1. Purpose and Commitment
Kingman Refinery is committed to responsible sourcing of gold and precious metals in a manner that supports legal compliance, ethical business conduct and supply chain integrity.
The Company adopts measures to ensure that materials accepted, processed or exported are sourced responsibly and do not contribute to illegal activities, conflict, or human rights abuses.
This Policy forms an integral part of Kingman Refinery’s overall compliance framework, including its AML and KYC controls.
2. Scope of Application
This Responsible Sourcing Policy applies to:
- All gold and precious metal materials accepted by Kingman Refinery
- All suppliers, counterparties and intermediaries
- All domestic trading, processing, refining and export activities
Kingman Refinery operates strictly in a post-mining, B2B industrial context and does not engage in mining or extraction activities.
3. Responsible Sourcing Principles
Kingman Refinery implements responsible sourcing based on the following principles:
- Legality: Only materials sourced in compliance with applicable laws and regulations are accepted.
- Transparency: Suppliers are required to provide accurate and truthful information regarding their business activities and the source of materials supplied.
- Traceability: Materials are recorded and tracked at batch level to support chain-of-custody controls.
- Risk Awareness: The Company applies a risk-based approach to identify, assess and mitigate sourcing-related risks.
- Zero Tolerance: Kingman Refinery does not tolerate sourcing linked to illegal mining, conflict, corruption, money laundering, or other prohibited activities.
4. Source-of-Gold Requirements
Kingman Refinery only accepts gold that:
- Is supplied by licensed and authorised counterparties
- Has a lawful and documented origin
- Falls within the scope of applicable dealer, processing and export licences
The Company does not accept:
- Gold of unknown or undocumented origin
- Illegally mined gold
- Gold associated with conflict, sanctions or criminal activity
5. Counterparty Responsibilities
Suppliers and counterparties are expected to:
- Operate in compliance with applicable laws and licensing requirements
- Provide information necessary to verify the source of materials
- Cooperate with due diligence and compliance reviews
Failure to meet these expectations may result in refusal of materials or termination of the business relationship.
6. Risk Identification and Mitigation
Kingman Refinery identifies and manages sourcing risks through:
- Counterparty due diligence
- Review of source-of-gold documentation
- Ongoing monitoring of transactions and supply patterns
Where elevated risks are identified, enhanced due diligence or additional controls may be applied.
7. Record Keeping and Documentation
The Company maintains records related to sourcing, counterparties and materials in a secure and organised manner. Documentation is retained for appropriate periods to support internal review, audit processes and lawful regulatory requests.
8. Cooperation with Authorities and Stakeholders
Kingman Refinery cooperates with relevant authorities, regulators and financial institutions when legally required, and supports industry efforts to improve transparency and integrity in the gold supply chain.
9. Policy Review and Updates
This Responsible Sourcing Policy is reviewed periodically to reflect:
- Changes in laws and regulations
- Developments in industry best practices
- The Company’s operational experience and risk profile
10. Final Statement
Responsible sourcing is a core operating principle of Kingman Refinery. Through the implementation of this Policy, the Company seeks to contribute to a transparent, lawful and sustainable gold supply chain while maintaining regulatory confidence and long-term business integrity.