ULTRA GOLD AND DIAMOND JEWELLERY RESPONSIBLE GOLD TRADING POLICY

  1. INTRODUCTION

It is the policy and practice of Ultra Gold and Diamond Jewellery to maintain high standards of ethical conduct, to comply with all applicable laws, and to do business only with persons who themselves abide by laws and ethical principles. In particular, when trading gold, we will operate only with transparency by all parties and with assurances of legitimacy in all transactions.

This Policy sets out Ultra Gold and Diamond Jewellery’s commitment to the standards set by the following:

  • the World Gold Council’s Responsible Gold Mining Principles (“RGMPs”); 
  • the London Bullion Market Association’s Responsible Gold Guidance (“RGG”) policy document;
  • the Organisation for Economic Co-operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Due Diligence Guide”); and
  • the principles relating to trade of conflict minerals as contained in section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”),

and establishes the measures that we will implement to further these commitments.

Ultra Gold and Diamond Jewellery is committed to sustainable gold trading that remains cognizant of and promotes environmental (including climate change), social (including occupational health and safety) and governance (“ESG”) matters. 

In particular, Ultra Gold and Diamond Jewellery is opposed to activities which, directly or indirectly, finance or benefit armed conflict and the extreme levels of violence which contribute to abuses of human rights. Moreover, we are committed to trading gold originating from operations which conform to internationally-accepted environmental practices.

Consequently, Ultra Gold and Diamond Jewellery commits to refraining from knowingly trading in gold that originates from regions and operations which contribute to the financing of conflict or the degradation of the environment and further commits to complying with the relevant United Nations sanctions, recommendations and protocols from other appropriate supra-national bodies, in this regard.

Furthermore, Ultra Gold and Diamond Jewellery is committed to publicly endorsing the RGMPs, the RGG, the OECD Due Diligence Guide and the principles contained in section 1502 of the Dodd-Frank Act, using our best endeavors to encourage the adoption of these policies and procedures at all operations where we have influence, and, where applicable, ensuring direct compliance with them in our gold trading operations.

In addition, Ultra Gold and Diamond Jewellery is committed to expanding the awareness and understanding of the RGMPs, the RGG, the OECD Due Diligence Guide and the principles contained in section 1502 of the Dodd-Frank Act of our directors, officers, consultants, shareholders and other stakeholders.

  1. SCOPE OF THE POLICY

This Policy applies to Ultra Gold and Diamond Jewellery, as well as our direct and indirect subsidiaries.

  1. POLICY STATEMENTS

Ultra Gold and Diamond Jewellery is opposed to, and commits to refraining from, trading gold in gold that originates from conflict-affected and high-risk regions and operations. As further stated, we endorse the RGMPs, the RGG, the OECD Due Diligence Guide and the principles contained in section 1502 of the Dodd-Frank Act and are committed to expanding the awareness and understanding of our various stakeholders of the principles thereof, as well as using our best endeavors to encourage the adoption of these policies and procedures at all operations where we have influence.

We will not conduct business, in any form, with any contractor, supplier or trader that:

  • Has unethical work practices such as any human rights violations
  • Has had any instances of past misconduct such as sexual, physical, emotional, or intellectual abuse
  • Performs, or has performed, any forms of child labor
  • Performs, or has performed, any forms of forced labor
  • Performs, or has performed, any form of fraudulent activity such:
  • Money laundering
  • Incorrect representation of the source of any minerals
  • Tax evasion or any form of fraudulent tax activities
  • Extortion
  • Bribery
  • Corrupt business practices
  • Will not source any raw minerals from any high-risk and in-conflict areas
  • Does not pay its staff minimum wage according to their countries law
  • Has lasting or irreparable damage to the environment 

In furtherance of this endorsement and these commitments, Ultra Gold and Diamond Jewellery will take the following measures:

  1. Training: We are committed to training its officers and employees to better understand and implement this Policy;
  1. Due Diligence: Ultra Gold and Diamond Jewellery is committed to identifying and recording the implementation of and conformance with the RGMPs when onboarding new clients, including applying a robust Know Your Customer (KYC) policy in order to identify transactions which would contravene this Policy or would represent money laundering or another related criminal activity;
  1. External Consultants: We are committed to ensuring that all consultants are familiar with this Policy before engaging with them.
  1. Contractual Provisions: Ultra Gold and Diamond Jewellery committed to ensuring that appropriate contractual provisions aligning with its commitments as set out in this Policy are negotiated when pursuing new business opportunities;
  1. Monitoring: We are committed to monitoring our implementation of and conformance with the Policy in respect of our gold trading operations;
  2. Transparency: Ultra Gold and Diamond Jewellery is committed to publicly reporting, on an annual basis, on the status of our conformance to the commitments and measures described in this Policy;
  1. Independent Reporting: We are committed to engaging with an appropriately qualified external provider to produce an annual report on our conformance to the commitments and measures described in this Policy, which report we will publicly release; and
  1. Internal Controls: Ultra Gold and Diamond Jewellery is committed to developing internal systems and processes to ensure our compliance with the foregoing measures.
  1. ADMINISTRATION OF THE POLICY

Ultra Gold and Diamond Jewellery’s Compliance Committee will review this Policy annually to ensure that it is effective in achieving its objectives and may recommend changes to such objectives or this Policy or may recommend additional objectives as appropriate.

  1. DATE OF ADOPTION

This Policy was adopted in February 2022. This Policy supersedes any written or oral representations that are in any way inconsistent with it.

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