RESPONSIBLE SOURCING

DELTALUM has international customers from various parts of the world and suppliers from different
countries as well, so the origins of its goods are quite diverse. To protect the operation of DELTALUM against
any breaches of national and international law or involvement in money laundering or terrorist financing,
DELTALUM relentlessly pursues a strict adherence and acceptance policy with respect to both its customers
and suppliers.

DELTALUM has adopted a Precious Metals Supply Chain Policy to ensure the highest standards regarding
sourcing of gold and other precious metals from conflict and high-risk areas and has implemented a robust
due diligence framework based on the risk assessment and guidelines set out in the LBMA Responsible Gold
Guidance, OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas and relies on the expertise of its dedicated law firm partner and collaborator, LCMB & Associates
based in Paris, to undergo extensive care and due diligence on both its clients/buyers and suppliers/sellers
for the first-rate functioning of its process and its transactions by extension.

AML/CFT AND KYC POLICY

In compliance with the Anti-Money Laundering and Combating the Financing of Terrorism Policy and
Process and to assist in the implementation of all relevant domestic as well as international laws and best
practices, DELTALUM shall apply the following principles:

i. Know-Your-Customer (KYC) – DELTALUM maintains a clear customer acceptance policies and procedures,
including a description of the types of customers that are likely to pose a higher risk than the average risk.
Before accepting a potential customer, KYC and due diligence procedures are followed. Reasonable steps
are also undertaken by DELTALUM to ensure that KYC information and documents are duly and diligently
updated as and when required.
ii. Compliance with laws – DELTALUM shall ensure that its business is conducted in conformity with high
ethical standards, that laws and regulations are scrupulously adhered to and that service is not provided
where there is a reasonable ground to believe that transactions are associated with money-laundering and
illegal activities.
iii. Cooperation with law enforcement agencies – Within the legal constraints relating to customer
confidentiality, DELTALUM is duty-bound to cooperate fully with the law enforcement agencies in taking
appropriate measures allowed by law if there are reasonable grounds for suspecting money laundering and
will immediately report the case to the relevant authorities dealing with Anti-Money Laundering cases.
iv. Policies, procedures, and training – DELTALUM has adopted and implemented policies consistent with the
principles set out in its internal AML-CFT and KYC Compliance Manual, and ensure that its staff, wherever
located, are informed of these policies and adequately trained in matters covered therein.
ANTI-BRIBERY POLICY
DELTALUM strictly prohibits any form of bribery and corruption within the company, as well as with its
business partners, service providers, customers as well as governmental agencies, parastatal bodies, non-
governmental organisations and international institutions. In line with DELTALUM’s principles of honesty,
integrity, and transparency in conducting its business, DELTALUM has adopted and implemented an Anti-
Bribery and Anti-Corruption Policy.

DELTALUM takes a zero-tolerance approach to bribery and corruption and is very committed to acting
professionally, fairly and with integrity in all its business dealings and relationships whenever and wherever
it operates. It is our best practice objectives that those whom we do business with take a similar zero-
tolerance approach to bribery and corruption at all times.

For questions and/or concerns related to DELTALUM Precious Metals Supply Chain Policy, DELTALUM
AML/CFT and KYC Policy and DELTALUM Anti-Bribery and Anti-Corruption Policy, or any other document in
relation to the subject matter, please email us at deltalum@pm.me or contact our dedicated law firm for
further information on contact@lcmb-avocats.com

Best Regards,

PATRICE LE BON
Acting as Chief Executive Director for Delta Lumineux Ltd (DELTALUM)