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OECD COMPLIANCE & RESPONSIBLE SOURCING
📍 Kampala Vault Hub

OECD Compliance & Responsible Sourcing

Our supply chain management is anchored in the 5-Step Framework of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

1

Step 1: Strong Management Systems

We maintain clear supply chain policies, dedicated compliance personnel, and formal contracts requiring all regional DRC mining partners to adhere to conflict-free sourcing protocols.

2

Step 2: Supply Chain Risk Identification

We map the physical chain of custody from mine site to export hub, assessing risks related to mineral extraction, transport, trade, and taxation in regional supply corridors.

3

Step 3: Risk Mitigation Strategy

We execute documented risk management plans, conducting ongoing monitoring of transportation routes and enforcing secure custody controls at our Kampala facilities.

4

Step 4: Independent Supply Chain Audit

We support independent third-party audits of due diligence practices and ensure export documentation undergoes rigorous customs and regulatory verification.

5

Step 5: Annual Public Reporting

We document and report on our due diligence policies, origin verification metrics, and supply chain management practices to foster institutional trust.

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KYC / AML Governance

Mandatory Know Your Customer (KYC) screening and Anti-Money Laundering (AML) checks enforced for all buyers, logistics carriers, and financial institutions.

Mandatory Buyer KYC Compliance Documentation

Before executing any Sale & Purchase Agreement (SPA), corporate buyers are required to submit standard due diligence documentation:

  • ✓ Certificate of Corporate Incorporation & Trade License
  • ✓ Memorandum & Articles of Association
  • ✓ Authorized Signatory Passport Copies & Resolutions
  • ✓ Verified Tax Identification & Regulatory Registrations
  • ✓ Nominated LBMA/Licensed Refinery Confirmation
  • ✓ Bank Comfort Letter / SWIFT Proof of Funds Capability