igr metals trading dmcc · world gold council conflict-free gold standard, 01 october 2012 scope...

ISTANBUL GOLD REFINERY / IGR GLOBAL COMPLIANCE DIRECTIVE

REFERENCES:

Istanbul Gold Refinery (IGR) Co. Intercorporate regulations and instructions

LBMA Good Delivery Rules for Gold Bars, October 2012

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-affected and High Risk Areas, Second Edition November 2012

OECD Due Diligence Guidance Gold Supplement, 17 July 2012

World Gold Council Conflict-Free Gold Standard, 01 October 2012

SCOPE AND EXECUTIVES:

This document concerns all companies, units, business and business partners of Istanbul Gold

Refinery / IGR Global involved in the business of gold and gold containing valuable metals. It does

not include business or business partners not involved with gold refinement.

MANNER OF IMPLEMENTATION:

Istanbul Gold Refinery / IGR Global Compliance Directive shall become effective on the date of its

publication. Potential changes to it shall be issued by the Compliance Officer indicating revision

number. Unit officers/managers are responsible for ensuring full understanding of the principles and

application of this directive by all personnel, for establishment of their own internal communication

systems, to facilitate an operational style to meet the requirements of unit internal conformance

systems, and from application of unit internal instructions and directives.

Corporate Compliance Officer has the primary responsibility for Compliance Process and Due

Diligence activities and stages toward the Istanbul Gold Refinery / IGR Global Board of Management,

our clients, accrediting organizations and other 3rd parties. Compliance Officer reports the

activities to the Top Management and to the Chairman of the Board.

1. GENERAL PRINCIPLES:

Compliance; concerns gold refinement and is put into effect by Istanbul Gold Refinery / IGR Global in

consideration of the scope of activities and implementations meeting the requirements of accrediting

institutions and organizations, national and international regulations and standards. In Istanbul Gold

Refinery / IGR Global Compliance constitutes the common point for the work undertaken within the

scope of gold refinement, and related practices.

IGR DUE DILIGENCE GUIDANCE FOR RESPONSIBLE SUPPLY CHAIN OF MINERALS ©IGR Metals Trading DMCC, All Rights Reserved. Page 01

IGR Metals Trading DMCC

The fact that we are a credible trademark in the world market is related with our certifications by

respectable institutions such as London Bullion Market Association (LBMA); our place in the Good

Delivery List of London Bullion Market Association (LBMA); our product quality in consistence with

accredited standards;

and that we internalize and implement the requirements of Compliance Principles and Due Diligence

Our whole commercial affairs with our customers are run based on the compliance principles.

Implementing all the related national and international legal regulations and instructions, as well as

the rules and instructions by respectable institutions of the sector such as London Bullion Market

Association (LBMA); so as to establish all of our commercial relationships on those basic principles,

sharing them in the beginning with our customers; and training all of our employees and raising

awareness among them within the scope of those principles; are the basic principle of our Company

Gold Supply Chain Responsibility Policy.

Istanbul Gold Refinery / IGR Global personnel, shall never make purchase, refinery, and sales of gold

and gold containing valuable metal outside the below specified principles; and shall not risk the

refinery’s /company’s credibility for their own interests. In the first place the Chairman of the Board,

Compliance Committee and all the department managers of the refinery are responsible for

implementing and having implemented above specified principles. If during the process, any Istanbul

Gold Refinery / IGR Global personnel including laborers, face any non-compliance which they

consider to be a risk within the scope of the principles of Gold Supply Chain Responsibility Policy,

they have the self-confidence to inform the management about the situation. Commercial relations

with our customers shall also be formed with this awareness.

2. MAIN PRINCIPLES:

Istanbul Gold Refinery / IGR Global Compliance Directive; is in the nature of a guiding directive for

the necessary practices so as to ensure that the tasks with a continuous applicability and required to

be performed by all departments and employees of the refinery /company within the scope of

London Bullion Market Association (LBMA) compliance process and sustainability, and each step

required to be taken within the scope of Compliance Process Due Diligence work are consistent with

accreditation principles we committed to, and in compliance with market rules and international

validity standards; and to provide that all the transactions and applications in the process are run

according to the principles we are subject to. This instruction also constitutes the basis of Gold

Supply Chain Responsibility Policy document. Gold Supply Chain Responsibility Policy shall be

prepared by Compliance Officer and be published following the approval of Board, and policy

updates shall be followed.

3. APPLICABILITY AND RISK MANAGEMENT

With the objective of enabling compliance of the existing system and its applications to this process,

ensuring continuity of accreditation principles and to meet the Good Delivery List requirements of

London Bullion Market Association(LBMA); and providing compliance of present system and

practices of the refinery with this process; and in order to establish and provide functionality of a

particular Refinery / Company Compliance System which meets the minimum requirements of

London Bullion Market Association (LBMA), Istanbul Gold Refinery Inc. / IGR Global Inc. is under

the commitment to:



a. Establish a strong corporate management system,

b. Identify and assess the risks in the gold supply chain,

c. Design and implement a management strategy to alleviate the risks identified,

d. Appoint an independent auditor for gold supply chain Due Diligence,

e. Report the results.

This is the focal point in the work and efforts of Corporate Compliance Officer, Unit Compliance

Officers and Compliance Committee.

Within the entire process, everything which will contribute to:

Armed conflict,

Growing of violence,

Violation of human rights,

Money laundering,

Financing of Terrorists

are considered to be high risk, customer with high risk, or transactions with high risk.

The motto “Choose honesty without hesitation when you have to choose between honesty and

interest “ ,which has been defined with this intention, is our main principle. Acting outside this

principle and generating simple solutions will damage our commercial credit; and will require too

much time and effort for the reinstallment of the trust and respectability of our refinery/company.

All the managers and the workers at Istanbul Gold Refinery / IGR Global shall be in the awareness of

that.

With this objective, Istanbul Gold Refinery / IGR Global shall put into effect the Gold Supply Chain

Policy, maintain its currency, and through sharing, achieve a common collective consciousness

among all company personnel, clients, business partners and other concerned 3rd persons.

Gold Supply Chain Risk Management Plan and Risk Analysis shall be undertaken by the Corporate

Compliance Officer, and shall be published upon approval by the Chairman of the Board.

Related Departments of Istanbul Gold Refinery / IGR Global shall implement all the rules of London

Bullion Market Association (LBMA)’s Good Delivery List, and shall run all the refining and fixing

operations within the scope of those principles.



4. COMPANY COMPLIANCE SYSTEM ORGANIZATION:

A Compliance Officer has been appointed by the Chairman of Management Board at Istanbul Gold

Refinery / IGR Global Corporate Compliance Officer works in coordination with all managers and

units, and while reporting operation, observation and inspection results to the concerned unit

managers for corrective action, also informs the Management Board Chairman. Depending on the

level, confidentiality and character of matter requiring correction, when necessary reports directly

to the Chairman. Corporate Compliance Officer conducts all monitoring and applications of

statutes related to compliance.

At the same time, corporate Compliance Officer is also the Chief Compliance Trainer. The

Corporate Organizational Structure chart which also incorporates the Compliance Officer is

provided in Appendix-A and Compliance Officer Operation instructions are given in Appendix-B.

A Corporate Compliance Committee has been formed to operate under the supervision of Board

of Management. Compliance Committee Organization Chart is presented in Appendix-C and the

Compliance Committee operation instructions are presented in Appendix-D.

A Non-Compliance Notification System has been installed as a communication mechanism

enabling the reporting to the Top Management of any kind of non-compliance, which has been

evaluated during the process as a risk within the scope of the Gold Supply Chain Refinery Policy

principles; and to that end, Compliance Access Points have been formed. Functioning of

Non-Compliance Notification System and Compliance Access Point utilization instructions are

given in Appendix- E. Non-compliance Notification Form and the refinery Compliance Officer,

Departmental compliance officers, Compliance Committee, Compliance- access point relation are

given in Appendix-F and Appendix-G respectively.

Unit officers/managers and department Compliance officers are responsible for providing

compliance in their departments. They are in direct communication with the Corporate

Compliance Officer during their operations. Unit Officer/Unit Manager operation

instructions and Unit Compliance Officer Operation instructions are given in Appendix-H and in

Appendix-I respectively.

In order to inform all the employees in the company including managers and workers

about Compliance Process and Due Diligence; to update their available knowledge; and to build a

common consciousness; Corporate Supply Chain Compliance Training Instructions shall be prepared

by the Compliance Officer; and internal Supply Chain Compliance Trainings shall be planned and put

into practice.

In order to raise the same consciousness among the customers regarding the Compliance and DueDiligence; and to implement a common understanding, a Good Will/Compliance Settlement shall bemade; and regarding the process management, the customers shall be supported through regularand periodical visits to the customers.



In order to evidence that activities are conducted as per requirements of Due Diligence, and

regulations, instructions, directives are complied with at each stage of process, all records and

documents relating to gold supply chain are archived at least for 5 years in classic manner and in

preserved in a database environment, and the corporate Archive Directive is revised accordingly.

Within the scope of Know Your Customer System, Customer Files shall be prepared by the related

units in Istanbul Gold Refinery / IGR Global and their content shall always be kept update. A reference

and lot system which are consistent with each other, shall be installed to enable the transparency and

in a systematic structure functionality of all the transactions, registers, input and outputs of Gold and

Gold containing precious metals within the process of Gold Supply Chain; and measures shall be taken

to provide that all the commercial transactions are run within the scope of requests by accredited

institutions.

Following the closing of fiscal year, a Corporate Annual Report shall be prepared and be distributed

to the appropriate points by the Accounting and Finance Unit. Company shall submit the Compliance

process and Due Diligence systems together with their records to the annual auditing; and shall share

the auditing results with both its staff and third parties in related platforms. To that end, an annual

Auditing Contract shall be made by the Compliance Committee according to the provisions of the

London Bullion Market Association (LBMA) Audit Guidance. In that context, an Internal Audit Plan

and Corrective Action Plan shall be prepared; and their implementations shall be monitored. Papers

and documents to be submitted to the Auditing Unit by the related units, shall be made ready at a

time sufficiently prior to end of that fiscal year. Control and coordination, as well as the reporting

required at the end of the auditing shall be performed by corporate Compliance Officer.

London Bullion Market Association (LBMA) corporate Compliance Process Analysis chart, which

summarizes the whole process and lists the operations, is presented in Appendix-J.

5. RESPONSIBILITY

Every unit and all employed personnel engaged in gold and gold containing metal business within

Istanbul Gold Refinery Inc. / IGR Global Inc. are responsible for meeting the requirements of

Compliance Directive as well as those of the Gold Supply Chain Responsibility Policy, to inform any

problems or shortcomings within the shortest period, and to carry out appropriate corrective actions.

Istanbul Gold Refinery / IGR Global

7 No’lu Fabrika Kuyumcukent Sitesi 34197 Yenibosna/Istanbul

P: +90 212 603 01 01 F: +90 212 603 01 10



Appendix-A

COMPLIANCE OFFICER OPERATIONAL DIRECTIVE:

1. Corporate Compliance Officer shall be appointed by Chairman of the Management Board.

Operations and activities shall be reported to the Upper Management and to the Chairman.

2. Appointment shall be notified to the accrediting organizations and necessary 3rd persons.

3. Compliance Officer shall monitor all national and international statutes concerning the field

of activity. Within this framework, prepares all corporate instructions and implementations,

ensures follow-up and control.

4. Prepares the corporate Gold Supply Chain Responsibility Policy document and ensures its

currency.

5. Conducts corporate Due Diligence activities.

6. Guides and directs the Due Diligence efforts of Corporate Units.

7. Conducts the Due Diligence Risk Analysis. Establishes the Risk Management Plan.

8. Reports activities to the Upper Management and Chairman of the Management Board.

9. Represents the Corporation by participating in accreditation organization collaboration.

10. Chairs the Compliance Committee, reports results to the Chairman of Management Board.

11. Presents high risk clients to the approval of Chairman, Management Board.

12. Monitors non-compliance notification system, reevaluates non-compliance notifications,

processes, and when required issues timely calls for Compliance Committee meeting with

appropriate representation.

13. Conducts periodic compliance inspections and reports results to the relevant managers and

Chairman, Management Board.

14. Prepares a Corrective Action Plan and implements it when required.

15. Functions as Compliance Chief Trainer. Plans corporate in-training and applies such plans.

16. Trains Unit Compliance Officers, monitors their activities.

17. Establishes a relevant unit archiving system.

18. Conducts the relationship with auditing firm.

19. Conducts client visits when required and shares Compliance Process as well as Due Diligence

information, also contributes to formation of identical awareness.

20. Acts as an subject advisor, provides assessments and suggestions to the Upper Management

and Chairman, Management Board.



A .Özcan HALAÇ President&CEO

Director General Compliance O cer Manager, Internal Audit Unit Director

Financial A airs Group nterna onal Branch Mangers

Department Managers

Department Compliance O cer Department Compliance O cer Department Compliance O cer

PRESIDENT&CEO

COMPLIANCE COMMITTEE

COMPLIANCE COMMITTEE



Appendix-C

COMPLIANCE COMMITTEE OPERATION DIRECTIVE:

1. Compliance Committee shall have a structure providing supportive services to the

compliance system and is under direct supervision of Chairman, Management Board.

2. Compliance Officer serves as a secretary and rapporteur of the Compliance Committee.

Minutes and reports are recorded by the rapporteur. Matters of utmost significance shall be

issued as Management Board decisions. Compliance Committee is response to the

Chairman, Management Board.

3. Compliance Committee consists of following Officers:

Director General

Compliance Officer

Manager, Internal Audit Unit Director,

Financial Affairs Group

International Branch Mangers

4. Committee serves as the decision taking authority in matters concerning the Compliance

Process and Due Diligence. Evaluates high risk clients. Determines corrective actions to be

taken and guides their execution in subjects under consideration due to non-compliance

notifications.

5. Submits high risk clients to the approval of Chairman, Management Board.

6. Compliance Committee meets once every 3 months. If investigative commission

subcommittees are appointed concerning non-compliance notifications, commissions take

the necessary decisions and corrective action plans are implemented, and necessary

information are provided to the Chairman, Management Board as well as to parties who

supplied the notification.



Appendix-D

NON-COMPLIANCE SYSTEM OPERATION and COMPLIANCE ACCESS POINT DIRECTIVE :

1. Compliance Access Points are parts of both London Bullion Market Association(LBMA) andcorporate Quality Control Management System.

2. It has been established as a communication mechanism facilitating non-compliance

notifications resulting from compliance failures considered as risks by employees/workers

within the context of corporate Gold Supply Chain Process.

3. Compliance Access Points are used jointly with Total Quality Management System

complaint/suggestion facilities. These facilities are drop-form locked boxes positioned in all

appropriate Unit locations and employee/worker gathering places such as corporate

cafeterias and rest rooms. These boxes at all times provide a supply of blank forms to be

filled and pens. Intranet internet system may also be used.

4. Non-compliance notification forms possess CONFIDENTIAL level secrecy. If the notifier

wishes to disclose his/her name than he/she must also sign the form. Corporate

management guarantees non-prejudice, non-criticism, and non-denunciation to persons

providing notifications, and further warrants that notifies are under protection in such

matters. Unit Compliance Officers shall directly inform the Corporate Compliance Officer of

any non-compliance identified.

5. If the Compliance Officer or Compliance Committee fined the notification worthy of

consideration and investigation, than the Chairman, Management Board shall be informed.

If it is a problem concerning the e n t i r e Corporation than a s u b c o m m i t t e e may

be commissioned to carry out investigations in support of decisions to be taken.

6. Compliance Access Points shall be monitored on weekly basis by corporate Compliance

Officer/Unit Compliance Officers/Total Quality Management Officer and if any, submitted

notification forms shall be evaluated and assessed by the Compliance Committee. Necessary

corrective action plan shall be initiated and Chairman, Management Board shall be informed.

Findings and conclusions, corrective action plan results shall also be provided as feedback to

the notifying person.



Appendix-D

NON-COMPLIANCE SYSTEM OPERATION and COMPLIANCE ACCESS POINT DIRECTIVE :

1. Compliance Access Points are parts of both London Bullion Market Association(LBMA) and corporate Quality Control Management System.

2. It has been established as a communication mechanism facilitating non-compliance

notifications resulting from compliance failures considered as risks by employees/workers

within the context of corporate Gold Supply Chain Process.

3. Compliance Access Points are used jointly with Total Quality Management System

complaint/suggestion facilities. These facilities are drop-form locked boxes positioned in all

appropriate Unit locations and employee/worker gathering places such as corporate

cafeterias and rest rooms. These boxes at all times provide a supply of blank forms to be

filled and pens. Intranet internet system may also be used.

4. Non-compliance notification forms possess CONFIDENTIAL level secrecy. If the notifier

wishes to disclose his/her name than he/she must also sign the form. Corporate

management guarantees non-prejudice, non-criticism, and non-denunciation to persons

providing notifications, and further warrants that notifies are under protection in such

matters. Unit Compliance Officers shall directly inform the Corporate Compliance Officer of

any non-compliance identified.

5. If the Compliance Officer or Compliance Committee fined the notification worthy of

consideration and investigation, than the Chairman, Management Board shall be informed.

If it is a problem concerning the e n t i r e Corporation than a s u b c o m m i t t e e may

be commissioned to carry out investigations in support of decisions to be taken.

6. Compliance Access Points shall be monitored on weekly basis by corporate Compliance

Officer/Unit Compliance Officers/Total Quality Management Officer and if any, submitted

notification forms shall be evaluated and assessed by the Compliance Committee. Necessary

corrective action plan shall be initiated and Chairman, Management Board shall be informed.

Findings and conclusions, corrective action plan results shall also be provided as feedback to

the notifying person.

Appendix-E

COMPANY COMPLIANCE OFFICER, DEPARTMENT COMPLIANCE OFFICERS, COMPLIANCE

COMMITTEE, COMPLIANCE ACCESS POINT CORRELATION:

BOARD OF CHAIRMAN

COMPLIANCE COMMITTEE Compliance Officer

Department Compliance Officer



COMPLIANCE ACCESS

POINT

EMPLOYEES / WORKERS

CORRECTIVE ACTION CORRECTIVE ACTION

IGR DUE DILIGENCE GUIDANCE FOR RESPONSIBLE SUPPLY CHAIN OF MINERALS ©IGR Metals Trading DMCC, All Rights Reserved.


Appendix-F

UNIT OFFICER/ UNIT MANAGER OPERATIONAL DIRECTIVE:

1. Ensures Compliance Process awareness among all unit personnel.

2. Monitors relevant statutes.

3. Appoints and supervises Unit Compliance Officer.

4. Applies corporate Gold Supply Chain Responsibility Policy and Compliance Directive

principles and provisions.

5. Conducts in-Unit Due Diligence, identifies risks and proposes resolutions.

6. Applies any corrective actions set out.

7. Follows-up in-Unit non-compliance notifications.

8. Prepares the Unit Compliance Directive in accordance with the Corporate

Compliance Directive.

9. Ensures preparation of Unit Compliance File.

10. Prepares In-Unit Compliance Instructions and ensures notification of personnel.

11. Executes Compliance Agreement with clients.

12. Ensures maintenance of Client Information Files.13. Conducts client visits when required and for the purpose of raising awareness, and

shares information on Compliance Process and Due Diligence.

14. Participates in related meetings.

15. Establishes a relevant Unit Archive system.

16. Prepares the Unit for audit.

17. Works in coordination with Corporate Compliance Officer



Appendix-G

UNIT COMPLIANCE OFFICER WORK DIRECTIVE:

1. Unit Compliance Officer is appointed by Unit Manager. Officer is responsible to theUnit Manager.

2. Appointment and duty reassignments shall be notified to the Corporate Compliance Officer.

3. Unit Compliance Officer works in coordination with Corporate Compliance Officer.

Monitors relevant statutes. Develops In-Unit directives and applications, ensures

execution and control.

4. Conducts In-Unit Due Diligence jointly with Unit Manager.

5. Works in coordination and cooperation with the Corporate Compliance Officer.

6. Reports his/her activities to the Unit Manager and Corporate Compliance Officer.

7. Participates in related compliance meetings.

8. Monitors In-Unit non-compliance notification system.

9. Functions Unit internal trainer.

10. Coordinates Unit audit preparations.

11. Maintains the relevant In-Unit records and Unit Compliance File.



Annex-I

LBMA COMPLIANCE PROCESS ANALYSIS

Item no.

To do Responsible Unit Remarks

1. To appoint a Company Compliance Person and inform the LBMA about it.

Compliance Person LBMA was informed on the 18th of December 2012.

2. Organizational chart of the company was reviewed and arranged to include the Compliance Person

Compliance Person Arranged and published.

3. Company Compliance Directive was prepared Compliance Person Prepared.

4. Preparing and constant updating the Gold Supply Chain Responsibility Company Policy

Compliance Person Prepared and updated

5. Announcing the GSC Responsibility Company Policy to all stakeholders/and publishing it on the

Compliance Person/IT Prepared and added to web site.

6. Entering into an agreement with an independent auditor who acts in accordance with the LBMA standards, and having him/her audit anytime during the year and reporting the results to the LBMA.

Compliance Person Compliance Committee

Audit from independent auditor every year and report to LBMA

7. The format of the Refinery Compliance Report of the company, which should be prepared at the end of the audit, shall be prepared according to the Draft Audit Guidance Annex B), and developing the in-house applications in the framework of

Compliance Person Refinery Compliance Report has been preparing every year.

8. Creating a Compliance Committee, holding periodic meetings and keeping the meeting minutes.

Compliance Person Compliance Committee

Committee was established.

9. Commissioning a Unit Compliance Person for each unit

All units Nominated Compliance Officer at each departments.

10. Preparing a Unit Compliance Directive for each unit

Compliance Persons of the Units Company Compliance Directive has been prepared, and send to units.

11. Preparing an LBMA Compliance File for each unit (The unit compliance directive which includes company policy, special issues to be considered in the unit, the unit instructions, commissioning, notification lists etc)

Compliance Person / All units A sample file is prepared by the Compliance Person and be given to the units.

12. Holding a supply chain training program, determining a chief trainer and trainers, holding periodical trainings, and keeping the minutes on trainings.

Compliance Person Compliance Officer has been organizing the training programs.



13. Holding periodical in house audits by the Compliance Committee and the Company Compliance Person and submitting quarterly reports to the top management

Compliance Person Audit Unit

An audit plan and a calendar are to be published by the Compliance Person.

14. Preparing a Corrective Action Plan and implementing it through periodical audits.

Compliance Person To be prepared and published by the Compliance Person

15. Creating a lot system/ or a compliance reference system where each refined lot could be monitored, and where the compliance of all processes with each other could be seen.

Compliance person/ Istanbul Gold Refinery Manufacturing/Gram Gold manufacturing/ Accountancy / All commercial Units

A working group is to be established and the system will be set up within January.

16. Strengthening the current relations with the customers, holding customer visits as well as documenting the visits to this effect

Compliance person/All commercial units

Commercial units will schedule a quarterly Customer visits and the Compliance Person is to be informed about it.

17. Creating an in-house Report System that will provide an early-warning that covers in-house participation and communication, in order to determine – and take action- the new risks that emerges at each stage related to the supply chain, and implementing a mail/notification box and the Compliance Access Points, to this effect.

Compliance Person Prepared by the compliance officer and set Compliance Access Points.

18. Entering into Good Will/ Due Diligence agreements with our customers, revising the current agreements (if any) in the process of compliance to the LBMA and raising awareness amongst them in the framework of our policy.

Compliance Person/All commercial units

Prepared by compliance officer.

19. Creating a risk management plan and holding a general risk analysis on the Supply chain

Compliance Person Prepared by compliance officer.

20. Keeping a Customer File, which is separate for each customer, and holding a risk analysis in the scope of KYC (Know Your Customer) system, creating a customer databank format, appointing a reference number and risk rating to each customer, and those with high risk rate should be approved by the Top Management(Private).

Compliance person/Istanbul Gold Refinery Manufacturing/Gram Gold Manufacture/ Accountancy /All commercial units

risk rating to each customer has been doing by compliance department.

21. Creating and publishing the lists of customer reference numbers

Compliance person/All commercial units

Customer lists are to be prepared by the commercial units according to a format to be determined by the Compliance person and are to be submitted to the Compliance Person

22. Creating a classical archiving and a database archiving system that will keep the processes/documents for at least 5 years

Human Resources/Information technology/All commercial units/Accountancy/Manufacture units

Trying to make better

archiving system.

23. Holding the on-site observations on refinery units and other related offices, and making them ready for the audits

All units Things to be put in order and organized by all the units before the audit



24. Keeping all instructions, directives etc ready in the framework of Total Quality Management-ISO…, all workers should be notified of their job definitions, powers and responsibilities, related instructions and directives, and keeping all records including the in-house trainings. And any type of instructions, directives etc that will be prepared in this scope should be updated in accordance with the principles of the Company Gold Supply Chain Responsibility.

All Units/Human Resources/Total quality management person.

Regarding the actions/documents to be carried out/prepared by the Human Resources/Total Quality Management Person pursuant to the ISO 9001,14001, OHSAS(Occupational Health and Safety Management System) 18001 etc., these actions/documents should be adapted to comply with the Company Gold Supply Chain Policy Principles

25. Performing the refining and manufacturing processes in accordance with the requirements of the LBMA Good Delivery List (marking, branding, labeling, registering etc)

Production Units/ Laboratory/Adjustment house

Following the processes and the maintaining the adjustment processes to the requirements of the LBMA Best Manufacturers List

26. Preparing an Annual Financial Report at the end of each fiscal year and submitting it to the LBMA

Finance/Accountancy Audit done by independent auditor

27. Participating the meeting/seminary events of the LBMA during the year and keeping a close contact with it.

Compliance Person LBMA Annual Calendar is to be followed and participated accordingly

28. Preparing the file and the brief that will be submitted to the auditor.

Compliance Person Done by every year.

29. In order to submit to the auditor, preparing the lists –of the audit term- indicating the amount and name/addresses of all types of commercial activities related to the gold refining, including the countries and risk rates of those who supplied the gold

Compliance person/Finance/Accountancy/ Related Units

To be prepared in agreement with the auditing company

30. Preparing the lists -within its term- detailing the date, weight and types of all materials containing gold that was purchased outside or provided through the in-house transfers for refining as well as the lists that cover all commercial processes including the details on the excavation points of the materials that come from recycling or those materials that are used for investment such as ingot, bar, coin and such ones that contain gold for submission to the auditor.

Compliance Person/Finance/Accountancy/Related Units

To be prepared in agreement with the auditing company

31. Preparing the lists –of the audit term- on offices related to the materials containing gold outside the refinery, including their place of operation, and their storage areas (if there is any) as well as the name/addresses for submission to the auditor.

Compliance Person To be prepared in agreement with the auditing company



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