Compliance – International, Patriot Act

Gold Supply Chain Policy

Chief Gold supports worldwide efforts to ensure that precious metals come from legitimate ethical sources, and that they have not been associated with criminal activity, armed conflict, terrorism, or human rights abuse. Chief Gold will refuse any business proposal which might be connected with any illegitimate activity. Our gold supply chain practices and due diligence policy are consistent with the laws of The United States of America, OECD due diligence guidance on conflict minerals, and import laws of Hong Kong. We have implemented a program of strict due diligence to ensure that the mined gold we source meets the highest human rights, social, and environmental criteria at all stages in the supply chain (mining, processing, etc.).

We commit to check on a per client basis that:

1. Request that basic human rights are being respected by all parties involved in the mining, processing, and exporting of the metal. We will not tolerate any kind of inhuman treatment, forced or compulsory labor, child labor, human rights violations and abuses.

2. Request that workers’ rights and labor standards are being respected by all parties involved in mining, processing, and exporting of the metal.

3. Chief Gold and partners/clients are not engaging and will immediately discontinue engagement with customers or suppliers where we identify a reasonable risk that they are committing, or are sourcing from or linked to any party committing any abuses described above or any other illegal party.

4. Gold and precious metals traded do not facilitate the funding of any kind of armed conflicts.

5. Procured metals are NOT from countries prohibited by the laws of the United States of America, the OECD, or Hong Kong.

6. Partners, clients, and mining companies are NOT offering, promising, giving or demanding bribes or kickbacks in any form to individuals, including government officials, customers, contractors and suppliers or any other organization.

7. Partners, clients, and mining companies are NOT misrepresenting taxes, fees and royalties paid to governments for the purposes of extraction, trade, handling, transport and export of precious metals. Likewise Chief Gold and its partners will NOT conceal the origin of precious metals.

8. Supporting efforts to avoid and disclose money-laundering and financing of terrorism where we identify a reasonable risk of money-laundering and financing of terrorism resulting from, or connected to the supply and distribution chain of precious metals.

9. Procured gold and precious metals that are mined and produced without endangering the safety and health of people or damaging the environment.

10. Chief Gold requests that the metals have not been sourced from mining/smelting operations that will result in toxic chemical contamination into soil, surface water, groundwater, or the environment.

https://www.pmmc.gov.gh/pmmc/

Due Diligence Documentation

The seller agrees to supply the buyer with the following DUE DILIGENCE supply chain documentation to prove their gold is legally obtained and can legally clear customs, be refined, and sold in USA, EU, Hong Kong (ROC), and various signatory countries following the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas


1. “Seller information sheet” on company letterhead with
  • Company’s Articles of Formation or Certificate of Assumed Business Name (DBA) and Business License/Government Tax ID
  • Passport copies of owners of mining company
  • Statement of compliance with the following Supply Chain Policy (See Attachment #1)
2. “Letter from the Mining Company” to prove legal origin for USA Patriot Act and Hong Kong/EU anti-money laundering/anti-smuggling laws. Letter includes:
  • Mining Company’s Articles of Formation or Certificate of Assumed Business Name (DBA) and Business License/Government Tax ID
  • Mine location and a picture
  • Mining company’s permit or govt. license for mine
  • Passport copies of owners of mining company
  • Statement from mine owners of compliance with the following Supply Chain Policy (See Attachment #1)

Note: Failure to provide this documentation may void contracts