1.1. UAB Florinus (hereinafter – the Company), as an importer of precious metals, is involved in the supply of precious metals to natural and legal persons (jewelry workshops, investment and asset funds, banks, and other organizations engaged in investment and capital protection).
1.2. This Precious Metals Supply Chain Policy (hereinafter – the Policy) has been prepared in accordance with Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017, which lays down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores, and gold originating from conflict-affected and high-risk areas (hereinafter – the Regulation); Commission Recommendation (EU) 2018/1149 of 10 August 2018 on non-binding guidelines for the identification of conflict-affected and high-risk areas and other supply chain risks under Regulation (EU) 2017/821 (hereinafter – the Guidelines), and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (hereinafter – OECD Guidance).
2.1. The following terms are used in this Policy:
2.1.1. OECD Due Diligence Guidance – OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (second edition, OECD, 2013), including all annexes and supplements;
2.1.2. Downstream – the metal supply chain from after smelters and refiners to the final product;
2.1.3. Supply chain due diligence – obligations of Union importers of tin, tantalum, tungsten, their ores, and gold related to their management systems, risk management, independent third-party audits, and disclosure of information, aimed at identifying and addressing actual and potential risks related to conflict-affected and high-risk areas, in order to prevent or mitigate adverse impacts;
2.1.4. Conflict-affected and high-risk areas – areas in a state of armed conflict or fragile post-conflict conditions, as well as areas with weak or non-existent governance and security, such as failed states, and where international law, including human rights violations, is widely and systematically breached;
2.1.5. Model supply chain policy – a supply chain policy consistent with Annex II of the OECD Guidance, defining risks of significant adverse impacts associated with mineral extraction, trade, handling, and export from conflict-affected and high-risk areas;
2.1.6. Upstream – the mineral supply chain from extraction sites to smelters and refiners inclusive;
2.1.7. Refiner – an entity (including a natural person) that refines gold to marketable quality by removing other materials from semi-processed gold alloys, alluvial gold, recyclable gold, scrap gold, or other raw materials containing gold;
2.1.8. Union importer – any natural or legal person declaring minerals or metals for release for free circulation as defined in Article 201 of Regulation (EU) No 952/2013 of the European Parliament and of the Council, or any person on whose behalf such declaration is made as indicated in data elements 3/15 and 3/16 of Annex B of Commission Delegated Regulation (EU) 2015/2446;
2.1.9. Suppliers – any person or organization considered part of the supply chain of gold and gold-containing materials;
2.1.10. Supply chain – a system including all activities, organizations, entities, technologies, information, resources, and services involved in moving gold from its origin to end consumers.
3.1. This Policy applies to all business partners of the Company involved in the extraction, refining, and production of precious metals. The Company’s supply chain due diligence system ensures that all sourced precious metals originate from legitimate, ethical sources and are not associated with criminal activities, armed conflicts, or human rights violations.
3.2. This Policy does not apply to diamond supply, as a separate policy has been established for diamonds.
3.3. This Policy is consistent with Annex II of the OECD Guidance, which defines risks of significant adverse impacts related to mineral extraction, trade, handling, and export from conflict-affected and high-risk areas.
3.4. The Company conducts its activities in accordance with the highest standards of ethics, morality, and social responsibility. The Company actively monitors and mitigates all significant and potential risks throughout the entire precious metals supply chain – from mine to refinery and from refinery to product distribution.
4.1. When determining whether it purchases or may purchase gold from conflict-affected and high-risk areas, the Company undertakes to implement the first step (establish strong company management systems) and the second step (identify and assess risk in the supply chain). The remaining steps will only be implemented if gold is sourced from such areas and risks are identified.
Step 1. Establish strong company management systems
4.2. The Company’s Head of Supply and Logistics is responsible for monitoring high-risk supply chains and business relationships and reports at least annually to the Commercial Director.
4.3. The Head of Supply and Logistics ensures periodic updates of supplier documentation (at least annually).
4.4. The Company’s Director is responsible for ensuring proper communication and dissemination of this Policy.
4.5. Responsible persons maintain gold inventory records, including origin and receipt data.
4.6. The Company requires suppliers to disclose refinery identity when requested.
4.7. The Company provides traceability information when required.
Step 2. Identify and assess risk in the supply chain
4.8. The Company identifies risks related to sourcing gold from conflict areas.
4.9. The Company identifies refiners in its supply chain.
4.10. If identified, the Company gathers due diligence data on refiners.
4.11. If not identified, the Company strengthens transparency, develops risk plans, and monitors mitigation.
Step 3. Design and implement a strategy to respond to identified risks
4.12. The Company reports risks, strengthens supplier cooperation, and implements mitigation plans.
Step 4. Independent third-party audit
4.13. The Company supports independent audits of refiners.
Step 5. Annual reporting
4.14. The Company publicly reports due diligence efforts.
4.15. Annual reports include due diligence disclosures.
5.1. The Company commits to responsible sourcing, respect for human rights, and non-contribution to conflicts.
5.1. The Company, recognizing the risk of significant adverse impacts associated with the extraction, trade, handling, and export of minerals from conflict-affected and high-risk areas, and recognizing its responsibility to respect human rights and not contribute to conflicts, undertakes to adopt, widely disseminate, and incorporate into agreements and/or contracts with suppliers this policy on responsible sourcing of minerals from conflict-affected and high-risk areas as a common reference for such sourcing practices, and to raise supplier awareness of risks from the point of mineral extraction to the end user. The Company commits not to take any actions that would contribute to the financing of conflicts and to comply with relevant United Nations sanctions resolutions or, where applicable, national laws implementing such resolutions.
Regarding serious abuses associated with the extraction, transport, or trade of minerals
5.2. The Company will not tolerate, will not profit from, will not contribute to, will not assist with, and will not facilitate any of the following acts carried out by any parties:
5.2.1. any forms of torture, cruel, inhuman, and degrading treatment;
5.2.2. any forms of forced or compulsory labor, which means work or service exacted from any person under the threat of penalty and for which that person has not offered themselves voluntarily;
5.2.3. the worst forms of child labor;
5.2.4. other gross human rights violations and abuses, such as widespread sexual violence;
5.2.5. war crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.
Regarding risk management of serious abuses
5.3. The Company undertakes to immediately suspend or discontinue engagement with upstream suppliers where there is a reasonable risk that they are sourcing from, or are linked to, any party committing the serious abuses defined in section 5.2.
Regarding direct or indirect support to non-state armed groups
5.4. The Company commits not to tolerate any direct or indirect support to non-state armed groups associated with the extraction, transport, trade, handling, or export of minerals. “Direct or indirect support” to non-state armed groups includes, but is not limited to, purchasing minerals from them, making payments to them, or otherwise providing logistical assistance or equipment to non-state armed groups or their affiliates who:
5.4.1. illegally control mine sites or otherwise control transportation routes, mineral trading points, and upstream actors in the supply chain, and/or
5.4.2. illegally tax or extort money or minerals at mine sites, along transportation routes, or at mineral trading points, and/or
5.4.3. illegally tax or extort intermediaries, export companies, or international traders.
Regarding risk management of direct or indirect support to non-state armed groups
5.5. The Company undertakes to immediately suspend or discontinue engagement with upstream suppliers where there is a reasonable risk that they are sourcing from or are linked to any party providing direct or indirect support to non-state armed groups as defined in section 5.4.
Regarding public or private security forces
5.6. The Company agrees to eliminate direct or indirect support to public or private security forces that illegally control mine sites, transportation routes, and upstream supply chain actors, illegally tax or extort money or minerals, or extort intermediaries, export companies, or international traders.
5.7. The Company recognizes that the role of public or private security forces at mine sites and along transport routes should be limited to maintaining the rule of law, including protecting human rights, ensuring the safety of workers, equipment, and infrastructure, and securing mining sites or transport routes without interfering with legitimate mining and trade.
5.8. Where the Company or any entity in its supply chain contracts public or private security forces, the Company commits to ensure that such forces operate in accordance with the Voluntary Principles on Security and Human Rights. The Company also supports screening policies to prevent hiring individuals or units known for human rights abuses.
5.9. The Company commits to support efforts or take steps to cooperate with central or local authorities, international organizations, and civil society organizations to contribute to solutions that improve transparency, proportionality, and accountability in payments made to public security forces.
5.10. The Company also commits to support efforts or take steps to cooperate with local authorities, international organizations, and civil society organizations to avoid or minimize negative impacts on vulnerable groups, especially artisanal miners, associated with the presence of security forces.
Regarding risk management of security forces
5.11. Depending on its position in the supply chain, the Company commits to develop, adopt, and implement a risk management plan in cooperation with upstream suppliers and stakeholders to prevent or mitigate risks related to security forces. If mitigation efforts fail within six months, the Company will suspend or terminate engagement with upstream suppliers. The Company will also respond where risks related to sections 5.9 and 5.10 are identified.
Regarding bribery and fraudulent misrepresentation of mineral origin
5.12. The Company undertakes not to offer, promise, give, or demand any bribes and to resist solicitation of bribes to conceal or disguise the origin of minerals or to misrepresent taxes, fees, and royalties paid to authorities.
Regarding money laundering
5.13. The Company commits to support efforts or take steps to contribute to the effective elimination of money laundering risks related to mineral extraction, trade, transport, and export.
Regarding payment of taxes, fees, and royalties
5.14. The Company commits to ensure that all legally required taxes, fees, and royalties are paid to governments and to disclose such payments in accordance with Extractive Industries Transparency Initiative (EITI) principles.
Regarding risk management of bribery, money laundering, and payments
5.15. The Company commits to cooperate with suppliers, authorities, international organizations, and civil society to improve and monitor risk mitigation. If mitigation fails, the Company will terminate relationships with upstream suppliers.
6.1. Procedures ensure metals are not linked to human rights abuses or conflict financing.
6.2. The Company maintains a list of prohibited countries (e.g., Russia, Iran, North Korea, etc.).
6.3. Supplier due diligence is conducted before contracting.
7.1. This Policy enters into force upon approval and remains valid until amended.
7.2. It is reviewed at least annually and updated when necessary.
