1. Purpose and Commitment
Kingman Refinery is committed to conducting its business in a lawful, transparent and responsible manner. The Company adopts appropriate measures to prevent, detect and mitigate risks of money laundering, terrorist financing and other illicit financial activities across all its operations.
This Anti-Money Laundering (AML) Policy is established to ensure that Kingman Refinery operates in compliance with:
- Applicable laws and regulations in Kenya
- Relevant anti-money laundering and counter-terrorist financing requirements
- International best practices applicable to the gold refining and precious metals industry
2. Scope of Application
This AML Policy applies to:
- All operations of Kingman Refinery
- All counterparties, business partners and stakeholders engaging with the Company
- Directors, officers, employees and any persons acting on behalf of the Company
Kingman Refinery does not provide retail services, does not sell investment products, and does not engage in public gold trading platforms. AML controls are therefore applied within a B2B, post-mining industrial context.
3. Core AML Principles
Kingman Refinery implements AML controls based on the following principles:
- Compliance-first approach: Compliance with applicable laws and regulatory requirements is a fundamental condition of all business activities.
- Risk-based approach: AML measures are proportionate to the level of risk associated with counterparties, transactions and source of gold.
- Transparency and traceability: Transactions, materials and processes are documented to ensure traceability at batch level.
- Zero-tolerance policy: Kingman Refinery does not engage in transactions involving unlawful, undocumented or suspicious sources of gold or funds.
4. Counterparty Identification and Due Diligence
Prior to entering into any business relationship or transaction, Kingman Refinery performs appropriate counterparty due diligence, including:
- Verification of legal existence and licensing status
- Assessment of business activities and risk profile
- Review of compliance-related documentation
Only counterparties that meet the Company’s legal and compliance requirements are permitted to transact with Kingman Refinery.
5. Source-of-Gold Controls
Kingman Refinery only accepts and processes gold that:
- Has a lawful and documented source
- Is supplied by licensed and authorized counterparties
- Falls within the scope of applicable licences and regulations
The Company does not accept gold of unknown origin, illegally mined gold, or gold associated with conflict or prohibited activities.
6. Transaction Monitoring and Record Retention
Kingman Refinery implements controls to:
- Monitor transactions for unusual or suspicious patterns
- Maintain accurate records of commercial, technical and compliance documentation
- Retain records for appropriate periods in accordance with applicable regulations
All records are maintained in a manner that allows timely retrieval for internal review, audit or lawful regulatory requests.
7. Internal Responsibilities and Training
Personnel involved in operational, technical, commercial and compliance functions are:
- Informed of their AML responsibilities
- Trained in accordance with their roles and risk exposure
- Required to escalate concerns or suspicions through appropriate internal channels
Management is responsible for overseeing the implementation and effectiveness of this AML Policy.
8. Reporting and Cooperation with Authorities
Kingman Refinery cooperates with competent authorities and financial institutions as required by law, including:
- Responding to lawful information requests
- Providing relevant documentation when legally required
- Fulfilling applicable reporting obligations
9. Policy Review and Updates
This AML Policy is reviewed and updated periodically to reflect:
- Changes in applicable laws and regulations
- Developments in industry best practices
- The Company’s operational experience and risk exposure
10. Final Statement
Kingman Refinery considers AML compliance to be a fundamental condition for maintaining operational integrity, regulatory confidence and long-term sustainability. This Policy reflects the Company’s ongoing commitment to responsible business conduct within the international gold refining and processing industry.