Supply Chain Due Diligence Policy

United Precious Metal Refining, Inc. (“UPMR”) has always been committed to ensure 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.

Specifically:

  • Serious abuse associated with the extraction, transport or trade of minerals:
    • Any forms of torture, cruel, inhumane and degrading treatment
    • Any forms of forced or 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
    • Non-payment of taxes, fees and royalties to governments
  • Money laundering
    • Precious metals are easy to move, store, and smuggle, and they are highly liquid and anonymous.
    • They can be used to conceal, transfer, or invest in illicit proceeds.
  • Financing of terrorism
    • Precious metals can be used to fund terrorist activities.
  • Illegally control mines, sites, traders or other intermediaries, and transport routes through the supply chains; or
  • Illegally tax or extorting money or minerals through the supply chains.

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.

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

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 in which material could potentially originate from or transit through a Conflict-Affected and high-risk Area (CAHRA), and strategies for mitigating potential risks that are identified in our supply chain. UPMR will ensure that training of management and all relevant employees is done at least annually. UPMR further commits to a review of the supply due diligence process annually for effectiveness and to explore and implement possible improvements to our strategy. A senior manager and current compliance officer, Michael Mikolay, has been assigned responsibility for ensuring supply chain compliance.

UPMR is also committed to be audited by an independent third party to ensure adequate testing of the system to ensure that the verification and documentation process is secure. Through these audits, UPMR displays transparency and our customers gain audit-based assurance that UPMR’s supply chain due diligence policy is verifiable and effective. It also provides UPMR with additional direction for enhancement and opportunities to provide feedback 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 engage in this assessment annually.

UPMR communicates this sourcing policy to our suppliers and customers and makes it publicly available for review. Additionally, UPMR requires the customer 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 discontinue any activity with that supplier.

UPMR continues to work with our advisory organizations and agencies to continue to upgrade our practices to safeguard our supply chain from “conflict affected” materials and to only obtain material which are sourced in a legitimate and ethical manner.

UPMR has implemented requirements for Environmental, Social, and Governance (ESG) factors which include adherence evolving set of regulations, industry standards, and internal company policies. Compliance in this area is not just about avoiding fines; it also addresses stakeholder expectations, enhances reputation, and mitigates long-term risks. Compliance with environmental, health, safety, and labor regulations fall primarily under the Environmental (E) and Social (S) pillars of ESG.

Environmental compliance (E): This pillar focuses on a company’s impact on the natural environment and its efforts to manage and mitigate that impact. Key requirements include:

  • Climate change mitigation
  • Resource efficiency
  • Waste management and pollution
  • Biodiversity and land use

Health, safety, and labor compliance (S): This pillar centers on a company’s relationship with its employees, supply chain partners, and the communities where it operates. Key requirements include:

  • Occupational health and safety
  • Fair labor practices
  • Supply chain due diligence
  • Diversity, equity, and inclusion (DEI)
  • Community engagement

Governance compliance (G): While environmental and social issues are distinct, the governance pillar provides the framework for ensuring compliance across all ESG areas. Key requirements include:

  • Business ethical practices
  • Transparent reporting
  • Executive oversight
  • Navigating compliance in practice

To meet these diverse requirements, UPMR follows a strategic process:

  1. Conduct a materiality assessment: Identify which ESG issues are most relevant to UPMR business and stakeholders to focus efforts effectively.
  2. Benchmark and set goals: Evaluate current ESG performance and set clear, measurable targets for improvement.
  3. Use globally recognized frameworks: Align reporting with established standards like the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), or regional regulations such as the EU’s Corporate Sustainability Reporting Directive (CSRD).
  4. Engage stakeholders: Maintain open communication with investors, customers, and employees to incorporate their feedback and build trust.
  5. Integrate technology: Use software platforms to streamline data collection, analysis, and reporting for greater efficiency and accuracy.
  6. Ensure continuous improvement: Regularly review and update ESG policies and procedures to adapt to evolving regulations and best practices.

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, UPMR 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. It is the responsibility of each customer to ensure material is properly declared to their local government prior to exporting the material. A copy of the export documentation may be shipped with the material or it can be sent in advance to intlrefining@unitedpmr.com.

Record Keeping and Retention of Document:

UPMR maintains a formal record retention policy to assure current and future customers of our desire to be incompliance with market standards as they evolve. The final step for a customer/supplier checklist is to ensure that all documents are stored electronically.

UPMR will maintain and secure due diligence documentation related to our compliance OECD for a minimum period of five years to ensure proof of verification standards as they presently exist. For international shipments, the paperwork is retained for a minimum of seven years as required by Customs Border Patrol (CBP) “Reasonable Care” standards. UPMR secures most records for a period greater than that in a computerized format.

Rev. MM, WM, RG 05/2026

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