(DELTALUM)

DELTA LUMINEUX LTD

Precious Metals Supply Chain Policy
 PRECIOUS METALS SUPPLY CHAIN POLICY

I. POLICY STATEMENT

DELTALUM conducts its business with high ethical, moral and social responsibility standards. High
integrity, honesty and transparency are the foundations on which our business is built and we
require from our employees involved in the precious metals supply chain to comply with our gold
supply chain policy and implement it thoroughly, through the appropriate management system in
place. Our Precious Metals Supply Chain Policy is implemented through a comprehensive
management system that encompasses strict risk-based due diligence approach. DELTALUM risk
management system policy has been designed and implemented to ensure that our commitments
and operating procedures are rigorously in line with the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict Affected and High-Risk Areas and accompanying
Gold Supplement, the LBMA Responsible Gold Guidance, for Risk-Based Due Diligence in the Gold
and Precious Metals Supply Chain, and the our Anti-Money Laundering and Combating the Financing
of Terrorism (AML/CFT) Policy and Process.

DELTALUM, by applying its Precious Metals Supply Chain Policy, participates and cooperates in
global effort to combat money laundering, terrorism financing, armed conflict, and human rights
abuses. DELTALUM condemns formally any human rights abuse and any child right abuse and expect
from all actors in the supply chain to be in line with these fundamentals. Our policy prohibits any
employee from offering or receiving of a bribe. In addition, DELTALUM requires from all partners in
the supply chain, a clear, transparent and full compliance with local and international regulations, to
ensure that our precious metals sourcing is legitimate, conflict-free, ethical and socially responsible.
An on-going training program is performed on a regular basis in order to bring all counterparties and
all relevant employees up to date on standards and due diligence, know-your-customer (KYC) best
practices.

II. SCOPE

This Precious Metals Supply Chain Policy applies to all precious metals handled by DELTALUM and to
all of its business partners engaged in the trade of precious metals. DELTALUM shall conduct
precious metals transactions foreign exchange brokers, gold exporters and traders, mining
companies, coin dealers, recovery companies, gold funds, private and institutional investors and
commercial banks, referred to this policy as “Counterparties”, who comply with DELTALUM Precious
Metals Supply Chain Policy, OECD Guidelines and the LBMA Responsible Gold Guidance.

III. RESPONSIBLE SOURCING

As part of our responsibility, DELTALUM fully commits to:

1. Neither tolerate, nor by any means profit from, contribute to, assist with or facilitate the
commission by any party of serious abuses associated with the extraction, transport, trade,
handling or export of minerals as indicated in Annex II of the OECD Guideline, any
transactions arising from:

(i) Any form of torture, cruel, inhuman and degrading treatment;

(ii) Any form of forced or compulsory labour;

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(iii) The worst forms of child labour;

(iv) Other gross human violations and abuses such as widespread sexual violence;
and/or

(v) War crimes or other serious violations of international humanitarian law, crimes
against humanity, or genocide.

(vi) To bride or to be bribed.

2. Not to enter into any business relationship, or immediately suspend or discontinue

engagement with Counterparties supplying precious metals where we identify a reasonable
risk that they are sourcing from, or are linked to, any party committing serious abuses as
defined above. DELTALUM’s intention is also to engage the Counterparty to ascertain the
circumstances of identified risks and violations, how the Counterparty has handled these
(through mitigation and remedy actions), and how the Counterparty introduces reasonable
control measures to prevent and better mitigate such risks in the future.

3. Not to tolerate any direct or indirect support to non-state armed groups through the
extraction, transport, trade, handling or export of precious metals. This includes, but is not
limited to, procuring minerals from, making payment to or otherwise providing logistical
assistance or equipment to non-state armed groups or their affiliates who:

(i) illegally control mine sites or otherwise control transportation routes, points where
minerals are traded and upstream actors in the supply chain; and/or

(ii) illegally tax or extort money or minerals at points of access to mine sites, along
transportation routes, or at point where minerals are traded; and/or

(iii) illegally tax or extort from intermediaries, export companies or international traders.

4. Not to enter into any business relationship, or immediately suspend or discontinue

engagement with upstream suppliers, where we identify 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 above.

5. Eliminate, in accordance with paragraph 10 of Annex II of the OECD Guidance, direct or

indirect support to public or private security forces who illegally control mine sites,
transportation routes and upstream actors in the supply chain; illegally tax or extort money
or minerals at points of access to mine sites, along transportation routes, or at point where
minerals are traded; or illegally tax or extort from intermediaries, export companies or
international traders.

6. Recognize that the role of public or public security forces at the mine sites and/or
surrounding areas and/or along transportation routes should be solely to maintain the rule
of law, including safeguarding human rights, providing security to mine workers, equipment
and facilities, and protecting the mine site or transportation routes from interference with
legitimate extraction and trade.

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7. Support efforts, or take steps, to engage with central or local authorities, international
organizations and civil society organizations to contribute to workable solutions on how
transparency, proportionality and accountability in payments made to public security forces
for the provision of security could be improved.

8. Not to enter into any business relationship immediately suspend or discontinue engagement
with any upstream participant/s should we identify a reasonable risk that the supply chain
directly or indirectly supports illegally acting public or private security forces.

9. Not offer, promise, give, or demand any bribes, and resist the solicitation of bribes to
conceal or disguise the origin of precious metals, to misinterpret taxes, fees and royalties
paid to governments for the purposes of extraction, trade, handling, transport and export.

10. Support efforts, and/or take steps, to contribute to the effective elimination of money
laundering as well as terrorism financing where we identify a reasonable risk of such illegal
practices resulting from, or connected to, the extraction, transport, trade, handling or export
of precious metals at points of access to mine sites, along transportation routes or at points
where precious metals are traded by upstream participants in the supply chain. In this
regard, we will immediately report to the relevant authorities any suspicion of any illegal
financial transactions we identify.

11. Contribute and participate in the promotion of Responsible Sourcing of Precious Metals to
our suppliers by (i) creating a long term association with suppliers and established strong
relationship with our customers; (ii) supporting our suppliers of gold to adhere with the
provision of this policy and encourage them to impart or convey it to its staff and their
supply chain; (iii) disseminating the precious metal gold guidance by local and international
bodies in which this policy was created such as the LBMA and OECD.

12. Systematically perform enhanced due diligence practices, including the Know-Your-
Customer (KYC) process, following a risk-based approach, before entering a business
relationship with any precious metals supplying counterparties. Conduct, utilizing a risk-
based approach, appropriate scrutiny and monitoring of (i) the transactions undertaken
through the course of the relationship; and (ii) the governance structures in place to prevent
any risk of illegal activities. Implement a management strategy to respond to identified risks.

13. Adequately store and maintain all records and documentation relating to the precious
metals supply chain in order to demonstrate appropriate and on-going due diligence has
been performed. Storage of such information should be for a minimum of 5 years or as
directed by applicable local laws, whichever is longest.

14. Train relevant staff and educate its employees through formal education, trainings or
seminars and conferences with the provision of this policy and the responsible sourcing of
precious metals. DELTALUM requires all its staff involved in the gold supply chain to strictly
comply with this policy and implement it in the management system.

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15. Require our Counterparties and, in particular, all Counterparties supplying precious metals,
to mutually cooperate by committing to, and acknowledging in writing, compliance with a
supply chain policy consistent with OECD Due Diligence Guidelines.

IV. COMPLIANCE UNDERTAKING

I hereby acknowledge that we have read and fully understood DELTALUM’s Precious Metals Supply
Chain Policy and we agree to comply with its provisions at all times during the business transactions
and relations with DELTALUM.

COMPANY NAME :

AUTHORIZED REPRESENTATIVE :

DESIGNATION :

DATE : Friday, 23 July 2021

SIGNATURE & CORPORATE SEAL

- END OF PRECIOUS METALS SUPPLY CHAIN POLICY -