COMPLIANCE | RESPONSIBLE GOLD SOURCING & RISK CONTROLS
Responsible sourcing governs every stage of SigraFi’s operation. The Company's Know-Your-Gold (KYG) framework is aligned with the three leading international standards: the OECD Due Diligence Guidance for Responsible Supply Chains (CAHRAs), the World Gold Council's Responsible Gold Mining Principles (RGMPs), and the LBMA Responsible Gold Guidance (RGG). All counterparty vetting, including sanctions and AML screening and provenance verification, is conducted in accordance with UK, European and UAE regulatory compliance obligations. SigraFi does not offtake from, provide capital to, or invest in gold from sanctioned jurisdictions, conflict zones, or untraceable sources. SigraFi’s gold sourcing policies align with the OECD Due Diligence Guidance for Responsible Supply Chains and are structured to meet institutional KYC/AML and ESG requirements across all jurisdictions.
Counterparty Enhanced Due Diligence
❖Mining licences & permit verification
❖Beneficial ownership disclosure
❖PEP & adverse media screening
❖Sanctions screening
❖Ongoing monitoring
Framework Alignment
❖OECD CAHRAs Due Diligence Guidance (2022)
❖WGC Responsible Gold Mining Principles
❖LBMA Responsible Gold Guidance
❖EU Regulation 2017/821 (EU Conflict Minerals Regulation)
❖HHRDD
Supply Chain and Provenance Controls
❖Mine-of-origin declaration
❖Chain of custody documentation
❖Conflict mineral & CAHRA screening
❖UN Group of Experts findings review
❖Refinery certification requirements
GOVERNANCE
The Gold Standard: Corporate responsibility, ethical conduct, responsible gold sourcing practices, and commitment to best practice governance and monitoring of the Company’s environmental and social impacts, form the foundation of SigraFi’s approach to managing ESG related risks. The Company implements clear, transparent policies and monitors operations to ensure their effectiveness. SigraFi does not offtake from, provide capital to, or invest in gold from sanctioned jurisdictions, conflict zones, or untraceable sources. Our work is governed by our published policy framework below. The framework applies to every member of the SigraFi team and to every counterparty relationship.
Corporate Responsibility
SigraFi is committed to conducting business with discipline, consistency, strategic focus, transparency and reliability, integrating these values into every aspect of the Company’s operations. The Company develops, monitors and implements policies to uphold these values and to ensure every aspect of its operations address, minimise and mitigate ESG related risks.
Ethical Conduct
The Company’s policy on Ethical conduct covers, but is not limited to, a commitment to upholding workers’ and wider human rights, effective management, oversight and mitigation of conflicts of interest through comprehensive anti-bribery and corruption measures, transparent reporting and upholding all business partners to the same standard.
Best Practice Governance
In addition to specific policies covering ethical business conduct and mitigating conflicts of interest, SigraFi maintains a thorough risk register overseen by the Board, adopts a compliance-first approach to due diligence in all areas of operation, regularly reviews policies for effectiveness and fosters a culture of integrity and transparency at all levels of the organisation.
Responsible Gold Sourcing
SigraFi’s strict know-your-gold (KYG) procedures aim at ensuring that the gold the Company processes and/or procures does not directly or indirectly contribute to the abuse of human rights, conflict, or irremediable environmental degradation, and is in full compliance with the laws and regulations of the jurisdictions in which SigraFi and its suppliers and customers operate.
Environmental Impact
Whilst SigraFi is not actively engaged or in control of gold production activities, by delivering access to capital the Company has a role to play in supporting the industry in the responsible production of gold and minimising its environmental impact. SigraFi is committed to working only with producers and refineries who share these values and standards.
Social Impact
SigraFi aims to improve the lives of the producers in its supply chain, and their wider communities, through financial inclusion, fair pricing, rigorous policies regarding child/forced labour, as well as health and safety standards and practices. SigraFi only enters into business relationships with producers who share their commitment to worker and human rights.
GUIDING POLICIES & FRAMEWORKS
As upstream actors in the gold supply chain, SigraFi is committed to upholding the principles of applicable best practice frameworks, to their public endorsement, and to using the Company’s best endeavours to encourage their adoption by all operations over which it has influence. The Company develops, implements and actively monitors adherence to policies guided by these frameworks. In addition to endorsing and encouraging the adoption of the principles of these frameworks, and in accordance with the principles therein, SigraFi is committed to driving awareness and understanding of these codes of conduct by the Company’s directors, officers, employees, temporary staff, contractors, consultants, shareholders and other stakeholders.
ADOPTED FRAMEWORKS
World Gold Council’s (“WGC”) Responsible Gold Mining Principles (“the RGMPs”) – 2019
London Bullion Market Association’ (“LBMA”) Responsible Gold Guidance, Version 9 (“RGG”) - 2021
Organisation for Economic Co-operation and Development’s (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-affected and High-risk areas (“CAHRAs”) – 2011
OECD’s Handbook on Environmental Due Diligence in Mineral Supply Chains – 2023
UN Sanctions List / UN Group of Experts (GoE) Guidelines – Live
United Nations’ (“UN”) Guiding Principles on Business and Human Rights (“UNGPs”) – 2011
United Nations’ Development Programme (“UNDP”) Heightened Human Rights Due Diligence for Business in Conflict-Affected Contexts (“HHRDD”) - 2022