1. Introduction

COMICORDIA is committed to conducting all its operations with integrity, transparency, and strict adherence to both national and international regulatory frameworks. This Responsible Sourcing & AML Policy defines the principles and procedures that guide our sourcing, processing, and export of gold dore bars.

2. Regulatory Frameworks Followed

COMICORDIA adheres to the following governing standards:

• DRC Mining Code & Mining Regulations

• OECD Due Diligence Guidance for Responsible Mineral Supply Chains

• ICGLR Regional Certification Mechanism (RCM)

• Anti-Money-Laundering (AML) & Countering Financing of Terrorism (CFT) requirements

• Know Your Customer (KYC) standards applicable to mineral export trade

• Environmental & Social Responsibility Guidelines for Artisanal Mining Cooperatives

3. Ethical Sourcing Commitments

3.1 Zero-Tolerance for Illicit Minerals

COMICORDIA strictly prohibits the purchase, processing, transport, or export of minerals associated with:

• Illegal mining

• Fraudulent origins

• Armed conflict or militias

• Corruption or bribery

• Terrorist financing

3.2 No Child Labour

We enforce a firm policy against child labour. Only adults above the legal working age participate in any COMICORDIA-associated mining activity.

3.3 Environmentally Responsible Practices

We encourage responsible land use, water protection, and safe extraction practices across all cooperative mining zones.

4. Supply Chain Traceability

COMICORDIA maintains a complete chain-of-custody system that includes:

• Individual miner registration

• Daily production logging

• Batch identification and serialisation

• Secure storage controls

• Independent or accredited assay testing

• Full export documentation trail

Every unit of gold exported by COMICORDIA is traceable back to its exact point of origin within our cooperative operations.

5. AML & KYC COMPLIANCE

5.1 Buyer Onboarding

Before any transaction, COMICORDIA requires:

• Corporate registration certificates

• Passport/ID of beneficial owners

• Proof of address

• Company tax number

• Anti–Money-Laundering compliance declaration

• Source of funds confirmation for large transactions

5.2 Transaction Monitoring

All commercial transactions undergo compliance screening to detect:

• Suspicious payment patterns

• Third-party involvement

• Inconsistent trade volumes

• High-risk jurisdictions

6. Documentation Provided for Each Export

• Certificate of Origin

• Export Licence

• Commercial Invoice

• Packing List

• Assay Certificate

• Ministry of Mines Clearance

• Transport & Customs Documents

Only legally compliant gold leaves COMICORDIA custody.

7. Internal Governance

A dedicated Compliance Office oversees:

• Daily monitoring of production

• Workforce age verification

• Environmental and safety practices

• KYC/AML verification

• Transaction approval

• Audit and reporting requirements

8. Enforcement & Reporting

COMICORDIA applies strict consequences for violations, including membership suspension, termination, and legal referral where necessary.

A confidential reporting mechanism allows workers, partners, and stakeholders to report misconduct securely.

COMICORDIA is committed to building a transparent, responsible, and trusted gold supply chain that meets the expectations of regulators, international buyers, and mining communities alike.