Supply Chain Due Diligence Policy

United Precious Metal Refining, Inc. (“UPMR”) has always been committed to ensuring that our supply chain is free of any gold, silver, platinum or palladium which was gathered for the support or benefit of armed conflict groups or involving serious abuses of human rights. Further, abusive practices from public or private security forces or support to non- state armed groups will not be tolerated. As part of our supply chain due diligence, UPMR shall be watchful for and assess the severity of various risks as recommended in the OECD Guidance Annex II Model Supply Chain Policy.


  • Serious abuses associated with the extraction, transport or trade of minerals:
    • Any forms of torture, cruel, inhuman and degrading treatment
    • Any forms of forced for compulsory labor
    • The worst forms of 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
  • Direct or indirect support to non-state armed groups
  • Direct or indirect support to public or private security forces
  • Bribery and fraudulent misrepresentation of the origin of minerals
    • Money laundering
    • Non-payment of taxes, fees and royalties to governments

UPMR strongly condemns such activity and will refuse any material which we believe was obtained using methods related to serious human rights violations or which benefitted or supported armed rebels or terrorist groups through illegal finance or other activities. This is in accordance with U.N. resolutions and Section 1502 of the Dodd Frank Act. In addition, the OECD (Organization for Economic Cooperation and Development) has released guidelines for due-diligence for sourcing from Conflict-Affected and High-Risk Areas (CAHRAs). We endorse these guidelines and use them as the model for our own due-diligence.

Establish strong management and reporting systems to be in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affect and High-Risk Areas (Annex II). This process will include a system of ongoing customer and transaction due diligence, enhanced due diligence for areas from which material could potentially originate or transit through – known as a Conflict-Affected and high-risk Area (CAHRA) – and strategies for mitigating potential risks that are identified in our supply chain.

In order to ensure our commitment to a “responsibly sourced” and OECD aligned supply chain, UPMR has integrated the following due-diligence protocols for analyzing and assessing our metal suppliers and metal supplies:

UPMR will ensure that training of management and all relevant employees is performed at least annually. UPMR further commits to a review of its supply due diligence process annually for effectiveness and to explore and implement possible improvements to our assessment strategy. A Senior manager and current compliance officer, Michael A. Mikolay, has been assigned the responsibility for ensuring supply chain compliance.

UPMR is also committed to undergo an independent third-party audit to ensure that our documentation, implementation, authentication, and verification processes are accurate and secure. Through these audits, UPMR displays transparency while allowing our customers to obtain audit-based assurance that UPMR’s supply chain due diligence policy is verifiable and effective. It also provides UPMR with third-party feedback opportunities to provide suggestions to the outside auditors for continued improvement. UPMR was originally determined conformant with the Responsible Mineral Initiative’s (RMI) – RMAP Assessment Standard (updated 2017) in September, 2018 and continues to renew our conformant assessment annually.

UPMR communicates this sourcing policy to our suppliers and customers and makes it publicly available for review. Additionally, UPMR requires international customers to acknowledge the policy and commit to providing information, documentation, and accommodations for site visits as necessary to complete our due diligence as outlined in our basic due diligence and enhanced due diligence policies.

If UPMR should discover, through its ongoing due-diligence, that our customer is engaging in suspect practices or activities that do not meet our responsible sourcing requirements, we would immediately suspend sourcing from the identified supplier and develop a plan to mitigate the identified risks. Should the mitigation fail to resolve a matter to our satisfaction, or we uncover activities which indicate extreme abuses, dishonesty, or situations where a supplier is unwilling to assist in our due-diligence, UPMR will immediately disengage any activity with that supplier.

UPMR continues to work with our advisory organizations and agencies to continue to upgrade our practices and improve our processes to ensure materials in our supply chain are “responsibly sourced” and to only obtain materials which are sourced in a legitimate and ethical manner.

Finally, UPMR publishes and makes publicly available an annual summary due diligence report to include the following:

  1. Third Party Assessment Summary
  2. Company Supply Chain Policy
  3. Company Management System
  4. Risk Identification
  5. Risk Mitigation

UPMR is committed to helping our customers/suppliers create and improve their own supply chain due diligence policies. Please contact us should you require guidance or have questions related to Supply Chain Due Diligence.

If you are importing material into the U.S., please read the following information:

As part of the ongoing due diligence process, should UPMR determine that further information is required, we may request supplementary documentation in addition to the import documents presented to U.S. Customs. In those cases, UPMR will request copies of the Export Documents provided to the customer’s local government for review and approval by UPMR in advance of shipment.

Rev. MM, RG 04/14/2023

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