Named accountability
A responsible officer owns the sourcing policy and signs off every new supply line. The role is named in the policy, not left to a committee.
Commitment three
Social engagement & governance
Fair payment terms for cooperatives at origin, and a governance policy that survives audit.
At origin
Paid against assay, on stated terms
The most consequential thing a bullion buyer does at origin is not philanthropy. It is paying correctly and on time. Late payment and unexplained deductions are what push cooperatives toward informal buyers, and informal buyers are where the chain of custody breaks.
So we pay against assay, on the terms stated in the contract, without discretionary deduction. The assay result is shared with the seller in the same form the buyer receives it, and any dispute is resolved by a third assay rather than by negotiation.
What we commit to
- Payment against assay on stated terms, without discretionary deduction
- The assay result shared with the seller, in full, in the same form the buyer sees
- Disputes resolved by an agreed third assay, not by renegotiation
- No purchase from any site where forced or child labour is indicated
- Training on documentation and sampling offered to cooperative suppliers
Governance
A policy that survives audit
Records for five years
Permits, assays, inspection notes and payment records are retained for five years and produced on audit without redaction.
Independent audit
The due-diligence practice is audited by a third party — the practice itself, not only the file it produces.
Conduct
How we behave as a counterparty
- An NCNDA is signed before any supplier or buyer detail is disclosed
- No facilitation payments, in any jurisdiction, for any reason
- Sanctions screening on every counterparty and on the transport chain
- Conflicts of interest declared in writing before a trade is priced
- A grievance channel open to suppliers, buyers and staff alike