Last Updated: September 6, 2026
Responsible sourcing
A2B GOLD FZCO, trading as A2B GOLD, is committed to responsible sourcing in its purchase, sale and distribution of non-manufactured precious metals. We seek to identify and address the risks associated with the origin, trade and movement of those materials.
We are committed to applying the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including its model supply-chain policy and Gold Supplement. We are also committed to meeting applicable UAE financial-crime, sanctions and other legal requirements.
This policy applies to A2B GOLD personnel involved in sourcing and trading. Our personnel must report sourcing or compliance concerns. We expect suppliers and other business partners to cooperate with our due diligence and uphold the relevant standards when doing business with us.
Responsibilities and supplier checks
A2B GOLD retains responsibility for its sourcing decisions and compliance. Our designated Compliance Officer oversees the assessment and escalation of compliance concerns. Decisions to accept or continue higher-risk relationships require appropriate A2B GOLD approval.
We assess suppliers’ identity, business activities, ownership and control, relevant licences, and the proposed source of the materials. We request documentation appropriate to the relationship and sourcing risks, including information supporting the origin of the gold and the parties involved in its supply chain. Suppliers must provide accurate information and cooperate with requests for clarification or further evidence.
We conduct supplier site visits as part of due diligence before starting a business relationship. Additional checks are applied where risk or applicable requirements call for them, including for conflict-affected and high-risk areas. Our KYC and AML Policy explains the related counterparty, ownership, screening and payment checks.
Standards we expect
We do not tolerate or support:
- Serious human-rights abuses associated with extraction, transport or trade, including torture, forced labour, the worst forms of child labour, war crimes and other grave abuses.
- Direct or indirect support to non-state armed groups through the supply chain.
- Unlawful control, taxation or extortion by public or private security forces at mines, transport routes or trading points.
- Bribery, fraudulent misrepresentation of the origin of materials, money laundering, or evasion of legally due taxes, fees and royalties.
We expect business partners to respect applicable laws, including environmental requirements, and these sourcing standards. Gifts, hospitality and other advantages must comply with our Anti-Bribery Policy.
Responding to sourcing risks
Where a serious compliance or sourcing concern is identified, we pause the affected transaction or business relationship while our Compliance Officer assesses it. We proceed only once the concern has been addressed to satisfy applicable legal and regulatory obligations.
In line with the OECD model policy, we immediately suspend or discontinue engagement with upstream suppliers where there is a reasonable risk of links to serious abuses or support to non-state armed groups.
For other risks, our response may include further verification and a corrective plan with measurable actions. We apply the response and timing appropriate to the risk under the OECD framework and applicable law. Where mitigation fails or is not feasible or acceptable, we suspend or end the relationship. No corrective plan overrides a legal prohibition, freezing requirement or reporting duty.
Review, records and accountability
Our approach includes periodic counterparty review in proportion to risk and further assessment when new information raises concerns. We check incoming payments against the agreed transaction and onboarding information.
We retain relevant due-diligence and transaction records for the periods required by law and cooperate with competent authorities. The retention principles are described in our KYC and AML Policy; personal-data handling is explained in our Privacy Policy.
We are committed to meeting applicable independent-review and public-reporting requirements. We are committed to providing staff compliance training in accordance with applicable legal and regulatory requirements. This policy is reviewed when relevant requirements, activities or risks change.
Raising concerns
Employees, counterparties and other stakeholders may raise sourcing concerns at compliance@a2bgold.com. We handle reports confidentially, subject to disclosures needed to assess and address them or meet legal obligations. We prohibit retaliation against anyone who raises a concern in good faith.