COMPLIANCE

AML & SUPPLY CHAIN GUIDELINES | POLICY DOCUMENT

AML – OVERVIEW
Commodity Group LP (Commodity) is committed in compliance to, and strict practice of

regulatory requirements including those related to Anti Money Laundering under its governing law.

COMMODITY GROUP LP AML POLICY

Commodity has procedural and control measures in place to support the fight against money laundering and the financing of terrorism. We are also committed to examining and maintaining our Anti-Money Laundering procedures and control on an on-going basis.

ESTABLISHMENT OF ULTIMATE OWNERSHIP

Ultimate beneficial ownership of legal entities with whom we transact is established by obtaining and verifying copies of trade licenses, company formation documents, export import licenses, passport copies and any other documents we deem necessary for this purpose.

ENHANCED DUE DILIGENCE

Use of the Escalation system may also be warranted.

INTERNAL REPORTING SYSTEM

In case of a suspicious transaction or suspicious activity, Commodity’s compliance officer is notified as part of our internal reporting system. Where required, we would also inform the Compliance department of our relevant institutional partners. Commodity will undertake or (where appropriate) support in-depth investigation, to be able to take appropriate action before filing a suspicious transactions report.

STAFF TRAINING AND RECRUITING

Before appointment of each employee, Commodity conducts due diligence, asks for references from previous employers or institutions and where Commodity considers appropriate a police report.

Once appointed, each employee is given a basic understanding of AML rules and organisational policies in this regard. All employees are required to and instructed to adhere to the established AML rules in this regard. Periodic and concurrent training is also available within the organization.

RECORD KEEPING

All records including, customer’s identification documents and related data, transaction data, and any other related documents are maintained and retained for a minimum of four years.

RESPONSIBLE SUPPLY CHAIN STATEMENT

OUR STATEMENT

Commodity is committed to the principles of the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplement on Minerals. We work together with applicable bodies to fight against interaction with any entity, governmental or non-governmental bodies that engages in forced labor, child labor, sexual violence, bribery or any elements of misrepresentation of the origin of minerals, taxes, fees and royalties paid to government for mineral processing.

We commit ourselves to uphold the best practices in the industry and adhere to the highest moral and ethical standards in whatever we do. We also comply with our AML policy which is aligned with national and international regulations in this regard.

IMPLEMENTATION OF THE POLICY STATEMENT

• Strict and efficient KYC procedures.
• Clear responsibilities and delegation of authority at all levels.
• Risk assessment system and continuous monitoring of transactions.
• Proper and detailed record keeping and maintenance of records for at least four
  years as well as continuous staff training.

ESCALATION SYSTEM
A self-functioning escalation system is put in place whereby anyone in the supply chain or within the organization can report any irregularities to the management. These irregularities will include but without limitation to money laundering, suspicious transactions that could be related to financing of terrorism or suspicious sourcing of minerals. If needed, such incidents are further escalated to local regulatory authorities.