Bonas Gold Global Policies

Anti-Money Laundering (AML) ，Counter-Terrorist Financing (CTF), and Conflict Minerals Policy:

Bonas Gold complies with AML, CTF, and conflict minerals policies in Hong Kong, the UN, the US, the UK, the EU, the FATF, the UAE, and the African Union. Bonas Gold promotes responsible global supply chains for minerals from conflict-affected and high-risk areas.

As a gold trading company, we are fully committed to delivering high-quality products and services while adhering to the highest ethical and moral standards in responsible sourcing. We recognize that mining, trading, processing, and exporting minerals from conflict-affected and high-risk areas may carry significant risks of adverse impacts. We acknowledge our responsibility to respect human rights and avoid contributing to conflict.

We commit to implementing, disseminating, and incorporating the following policy into supplier contracts and agreements as a shared reference for conflict-sensitive sourcing practices and risk-aware supplier engagement from mine to end-user.

We pledge to take no action that contributes to conflict financing and commit to complying with relevant UN sanctions resolutions or domestic laws enforcing such resolutions where applicable.

Serious Abuses Related to Mineral Extraction, Transportation, or Trade

When sourcing from or operating in conflict-affected and high-risk areas, we will neither tolerate nor profit from, assist in, or facilitate any party’s involvement in:

i) Any form of torture, cruelty, inhuman, or degrading treatment.

ii) Any form of forced or compulsory labor—work or service exacted under threat of penalty and not voluntarily undertaken.

iii) The worst forms of child labor.

iv) Other gross human rights violations, such as widespread sexual violence.

v) War crimes, serious breaches of international humanitarian law, crimes against humanity, or genocide.

Risk Management of Serious Abuses

If we identify upstream suppliers sourcing from or linked to parties involved in serious abuses as defined above, we will immediately suspend or disengage from them.

Direct or Indirect Support to Non-State Armed Groups

We will not tolerate any direct or indirect support to non-state armed groups through mineral extraction, transport, trade, processing, or export. Such support includes, but is not limited to:

- Procuring minerals from, making payments to, or providing logistical assistance or equipment to non-state armed groups or affiliates.

- Illegally controlling mines, transport routes, or upstream supply chain actors.

- Illegally taxing or extorting money or minerals at mine sites, along transport routes, or at trade points.

- Illegally taxing or extorting intermediaries, export companies, or international traders.

Risk Management of Support to Non-State Armed Groups

If we identify upstream suppliers linked to parties providing direct or indirect support to non-state armed groups, we will immediately suspend or terminate engagement.

Public or Private Security Forces

We commit to eliminating direct or indirect support to public or private security forces that illegally control mines, transport routes, or upstream supply chain actors, or engage in extortion.

Security forces at or near mine sites or along transport routes should only uphold the rule of law, protect human rights, ensure worker and facility safety, and safeguard legal mining and trade operations.

When contracting security forces, we require adherence to the Voluntary Principles on Security and Human Rights. We implement screening policies to exclude individuals or units with known human rights violations.

We engage with authorities, international organizations, and civil society to enhance transparency, proportionality, and accountability in security payments and minimize adverse impacts on vulnerable groups, such as artisanal miners.

Risk Management of Public or Private Security Forces

If a reasonable risk of supporting abusive security forces is identified, we will develop and implement a risk mitigation plan. If mitigation fails within six months, we will suspend or disengage from the supplier.

Bribery and Fraudulent Misrepresentation of Mineral Origin

We strictly prohibit offering, promising, giving, or soliciting bribes in any form. We firmly resist any solicitation of bribes aimed at concealing or falsifying mineral origins, or misrepresenting taxes, fees, and royalties payable to governments for mineral extraction, trade, handling, transportation, and export purposes.

Money Laundering

We will support or take measures to effectively combat money laundering if we identify a reasonable risk of money laundering associated with the extraction, trade, processing, transport, or export of minerals obtained through illegal taxation or extortion at mine sites, along transportation routes, or at upstream suppliers' mineral trading locations.

Payment of Taxes, Fees, and Royalties to Governments

We ensure all taxes, fees, and royalties related to mineral extraction, trade, and export from conflict-affected areas are paid to governments. In line with our position in the supply chain, we disclose these payments per the **Extractive Industries Transparency Initiative (EITI).

Risk Management of Bribery, Fraud, Money Laundering, and Tax Payments

We engage with suppliers, governments, and stakeholders to track and improve performance, taking measurable steps to mitigate risks. If efforts fail, we suspend or disengage from suppliers.

Bonas Gold maintains a robust due diligence and risk control system, including:

- Defined scope, responsibilities, and escalation channels.

- Identification and assessment of high-risk supply chains.

- Know Your Customer (KYC) processes.

- Transaction monitoring and oversight.

- Mandatory training for supply chain personnel.

All employees involved in the gold supply chain must strictly adhere to this policy.

Contact

For questions or concerns regarding this policy, employees, stakeholders, and counterparties may email: info@bonasgold.com.