COMPLIANCE

Code of Conduct

INTEGRITY:

One of our primary foundational principles is that integrity is essential for long term success. Abiding by this principle, we respect the interest of people associated with us like our employees, clients, suppliers and our society as well. We are committed to identifying and managing/avoiding any conflicts of interest in our business dealings. To make sure we live up to our name, we have policies and processes that avoid any reputational risks. Working along the lines of ethical values and professional standards, we believe in building the trust of all the parties associated with us.

RESPONSIBILITY:

We as a company take complete responsibility for our actions and honour our commitments not only towards our clients but towards our employees and suppliers as well. High-end ethical standards form the base of all our decisions and activities. The core purpose of our business is to identify and provide for our client’s needs in a proficient manner.

CONFIDENTIALITY:

We pride ourselves in maintaining the confidentiality of any information entrusted with us. Be it clients’, suppliers’, or any other individuals’, we do not engage in the disclosure of any information unless explicitly authorized or unless required by law. The privacy of people and companies associated with us is treated with extreme care. Further, it is only the information that is required for us to function efficiently that is acquired and retained by us.

SERVICE AND EXCELLENCE:

We are focused on being a proactive partner and treat our clients fairly and with due integrity. The rule of business is to gain a marginal profit. But for us the foundation of such gain is trust. All our practices are fair and within the boundaries of legal affairs. We practice a practical approach and only promise what we can deliver. We treat the complaints of suppliers/ customers immediately to ensure conformance of our high standards of service and excellence.

COMPLIANCE:

We make sure all our operations are in compliance with the relevant guidelines, policies, manual handbooks and professional practices with respect to our areas of responsibility. We make a diligent effort to implement the prescribed measures and approaches.

Responsibility

ANTI-BRIBERY AND ANTI CORRUPTION POLICY:

  1. Neither gain nor be part of, assist and facilitate any transactions arising from serious abuses such as inhuman and degrading practices, force and child labour, any forms of human rights violations and all forms of criminal activities.
    Immediately discontinue dealing with the suppliers where we identify a reasonable risk that their source are from linked, any party committing serious abuses as defined above.
  2. Not to tolerate any of the locally registered suppliers which directly or indirectly non – state armed groups through transaction such as extraction, transportation, trade, handling or export of minerals which includes or in any other form. It is also applicable to both non-state armed groups and its affiliates or any relation.
  3. Contribute and participate in promotion of Responsible Sourcing of Precious Metals to our suppliers by:
    1. Creating long term business association with the suppliers and strong relationship with the customers.
    2. Supporting our associates (suppliers, customers, employees and other third parties associated with the company on commercial terms) of precious metals to adhere to the provisions of this policy and encourage them to impart and convey the same to its staff and supply chain.
    3. Disseminating the precious metal guidance by local and international bodies which this policy was created as per the guidelines of OCED and LMBA.
  4. Not to offer, promise, give , demand ay bribes and will resist the solicitation of bribe to conceal or disguise the origin of precious metals to misrepresent taxes and royalties paid to Government.
  5. Play a part and contribute in elimination of money laundering and terrorist financing by creating robust management system to act in accordance with the standard of anti- money laundering and contributing Financing Terrorism. The company will take into the account the US rules and regulations.
  6. Ensure that effective Due Diligence on risk based approach is carried before starting any transaction and continuous monitoring to existing clients and suppliers to assess the level of risk and plan to mitigate the risk identified.
  7. Create and keep proper and adequate records of all precious metals transaction and activities that demonstrates the due diligence has been strictly followed.
  8. Train relevant staff and educate its employees, suppliers, clients through formal education, training or seminars and conferences with the provision of this policy and the responsible sourcing of precious metals and other International rules and regulations.

Policy

ANTI-BRIBERY AND ANTI CORRUPTION POLICY

Scope

This policy is applicable to every employee of Orelia Refiners Private Limited (ORPL). The reporting requirement of this Policy is applicable to all Orelia Refiners Private Limited (ORPL) contractors, suppliers, customers, and/or any other concerned individual, company and/or institute.

Purpose

Orelia Refiners Private Limited (ORPL) is committed to conducting business in accordance with all applicable laws, regulations and rules. We believe in abiding by the highest ethical standards, and this commitment is embodied in the Code of Business Conduct and Ethics.

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate our (us, and our officers, directors, employees and agents) full compliance to the U.S. Foreign Corrupt Practices Act (“FCPA”), and any local anti-bribery or anti-corruption laws that may be applicable. This policy supplements the code of business conduct and ethics and all the other applicable laws.

For the purpose of this policy, a “contractor” or a “supplier” is defined as a third-party entity or individual who provides and receives payment for, services or goods related to any aspect of Orelia Refiners Private Limited (ORPL) operations. This head also covers consultants and subcontractors.

A “non-supplier vendor” is defined as a third-party individual, company, organization, and/or government or government-related entity that will receive payment from Orelia Refiners Private Limited (ORPL) but will not provide goods or services in return of such compensation.

Definition

Corruption is the misuse of public power for private profit or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or any other inducement of any kind offered to a person in a position of trust/power. Such an offer is made to influence that person’s views or conduct to obtain an improper advantage of his/her stature. Bribery and corruption can take many forms, including the provision or acceptance of:

Cash payments

  • Phony jobs or “consulting” relationships;
  • Kickbacks;
  • Political contributions;
  • Charitable contributions;
  • Social benefits; or
  • Gifts, travel, hospitality, and reimbursement of expenses.

Policy requirements

Orelia Refiners Private Limited (ORPL) personnel and agents are strictly prohibited from offering, paying, promising, or authorizing any payment or anything else of value to any person directly or indirectly through or to a third party for the purpose of (i.e., in exchange for) making the person act (or fail to act) in violation of a legal duty, making the person to abuse or misuse their position, or securing an improper advantage, contract or concession for Orelia Refiners Private Limited (ORPL) or any other party.

Onboarding Forms

Documents Required: Commercialization and Refinery

A. Company Registration Documents: –

  • Articles of Association (Notarized)
  • Certificate of Good Standing
  • Certificate of Incorporation
  • List of Authorized Signatories & Beneficial Owners
  • Tax Registry
  • Commerce Registry/ Business Register Extract

B. Valid License, Certifications, Reports, Policy and Procedures: –

  • Export & Import License
  • Mining License or Trading License for Precious Metals
  • Latest Financial & Independent Audit Reports
  • Counterparty’s Policies and Procedure ( Specially AML/CFT Policy and Responsible Gold Supply/ Purchase Policy).

C. Owner’s or Shareholder’s Identification:

  • Copies of the beneficial owner or shareholders’ composition of the company.
    [Clear and Coloured Passport & Visa Page Copies]
  • Copies of Directors of the company including Board Members
    [Clear and Coloured Passport & Visa Page Copies]

D. Bank Account Details:

  • Bank Account Numbers
  • Bank Reference Letters