Shenzhen Cuilu Gold Refinery Co., Ltd

2024

Supply Chain Due Diligence Management Compliance Report

February 4, 2025

Company name: Shenzhen Cuilu Gold Refinery Co., Ltd.

Location: No.2 Factory Building, Huangshengfa Industrial Zone, Baida Street, Xikeng Village, Henggang Street, Longgang District, Shenzhen

Year-end Report: 2024 LBMA Supply Chain Due Diligence Management Compliance Report

Date of report: February 4, 2025

Person in charge of report: Li Wenju

Reporter position: Director of Compliance and Risk Control 8050529031@qq.com

Part I: Purpose

In order to meet the requirements of the LBMA Responsible Gold/Silver Guidance, avoid any systematic or extensive human rights violations, avoid conflicts, money laundering and combat terrorist financing, our company has established a strong management system and adopted the supply chain due diligence method to identify and evaluate the risks of all suppliers, so as to ensure that the company's gold/silver supply chain fully meets the requirements of the LBMA Responsible Gold/Silver Guidance.

Part II: General situation of the company

Shenzhen Cuilu Gold Refinery Co., Ltd., established in July 2007, is located in Huangshengfa Industrial Zone, Baida Street, Xikeng Village, Henggang Street, Longgang District, Shenzhen. It is a precious metal resource integration enterprise integrating gold regeneration, silver recovery, precious metal refining and testing. There are several advanced precious metal refining production lines, which can purify 300 tons of gold and 200 tons of silver annually, mainly producing "Cuilu" brand standard gold ingots, silver ingots and high purity（AU99.999% or more）. "Cuilu" brand has successively won "China Famous Brand" and "China Well-known Trademark", and it is one of the top 100 enterprises in Shenzhen. In September 2009, the company became a comprehensive member of Shanghai Gold Exchange, and it is a qualified enterprise that can provide standard gold ingots and silver ingots. The refining plant covers an area of more than 3,000 square meters and is a leading enterprise in the precious metal purification industry. Companies adhere to the quality first, sincere service as the core business philosophy, the company passed the ISO9001 quality system certification and ISO14001 environmental management system certification in 2009. Currently, the company's Quality and Environmental Management System certificates are valid until September 2027.

All the raw materials of our company come from the gold/silver jewelry production and processing company in China and the old gold and silver ornaments and ornaments at the sales terminal, as well as the related alloy gold and gold.

Part III: Summary of Compliance Activities

Step 1: Establish a strong corporate management system

Statement of compliance:

We have fully complied with Step 1: Establish a Strong Company Management System.

Company policy:

Compliance Declaration:

The Company issued the Due Diligence Management System for Gold/Silver Supply Chain and the Management Measures for Risk Mitigation in Gold/Silver Supply Chain on April 1, 2022. Our gold/silver supply chain policy strictly prohibits gold/silver suppliers from the following behaviors:

1.Violations of human rights, including the use of child labor, torture, inhumane or degrading treatment, widespread use of violence, or other serious human rights abuses such as forced labor, war crimes, crimes against humanity, or genocide.

2.Providing direct or indirect support to illegal armed groups or public or private security forces controlling mining areas, traders, intermediaries, or transportation routes through the supply chain, or engaging in illegal taxation or extortion of money or minerals throughout the supply chain ("Illegal armed groups, public or private security forces").

3. Concealing the origin of gold/silver through bribery or fraud;

4.Failure to comply with government requirements regarding extraction, trade, and export taxes on minerals from conflict and high-risk areas.

5.Money laundering or financing of terrorism.

6.Funding conflicts.

7.Engaging in high-risk business activities, such as weapons, gambling, antiques and art, sects, and their leaders.

8.Beneficiaries being politically sensitive individuals or wanted persons.

9.Not compliance with environmental, health, safety, and labor laws and/or company policies in the operating country/region.

The Due Diligence Management System of Gold/Silver Supply Chain stipulates the internal organizational structure and responsibilities, due diligence regulations of gold/silver supply chain, risk identification methods and evaluation standards of gold/silver supply chain, transaction monitoring, document preservation, training and reporting mechanism.

In 2024, our company completed the due diligence of all gold/silver suppliers in strict accordance with the system requirements, and carried out risk identification and assessment, effectively controlling the risks in the gold/silver supply chain. At the same time, the company also published this policy on its official website at http://www.transfarmall.cn/article.html.

Internal management structure

Compliance statement:

The company has established an internal management system in accordance with the "Gold/Silver Supply Chain Due Diligence Management System," which clearly defines management positions and their corresponding responsibilities. The company has appointed a Compliance Director, who is served by the Deputy General Manager, and a Compliance Officer, who is served by the Financial Director. Additionally, the company has formed a compliance team comprising the Business Department Manager, Production Plant Manager, Financial Department Manager, and Testing Center Director, each responsible for matters related to the gold/silver supply chain.

The compliance director is a senior manager of the company, responsible for the examination and approval of cooperation contracts with suppliers, including whether to cooperate with high-risk suppliers, and the review and supervision of suppliers after the contract is signed.

The compliance officer assists the senior management to be fully responsible for the due diligence of the gold/silver supply chain, and is responsible for everything in the gold/silver supply chain, ensuring that the whole gold/silver supply chain of the company meets the risk management regulations and can effectively identify risks and avoid risks. Responsible for the training of due diligence and risk control of gold/silver supply chain, drafting and updating the gold/silver supply chain policy, and providing accurate information for senior managers.

Members of the Business Department are responsible for the procurement of raw materials, ensuring the long-term stability, consistency, and safety of the supply. They are also tasked with refusing cooperation with enterprises, organizations, or nations associated with high-risk regions. Members of the Finance Department are charged with the meticulous preservation of all transactional documents pertaining to customers.

Members of the Production Department organize the production process of gold/silver by keeping detailed production records. They employ a closed-loop process during production to ensure the safety and traceability of gold/silver processing. They also maintain meticulous records of gold/silver storage and dispatch, categorized by customer. Members of the Testing Center are responsible for conducting chemical assays on each batch of gold/silver from suppliers and sending the test data in report form to the Business Department, Finance Department, and Production Department.

In 2024, Shenzhen Cuilu Gold Refinery Co., Ltd. strictly implemented the Due Diligence Management System of Gold/Silver Supply Chain and conducted risk due diligence on suppliers. Monitor all transactions to avoid establishing relationships with high-risk suppliers. At the same time, the compliance officer reviews all due diligence findings and results, and all gold/silver material procurement contracts have been approved by the compliance director.

Traceability System and Identification of Other Supply Chain Participants

Compliance statement:

The company has established a traceability system in accordance with management system requirements, collecting and maintaining supply chain information for each batch.  This includes assigning a unique reference number for each input and output batch:gold/silver product traceability (gold/silver-> raw materials)-gold/silver-containing material type (mineral gold and silver or recycled gold/silver); -warehousing weight and analysis report; -Raw material warehousing date and finished product warehousing date; Gold/silver product traceability (gold/silver-> customers)-customer information; -Transaction weight and analysis report; -Issue date; By retaining all records, it is possible to trace finished products back to raw materials and vice versa, as well as to trace the procurement contracts for each batch of products from every supplier. The information on the "Material Receipt Forms" from different suppliers allows for the tracing of details such as the type of precious metal, purchase weight, analysis reports, and related due diligence documents.

Interact with the counterparty and assist the counterparty to establish due diligence capability.

Compliance statement:

When entering into contracts with suppliers, the business personnel from the business department, in accordance with the management system requirements, sign the "LBMA Compliance Commitment Letter" and the "Anti-Forced Labor Commitment Letter" with all gold/silver supplier counterparties. They conduct supply chain due diligence and brief the suppliers on the relevant provisions of the "LBMA Responsible Gold/Silver Guide" and the "Policy and Procedures Prohibiting the Use of Forced Labor" to ensure that they understand the company's LBMA management requirements, supply chain policies, and the commitments required.In the letter of commitment, the other party to the gold/silver supply contract should promise and admit in writing that there is no serious human rights violation related to mineral exploitation, transportation or trade, no direct or indirect support for non-state armed groups, no direct or indirect support for public or private security forces, no bribery or false misrepresentation of mineral sources, and no money laundering. In addition, it has not participated in the payment of taxes, fees and royalties related to mineral exploitation, trade and export in conflict-affected areas and high-risk areas to the government. All the suppliers signed in 2024 have signed relevant letters of commitment.

Transaction monitoring

Compliance statement:

All payments for gold/silver are made through the company's bank account, and there is no cash transaction. These receipts and payments are supervised by banks and national finance and taxation departments, and financial audits are conducted every year. According to the requirements of the management system, supervise the risks in the supply chain of gold/silver suppliers. The refinery checks the received shipping documents, weight documents, inspection reports, invoices, transfer records and other texts of each batch of products. The Compliance Officer is responsible for transaction monitoring, checking the trading background that is inconsistent or suspected to be inconsistent in any form, and confirming the investigation results in writing and reporting to the Compliance Director. All transactions in 2024 are made by bank transfer.

Communication and complaint mechanism

Compliance statement:

The company has established a complaint mechanism, and the e-mail and contact information of the compliance officer are posted on the official website at:

Http://www.transfarmall.cn/article.html,and the complaint mechanism has made necessary communication with suppliers in the process of purchasing materials containing gold/silver, and internal and external stakeholders can anonymously report violations in the process of gold/silver trading. The factory set up a suggestion box as a way for internal employees to report, and the relevant personnel regularly unpack and check the contents of the report. There were no reported incidents in 2024. In addition, the company has also established a whistleblower protection system to prevent retaliation against whistleblowers and effectively protect their rights and interests.

Training

Compliance statement:

The company regularly organizes training sessions for all departments related to gold/silver, with one training session conducted in the year 2024. On May 16, 2024, the company provided training on supplier investigation procedures, risk level assessment, and response measures in accordance with the "LBMA Responsible Sourcing" system document requirements. An effectiveness evaluation was carried out following the training, and the training records have been retained.

Record Retention

Compliance Statement:

Compliance statement: according to the company's requirements, all supplier-related documents, including due diligence documents, risk assessment forms, compliance documents, contract texts, inspection records and warehousing records, shall be kept for at least five years.

Step 2: Identify and evaluate supply chain risks

Compliance Statement: We fully comply with Step 2: Identify and evaluate supply chain risks.

Supply chain risk identification:

Compliance statement: The "Gold/Silver Supply Chain Due Diligence Management System" stipulates the methods for supplier risk identification，covering all risks of gold/silver-containing materials from the place of origin to the refinery. The following risks are identified through the Supplier Due Diligence Questionnaire, such as basic information of suppliers, beneficiary, origin information, responsible precious metal supply chain policy, transportation process, anti-money laundering and anti-financing terrorism, bribery and fraud, human rights violations, transaction monitoring, and support for non-governmental armed organizations. The identification method includes: establishing supply chain customer files, including enterprise name, legal representative, address, contact information, operation mode, production mode, transaction contract, etc. Check the existing supply chain customers regularly. If there are new or changed customers, check their files in time to keep the file database in the latest state. Identify every customer, enterprise and enterprise beneficial owner, and make sure that every customer, enterprise and enterprise beneficial owner in the supply chain is not on any government's wanted list of money laundering, fraud or terrorism, and inquire that the enterprise and enterprise beneficial owner are not on the list of untrustworthy persons through China Executive Information Open Network; Regularly obtain the details of supply chain customers' business and finance, the purpose of gold/silver trading and business operation.

In accordance with the "Risk Assessment and Risk Management Procedures for Forced Labor in the Supply Chain" and the "Policy and Procedures Prohibiting the Use of Forced Labor," basic information about suppliers is collected, including their country/region, industry, number of employees, and employment policies. Potential risks of forced labor are identified based on the following indicators: the incidence of forced labor in the supplier's country/region; industry characteristics (such as higher risk in labor-intensive industries); the supplier's social responsibility certifications; and records of employee complaints, among others, to conduct risk analysis and determine the corresponding risk level. Risk levels are categorized as high, medium, or low based on the likelihood of risk occurrence and the degree of impact. High risk: Suppliers located in regions with a high incidence of forced labor and lacking relevant social responsibility certifications, where any form of forced labor is found during investigations, including but not limited to debt bondage, contract labor, servitude, etc., and employees are not free to choose their employment and are subject to any form of coercion or restriction. Medium risk: Suppliers with some risk of forced labor, where potential non-compliance with relevant human rights activities is found during the investigation process, but corresponding measures have been taken. Low risk: Suppliers that fully comply with local laws and regulations, due diligence aligns with the company's "Risk Assessment and Risk Management Procedures for Forced Labor in the Supply Chain" and "Policy and Procedures Prohibiting the Use of Forced Labor," and possess relevant social responsibility certifications. Risk response measures: High-risk suppliers: Require immediate rectification from the supplier and submission of a detailed rectification plan, conduct on-site audits to verify the effectiveness of the rectification, and terminate the cooperation if rectification is not completed within the stipulated time. Medium-risk suppliers: Provide training and support to help suppliers improve their employment policies, conduct regular reviews to ensure risks are effectively controlled. Low-risk suppliers: Continuous monitoring to ensure risks do not escalate, and encourage suppliers to further enhance their social responsibility performance.

Before the business relationship with suppliers is established, the business department needs to fill in the Due Diligence Questionnaire for Gold/Silver Supply Chain and conduct risk assessment for all gold/silver-containing materials according to the Due Diligence Rules for Gold/Silver Supply Chain. Mineral gold/silver: Suppliers need to provide information on the origin of gold/silver-containing materials, mining license, import and export license, proof of mining information, due diligence documents, in addition, they should also collect business licenses, beneficiaries, credit standing and financial information, whether they are on the government's money laundering list, known fraudsters or terrorists, etc. For some suppliers, compliance officers will go to the site to investigate the authenticity of the information to ensure accurate and reliable evaluation. The evaluation criteria of high-risk supply chain are as follows:

1. Mineral gold/silver or recycled gold/silver comes from, transits through or passes through high-risk areas affected by conflicts or human rights violations.

2. Mineral gold/silver claims to come from a country with limited known reserves, limited resources or limited expected silver production.

3. Regenerated gold/silver comes from a known high-risk area of conflict impact and human rights violation, or it is reasonably suspected to transit through this area.

4. Companies in the gold/silver supply chain or other known upstream companies are located in a country with high risks of money laundering, crime and corruption.

5. The profit owners of companies in the gold/silver supply chain or other known upstream companies are politically sensitive.

6. Companies in the gold/silver supply chain or other known upstream companies actively participate in high-risk business activities, such as weapons, gambling, money laundering, antiques and artworks, diamonds, religions and religious leaders.

7. High-risk countries and regions coming from and passing through, Including: using fragile state index, global conflict barometer, United Nations human development index, United Nations comprehensive sanctions list, United Nations human rights report, Financial Action Task Force (FATF) report, whether it is listed in DFA1502 or not, (a total of 10 countries: the Democratic Republic of the Congo, Republic of Congo, Central African Republic, Rwanda, South Sudan, Uganda, Tanzania, Burundi, , Zambia, Angola), EU CAHRA List and reliable market information about high-risk gold centers/transit centers and countries/regions with high money laundering risks to identify conflict-affected and high-risk areas.

Evaluation method:

Based on the content of the due diligence questionnaire, combined with the actual information received from suppliers and customers, evaluate and score according to the evaluation criteria of each project, and finally determine the risk level.

In 2024, an evaluation was conducted on all 44 silver material suppliers. The silver provided primarily originates from defective products, scraps, old jewelry, outdated ornaments, and unsold stock from silver jewelry manufacturers and stores in Shenzhen and its surrounding areas. Investigations revealed that the suppliers' raw materials mainly consist of unsold stock and defective items from exhibition halls and sales outlets in regions around Shenzhen, such as Hunan, Fujian, Henan, and Guangdong.

In the same year, all 565 gold material suppliers were also evaluated. The gold materials supplied by these vendors are predominantly old gold jewelry and related gold alloys and composite gold materials, all sourced from domestic cities and provinces. According to the company's "Definition Process for Conflict-Affected and High-Risk Areas (CAHRA)," China is not identified as a conflict-affected or high-risk area. During the 2024 responsible sourcing risk assessment, the supply chain was determined to be of low risk.

According to the company's "Gold and Silver Supplier Risk Assessment Form" and "Supplier Forced Labor Compliance Investigation Report" evaluation results, all suppliers have been assessed as low-risk suppliers. Although all suppliers are deemed low-risk with no warning signals detected, the "Gold/Silver Supply Chain Due Diligence Management System" has established enhanced due diligence measures, including:

1.Conducting on-site visits to verify the counterparty's KYC information and investigate the risk of threat financing, as well as the specific supply chain due diligence results conducted by qualified employees or independent third-party audit firms.

2.Completing the on-site visit report template in the refinery toolkit, following up and monitoring improvement measures, and documenting relevant content.

3.Enhanced Due Diligence (EDD) measures for high-risk recycled gold/silver also include the following, with records retained:

a. Checking government blacklist information for each company located in high-risk areas for recycled gold/silver, which are involved in the supply chain from the counterparty to the refinery (including transporters).

b. Evaluating the counterparty's supply chain due diligence practices (considering their capabilities and risk classification methods), procurement (if applicable), as well as anti-money laundering and counter-terrorism financing procedures.

c. Assessing due diligence records to confirm that procedures have been executed in accordance with the counterparty's supply chain due diligence policy.

d. Evaluating the counterparty's on-site visit methodology for high-risk supply chains.

Risk Assessment Reporting

Compliance statement:

The Compliance Officer provides a commentary report to the Compliance Director and top management on behalf of the senior management team every six months. The senior management retains ultimate control and responsibility for the gold/silver supply chain. In the case of high-risk suppliers, approval from the top management is mandatory, and cooperation must be ceased immediately.

Transaction monitoring

According to the requirements of the management system, ensure the transaction supervision of the risks in the supply chain of gold/silver suppliers. The refinery checks the received shipping documents, weight documents, inspection reports, invoices and other texts of each batch of products. The Compliance Officer is responsible for transaction monitoring, checking the trading background that is inconsistent or suspected to be inconsistent in any form, and confirming the investigation results in writing and reporting to the Compliance Director. Isolate the gold/silver materials that do not meet the requirements until the risk is reduced to low risk. In 2024, there was no non-compliance with the transaction monitoring and control procedures.

During the audit, some minor nonconformities of suppliers were improved and closed.

Step 3: Implement management strategies for the identified risks.

Compliance Statement:

We fully meet the third step: design and implement a management strategy to deal with the identified risks.

Implement a risk management strategy for the identified risks.

Compliance statement:

1. Mitigating risks when continuing to trade: When the evaluation of suppliers is at a low risk, we will continue to obtain gold/silver raw materials from the suppliers, and gradually improve their investigation data during the cooperation process, and gradually assist suppliers to establish their due diligence system and help them establish and improve the deficiencies in risk management and control.

2. Mitigating the risk when the transaction is suspended: when the evaluation result is medium risk, the cooperation will be suspended and the suspicious risk will be investigated until the supplier is determined to be a low-risk supplier. At the same time, isolate incoming materials. The company's gold/silver warehouse is equipped with a high-risk incoming isolation zone to deal with unexpected situations. Within a period of 6 months, if the supplier rectifies the risk item and removes the risk, the transaction will be resumed; if the rectification fails to meet the requirements or the risk cannot be removed, the cooperation with the supplier will be stopped.

3. Stop trading and get rid of risks: if the supplier is assessed as high risk, or if high-risk items are found during cooperation with the supplier, stop cooperating with it, report the evaluation report and high-risk items to the top management, and put them on the blacklist of the company. You cannot trade with the company within 3 years.

Quantitative measures, performance monitoring, re-evaluation and regular reporting

Compliance statement:

Compliance Statement: The "Gold/Silver Supply Chain Due Diligence Management System" stipulates the use of the "Gold and Silver Supplier Risk Assessment Form" as a systematic approach to evaluate the risk levels of suppliers. According to the company's assessment of all suppliers, the risk levels are categorized as follows: (i) low risk, R≥6 points; (ii) Medium risk, 2 points < r < 6 points; (iii) High risk, R≤2 points. If the result of due diligence is low risk, the company has adopted an improvement strategy with clear performance targets within the specified time range, and we will continue to obtain gold/silver raw materials from it. If the due diligence result of the gold/silver supply chain is medium-risk or high-risk, it indicates that there may be money laundering, terrorist financing, fuelling conflict and human rights violations, or there is a high possibility of this, we will immediately stop obtaining gold/silver raw materials from it until the information or data provided shows its low-risk level. According to the results of due diligence in 2024, no supplier needs a risk mitigation management strategy. Regular re-evaluation and continuous monitoring:

1. Annually，the compliance team members from the business department organize personnel to collect all changes in supplier information, continuously monitor transaction outcomes, and conduct an annual re-evaluation of supply chain due diligence to determine whether to continue the cooperation.

2. The transportation, warehousing, production and payment of each batch of purchased gold/silver raw materials are monitored by the compliance officer. Periodic report: The Compliance Commissioner submits quarterly reports to the Compliance Director and the top management according to the actual situation of LBMA management. Report and summarize the operation of LBMA management system in this quarter, and put forward the shortcomings and improvement measures.

In 2024, our company adopted quantitative means to manage suppliers' scores, and conducted annual supple mentary risk assessment for all suppliers except new suppliers. The Compliance Director has reviewed the evaluation results and submitted quarterly reports to the top management.

Step 4: Arrange an independent third-party audit

Statement of compliance:We are in full compliance with Step 4: Arrange an independent third-party audit.

Compliance statement:

This year, our company prepared the compliance report as of December 31, 2024 on time, and commissioned RCS Global to conduct compliance verification of our company.

Step 5: Supply Chain Due Diligence Report

Statement of compliance:We are in full compliance with Step 5: Supply Chain Due Diligence Report.

Compliance statement:

We have completed the investigation of all suppliers according to the Due Diligence Management System of Gold/Silver Supply Chain formulated by the company, which met the requirements of LBMA Responsible Gold/White Silver Index and formed the Compliance Report 2024. The report will be available on the company's website, http://www.transfarmall.cn/article.html.

Limited Assurance Statement on Forced Labour

Compliance Declaration: We are fully compliant with the prohibition of forced labor and human rights requirements. Neither our company nor any of our suppliers engage in forced labor.

Compliance Statement:

Our company is committed to safeguarding the legitimate rights and interests of our employees, strictly adhering to international labor standards and relevant laws and regulations, and firmly prohibiting any form of forced labor. In April 2024, we conducted a company-wide briefing, posted the policies in conspicuous locations within the company, established unobstructed grievance channels (suggestion boxes and publicized the contact numbers of local labor regulatory authorities), providing our employees with the opportunity to voice their opinions and feelings about their work. The company strictly enforces the "Labor Law of the People's Republic of China" and various regulations issued by the Shenzhen Federation of Trade Unions. There is no occurrence of any forced labor. The company's "Employee Handbook", "Attendance and Leave Management System", and "Anti-Forced Labor Policy" clearly stipulate that all employees shall not work more than 40 hours per week, all employees are required to sign a "Labor Contract" as mandated by the national labor department, and all employees are enrolled in social insurance as per regulations:

The company's "Employee Handbook" stipulates that all employees:

1. Voluntary employment: All employees must voluntarily choose employment, and employees must not be recruited by deception, coercion or other illegal means, and employees have the right to leave their jobs freely at any time without paying liquidated damages or other fees.

2. Prohibition of Document Seizure: It is strictly forbidden to seize employees' identification documents, passports, or other personal items.

3. Reasonable Compensation and Benefits: Employee compensation must meet the local minimum wage standards and be paid in full and on time. Deduction of wages or fines in any form is prohibited.

4. Working Hours and Rest: Employee working hours must comply with local legal regulations, forced overtime is prohibited, and employees should enjoy at least one day off per week.

5. Health and Safety: Provide a safe and healthy working environment to ensure the physical and mental health of employees.

6. Employees have the right to freely associate and collectively bargain.

7. The company shall not engage in any form of discriminatory employment practices (such as gender, race, religion, etc.).

8. The company has established an employee complaint mechanism and protects complainants (in 2024, the company did not receive any employee complaints).

In 2024, we formulated the "Policy and Procedures Prohibiting the Use of Forced Labor" and compiled the "Supplier Human Rights Due Diligence Questionnaire" according to the procedures. The questionnaire covers: 1. Whether the supplier's employees are voluntarily employed; 2. Whether the supplier prohibits the seizure of employee documents; 3. Whether the supplier's employees enjoy reasonable compensation and benefits and whether labor remuneration is paid in full and on time; 4. Whether the working hours and rest of the supplier's employees comply with the requirements of the "Labor Law of the People's Republic of China"; 5. Whether the supplier provides a safe and healthy working environment to ensure the physical and mental health of employees; 6. Whether the supplier's employees have the right to freely associate and collectively bargain; 7. Whether the supplier engages in discriminatory employment practices (such as gender, race, religion, etc.); 8. Whether the supplier has established an employee complaint mechanism and protects complainants. The "Supplier Human Rights Due Diligence Questionnaire" requires suppliers to fill in and sign in writing.

The compliance team members of the company's business department use emails, chat software, or telephone to investigate the implementation of anti-forced labor and human rights by suppliers in different regions, while conveying the requirements of prohibiting the use of forced labor and LBMA's human rights requirements to the respondents. The company's compliance team members conducted a risk assessment of forced labor and a human rights investigation on all gold/silver suppliers of the company through telephone interviews, chat software communication, or on-site visits with suppliers (customers), or by inquiring with personnel who have close contact with suppliers.

       The investigation covers the scenarios of forced labor as outlined in the "Policy and Procedures Prohibiting the Use of Forced Labor," such as: the company prohibits any actions that restrict labor freedom,such as seizure of identity documents, collection of deposits or collateral, seizure of workers' wages, forced body search, restrictions on workers' access to factories and forced overtime; The company does not use or support the use of any form of forced labor, including prison labor, contract labor, debt-paying labor, slave labor, forced or involuntary labor by means of punishment or intimidation; Managers at all levels, including security guards and managers, shall not be forced to search, work overtime, restrict employees' freedom of movement or intimidate, beat or scold employees. Security personnel are only responsible for maintaining the normal work and life order of the company and protecting the property and personal safety of the company and employees. Security personnel or management personnel shall not force or intimidate employees. The responsibility of security personnel is to protect the safety of personnel and property of the whole company, not to restrict employees' movement or force employees to work.

       Through due diligence on the forced labor risks of suppliers, we have determined that our suppliers are distributed across low-risk regions in China, including Anhui Province, Beijing Municipality, Shanxi Province, Fujian Province, Gansu Province, Guangdong Province, Guangxi Autonomous Region, Hebei Province, Henan Province, Inner Mongolia Autonomous Region, Hubei Province, Hunan Province, Jiangsu Province, Jilin Province, Liaoning Province, Shangdong Province, Zhejiang Province, Sichuan Province, Shanghai Municipality, Shanxi Province, Yunnan Province, Tianjin Municipality, and Shenzhen City.

       In the year 2024, there were a total of 619 gold and silver suppliers, including 348 corporate gold suppliers and 217 individual gold suppliers; 28 corporate silver suppliers and 16 individual silver suppliers. The raw materials provided are old gold and silver jewelry, unsold gold and silver ornaments, crafts, and decorative items from exhibition halls and stores. The company has queried public websites such as the National Enterprise Credit Information Publicity System and the Qichacha APP, and found no information on violations of the "Labor Law of the People's Republic of China" or forced labor among all corporate entities.

Through the above-mentioned written and random surveys and other comprehensive methods, a "Risk Assessment Report on Forced Labor" has been compiled, and no risks of forced labor among suppliers have been identified.

Part IV: Conclusion.

Our company has implemented effective management systems, procedures, processes and practices in the annual report for the year ending December 31, 2024, which has met the requirements of the LBMA Responsible Gold/Silver Guidance. Our company is committed to continuous improvement and will regularly monitor all corrective measures found internally. Continuously meet the requirements of LBMA responsible gold/silver Guidance.

Other

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