Precious Metal Refinery | Gold Refinery | Advanced Chemical Company - RESPONSIBLE SOURCING POLICY
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Advanced Chemical Company - Responsible Sourcing Policy

Advanced Chemical Company ("ACC") is a conformant smelter participating in the Responsible Minerals Initiative ("RMI") Responsible Minerals Assurance Process ("RMAP") and maintains a due diligence management system consistent with the Organization for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

ACC is committed to conducting business ethically and responsibly while respecting internationally recognized human rights. ACC prohibits the sourcing, purchasing, processing, or refining of any gold-containing material that directly or indirectly finances or benefits illegal armed groups, contributes to human rights abuses, facilitates money laundering or the financing of terrorism, or otherwise violates Annex II of the OECD Due Diligence Guidance. 

ACC shall only purchase gold-containing materials from suppliers whose materials have been verified as not involving or contributing to the prohibited activities listed in Annex II of the OECD Due Diligence Guidance, including serious human rights abuses, forced labor, child labor, war crimes, support to armed groups, bribery, money laundering, terrorist financing, and non-payment of legally required taxes, fees, or royalties. 

Supplier Requirements 

Compliance with this Responsible Sourcing Policy is a mandatory condition of conducting business with Advanced Chemical Company. 

All suppliers shall: 

  • Source materials exclusively from supply chains that comply with Annex II of the OECD Due Diligence Guidance. 
  • Maintain a documented due diligence management system consistent with OECD Guidance and RMАР. 
  • Maintain complete, accurate, and verifiable records demonstrating compliance and provide such records immediately upon request. 
  • Maintain written Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) policies. 
  • Cooperate fully with all due diligence requests, supplier assessments, documentation requests, audits, and verification activities. 
  • Immediately disclose any actual or suspected violation of this policy. 
  • Implement corrective actions within timelines established by ACC. 
  • Flow these responsible sourcing requirements to their upstream suppliers. 

Failure to comply with these requirements may result in immediate suspension or termination of the supplier relationship. 

ACC Due Diligence Requirements 

Advanced Chemical Company shall maintain a responsible minerals due diligence management system that: 

  • Exercises risk-based due diligence consistent with OECD Guidance and RMАР. Requires suppliers to provide complete, accurate, and timely due diligence information. 
  • Verifies supplier compliance through documented risk assessments, KYC procedures, supporting documentation, supplier declarations, and verification activities. 
  • Maintains business relationships only with suppliers that consistently demonstrate compliance. 
  • Requires continual supplier improvement. 
  • Requires immediate corrective actions for identified nonconformances. 
  • Suspends or terminates suppliers that fail to mitigate identified risks. 
  • Immediately suspends or terminates suppliers presenting a reasonable risk of contributing to severe human rights abuses, supporting armed groups, engaging in money laundering or terrorist financing, or violating this policy. 
  • Undergoes annual RMAP assessments. 
  • Maintains transparency with customers, stakeholders, regulators, and the public as applicable. 
  • Supports the Extractive Industries Transparency Initiative (EITI). 

Financial Integrity 

ACC shall conduct all payments and receipts for gold transactions through regulated financial institutions; prohibit cash transactions unless legally required or formally approved and documented; maintain complete transaction records; cooperate fully with regulatory, customs, and law enforcement authorities when requested or required; and provide complete and accurate documentation for all international shipments and customs declarations. 

Conflict Minerals Scope 

Gold is currently the only mineral processed by Advanced Chemical Company that falls within the scope of the Responsible Minerals Initiative Responsible Minerals Assurance Process. 

Grievance Mechanism 

Any employee, supplier, customer, contractor, stakeholder, or interested party who becomes aware of a potential violation of this Responsible Sourcing Policy shall promptly report the concern through Advanced Chemical Company's Grievance Mechanism. 

All reported grievances shall be reviewed, investigated, documented, and resolved in accordance with ACC's Grievance Policy and applicable corrective action procedures. ACC shall investigate all reported concerns, implement corrective actions where appropriate, and communicate the outcome to the reporting party to the extent permitted by law. Reports may also be submitted directly through the Responsible Minerals Initiative Grievance Mechanism. 

Compliance 

Compliance with this policy is mandatory for all employees, contractors, suppliers, and business partners. Failure to comply, refusal to cooperate with due diligence activities, submission of false or misleading information, failure to implement corrective actions, or failure to maintain required documentation may result in suspension or termination of the business relationship, reporting to appropriate authorities, or other actions deemed necessary by ACC. 

For additional information regarding our Responsible Minerals Initiative program or our company, please visit www.advchem.com, or email info@advchem.com. 

David Farnum
President and COO