decline and disengage where risk cannot be mitigated.

  4. 04

    Independent review

    Where proportionate, we rely on credible third-party assurance — reputable audit reports and certifications from counterparties — and periodically review the effectiveness of our own program.

  5. 05

    Report and improve

    We publish our policy commitments, keep records of due diligence decisions, and use lessons from implementation and reported concerns to strengthen controls.

Elevated-risk contexts

Conflict-affected & high-risk areas

Where a transaction or relationship shows exposure to conflict-affected and high-risk areas (CAHRAs) — through counterparties, sourcing footprints, transport routes, or settlement structures — enhanced due diligence applies. CAHRA-exposed transactions require senior management review before proceeding, are subject to documented conditions and mitigation plans, and are declined where credible risks cannot be ruled out. We treat CAHRA classification as dynamic and screen against credible, current sources.

Zero tolerance

Where we do not engage

AuHandel will not tolerate, profit from, contribute to, or facilitate any party’s involvement in the following. Where credible indicators exist and cannot be ruled out, we decline or disengage.

Forced & child labour

No tolerance for forced or compulsory labour, the worst forms of child labour, or degrading treatment anywhere in transactions we touch.

Human trafficking

No tolerance for human trafficking or other severe human rights abuses associated with the extraction, transport, or trade of gold.

Bribery & corruption

No bribes, kickbacks, or facilitation payments — and no fraudulent misrepresentation of gold origin, documentation, taxes, or royalties.

Conflict financing

No direct or indirect support to illegitimate armed groups or illegitimate security forces through sourcing, payments, logistics, or material assistance.

Continuous improvement

A program under review, by design

Responsible sourcing is not a static claim. Our policies and procedures are reviewed at least annually and whenever the risk context changes materially — new jurisdictions, new product forms, regulatory changes, or significant incidents. Training, red-flag awareness, and lessons from reported concerns feed back into the program.

We describe our commitments and approach honestly: due diligence reduces risk, it does not eliminate it. AuHandel does not make absolute claims such as “100% conflict-free”, and we treat any counterparty making such guarantees with additional scrutiny.