Supply Chain Due Diligence Information

Revised May 11, 2021

This is information is intended for all Sabin Metal Corporation customers, employees, suppliers, stakeholders and the general public.

Sabin Metal Corporation (and its subsidiaries and affiliates) exercise due diligence on all of our suppliers or counterparties in accordance with the London Platinum & Palladium Market’s (LPPM’s) Responsible Platinum/Palladium Guidance as well as the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High Risk Areas.

Sabin Metal Corporation retains a client database and part of our due diligence process entails creating a risk profile for each supplier or counterparty. Information requested is based on, but not necessarily limited to, the data requested in this template form from the LPPM. We will also conduct inquiries into the source of all material sent to us. This is in compliance with the LPPM and OECD initiatives referenced above as well as United States Federal regulation pertaining to refiners of precious metals such as ourselves. Our risk profile is based on numerous factors, including product risk, customer risk, and geographic risk. This information shall be kept confidential and released only to the extent there is a legitimate legal or regulatory need to do so.

Sabin Metal Corporation will not be associated with certain activities, particularly the crimes and activities mentioned in our Responsible Supply Chain Policy, below. Including but not limited to:

1. Serious abuses associated with the extraction, transport or trade of minerals, including:

  • torture, cruel, inhuman and degrading treatment; any forms of forced or compulsory labor
  • child labor
  • other gross human rights violations and abuses such as widespread sexual violence; war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide

2. Direct or indirect support to non-state armed groups

3. Illegal or abusive acts by security forces

4. Bribery or fraudulent misrepresentation of the origin of materials

5. Money Laundering and the financing of terrorism

6. Evasion or failure of the payment of taxes, fees and royalties due to governments, misrepresentations to same, and/or bribery of same (per our Anti Bribery and Corruption Policy)

7. Doing business with, or receiving any material, directly or indirectly, from any party in violation of sanctions by the United States, EU, UN, UK or other relevant authority

If Sabin Metal Corporation determines there is the risk of any supplier, counterparty, or participant in the supply chain of any material proposed to be sent to Sabin is engaged in any of the above activities, depending on the severity of the behavior and level of risk Sabin may at its discretion 1.) take action to mitigate or encourage the counterparty to mitigate the risk while continuing business, 2.) take action to mitigate or encourage the counterparty to mitigate the risk while suspending business, or 3.) disengage and/or refuse to enter into a business relationship at all with the relevant party.

Counterparties or suppliers considered high-risk shall also be subject to enhanced due diligence measures. These parties may include (but are not limited to) those that meet any of the following criteria in the determination of Sabin Metal Corporation:

  1. Sending us material originating from, transiting through, or having been transported via a Conflict-Affected or Human Rights Abuse (CAHRA) high risk area.
  2. Sending us material claimed to be from a country known to have limited reserves or production levels of precious metals.
  3. Sending us material from a country where CAHRA areas are known or reasonably suspected to transit.
  4. The party or other known upstream companies are located in a country representing high risk for crime, money laundering or corruption
  5. The party or other known upstream companies or their beneficial owners are Politically Exposed Persons (recognizing that this will often be the case in dealing with state-owned
  6. The party or other known upstream companies are active in a high-risk business activity such as arms manufacturing, gaming and casino operation, dealing in antiquities, or associated with sects, groups or factions known to be involved in criminal or violent activity

Failure to disclose information needed to determine anything in this Responsible Supply Chain due diligence policy, or our other AML/KYC policy or Anti-Bribery and Anti-Corruption Policy may be considered cause to raise a customer or supplier’s risk profile.

Grievance Mechanism: All Sabin Metal Corporation (and it’s subsidiaries’) stakeholders, suppliers, customers, counterparties, employees, and the general public may report – anonymously if desired – concerns about our practices or parties in our supply chain, or any newly identified risk. Such concerns are treated discreetly, strictly confidential and any attempt to identify a whistle-blower who has chosen to raise his concerns anonymously is strictly forbidden. You may send concerns via email to compliance@sabinmetalcorp.com. Or via physical mail (marked confidential) to: Compliance Department, 300 Pantigo Place, Ste 102, East Hampton, NY 11937. You may also report concerns directly to industry groups such as the LBMA or LPPM or via the Responsible Mineral’s Initiative Grievance Mechanism.

 

Responsible Supply Chain Policy

This policy is adapted from the Organisation for Economic Co-operation and Development’s (OECD) “Model Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas.” It has been adapted to reflect Sabin Metal Corporation’s role in the global supply chain as a privately held refiner of precious metals. This policy relates specifically, though not exclusively, to the sourcing and procurement of any and all metal-bearing materials we refine, including materials bearing gold, silver, or any platinum group metals.

Recognizing that risks of significant adverse impacts which may be associated with extracting, trading, handling and exporting minerals from conflict-affected and high-risk areas, and recognizing that we have the responsibility to protect human rights and not contribute to conflict, we voluntarily commit to adopt, to widely disseminate, to incorporate in contracts and agreements with our suppliers, to embed where possible into our standard operating procedures, processes, and systems, and to communicate to and train our employees in regards to, this policy.

As a refiner, we believe this policy represents a common reference for conflict-sensitive sourcing practices and risk awareness from the point of extraction until end user.

We commit to refraining from any action which contributes to the financing of conflict and we commit to comply with relevant United Nations sanctions resolutions, or any applicable domestic laws implementing such resolutions.

Included in the above is a voluntary commitment to conduct due diligence in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, Section 1502, and to take action necessary to prevent sourcing, from regions identified to finance or benefit, directly or indirectly, armed groups in the Democratic Republic of the Congo (DRC) or an adjoining country.

This policy may be revised going forward and supersedes any existing policies regarding the sourcing of material and supply chain responsibility.

Regarding serious abuses associated with the extraction, transport or trade of minerals:

1. While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with or facilitate the commission by any party of:

  1. any forms of torture, cruel, inhuman and degrading treatment;
  2. any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
  3. the worst forms of child labor;
  4. other gross human rights violations and abuses such as widespread sexual violence; war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
  5. war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.

2. We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph 1.

Regarding direct or indirect support to non-state armed groups:

3. We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling or export of materials. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:

  1. illegally control mine sites or otherwise control transportation routes, points where minerals are traded and upstream actors in the supply chain, and/or
  2. illegally tax or extort money or minerals at points of access to mine sites, along transportation routes or at points where minerals are traded; and/or
  3. illegally tax or extort intermediaries, export companies or international traders.

4. We will immediately suspend or discontinue engagement with upstream suppliers where we identify a reasonable risk that they are sourcing from, or linked to, any party providing direct or indirect support to non-state armed groups as defined in paragraph 3.

Regarding public or private security forces: Where we or any company in our supply chain contract public or private security forces, we will require that:

5. Security forces will be engaged in accordance with international standards.

  1. Security forces that are known to have been responsible for gross human rights abuses will not be hired.
  2. Security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders, will not be hired.
  3. Security forces who illegally control mine sites, transportation routes and upstream actors in the supply chain; illegally tax or extort money or minerals at point of access to mine sites, along transportation routes or at points where minerals are traded; or illegally tax or extort intermediaries, export companies or international traders, will not be hired.

6. We recognize that the role of security forces at the mine sites and/or surrounding areas and/or along transportation routes should be solely to maintain the rule of law, including safeguarding human rights, providing security to mine workers, equipment and facilities, and protecting the mine site or transportation routes from interference with legitimate extraction and trade.

7. We will work with central or local authorities, international organizations and NGO’s to improve transparency and accountability in payments to security forces and to minimize exposure of vulnerable groups to adverse impacts associated with the presence of security forces on mine sites.

8. We will devise, adopt and implement a risk management plan with upstream suppliers and other stakeholders to prevent or mitigate the risk of direct or indirect support to public or private security forces where we identify that a reasonable risk of the circumstances described in paragraph 5 exist. In such cases, we will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation within six months from the adoption of the risk management plan. Where we identify a reasonable risk of activities inconsistent with paragraphs 6 and 7, we will respond in the same vein.

Regarding bribery and fraudulent misrepresentation of the origin of minerals:

9. We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of minerals, to misrepresent taxes, fees and royalties paid to governments for the purposes of mineral extraction, trade, handling, transport and export.

Regarding money laundering:

10. We have committed to prohibit and actively prevent money laundering and the funding of terrorist or criminal activities. We have a written anti-money laundering program of compliance and supervisory procedures that complies with domestic law and international guidance, as well as regular staff training and independent third- party audits to maintain the integrity of our anti-money laundering systems and practices.

Regarding the payment of taxes, fees and royalties due to governments:

11. We will ensure that all taxes, fees, and royalties related to mineral extraction, trade and export from conflict-affected and high-risk areas are paid to government and we commit to disclose such payments in accordance with recognized industry best practices.

Regarding risk management of bribery and fraudulent misrepresentation of the origin of minerals, money-laundering and payment of taxes, fees and royalties to governments:

12. We commit to engage with suppliers, central or local governmental authorities, international organisations, civil society and affected third parties, as appropriate, to improve and track performance with a view to preventing or mitigating risks of adverse impacts through measurable steps taken in reasonable timescales. We will suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.