CORPORATE OVERVIEW

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Corporate Infrastructure, Scope of Operations & Philosophy: TRAWW, Ltd.’s structure maximizes operational efficiencies as a privately-owned smelting company (SIC 3339) with its focus on precious metals. TRAWW is not a toll smelter; rather, it processes only ore it owns or controls. Further, TRAWW on request, intermediates precious metal as a service, to a select set of established sovereign and corporate counterparties, engaging only with well documented grandfather stocks in Europe, the Middle East, and Asia to acquire same for further refining and or hall marking of said grandfathered stocks as defined by the Organization for Economic Co-operation and Development (“OECD”) as well as out of compliance London Bullion Market Association (“LBMA”) bullion (hereinafter collectively referred to as (“Doré”) on a worldwide basis in compliance with all applicable legal and regulatory regimens. TRAWW does not trade in physical nor securitized precious metals and as such maintains no trade desk nor capacity in this regard. TRAWW maintains refining, banking, transport, insurance, relationships worldwide. These relationships, informed by unrivaled infrastructure, capacity and experience allow TRAWW to provide counter-parties with professional goal-oriented compliant service.

TRAWW operates globally and takes pride in its continent-spanning reputation for integrity and honesty. It is essential that TRAWW employees, counter-parties and all those associated with TRAWW, protect that reputation. Money laundering, bribery and corruption are criminal offenses. In addition to the fines, penalties and reputational harm that TRAWW may suffer, such activities can lead to untoward human rights abuses and conflict financing. Employees, counterparties and all those associated with TRAWW involved in money laundering, bribery and corruption will be terminated. Third parties doing business with TRAWW are expected to comply with all applicable laws and adhere to our policies and contract provisions relating to the prevention of money laundering, bribery and corruption. As a leader in the precious metal smelting supply chain, TRAWW recognizes it is uniquely positioned to detect and prevent commercial activities that contribute ton illegal activities. TRAWW works with its employees and counter parties to ensure they are aware of our policies and procedures and that the materials intermediated by TRAWW do not contribute to such illegal activities.

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ANTI-MONEY LAUNDERING, BRIBERY AND CORRUPTION POLICY

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Internal Controls, Procedures & Compliance Management: TRAWW’s integrated anti-money laundering (“AML”), know our customer (“KYC”) and chain of custody (“COC”) policies, procedures and internal controls are designed to ensure compliance with all applicable statutes, regulations and rules and are reviewed and updated on a regular basis. TRAWW employs on boarding procedures to insure its understanding of the nature, scope, motivation and provenance of those with whom it engages. TRAWW’s Management regularly reviews TRAWW’s policies, procedures and internal controls with professional international audit, taxation and legal counsel to ensure their ongoing efficacy. Further, TRAWW submits to external periodic independent audit of its compliance regimen. TRAWW’s management is vested with responsibility for enforcement and as such a working knowledge of the OECD Chain of Custody Policies, LBMA and World Gold Council Protocols as well as familiarity with related statutory regimes including but not limited to: The foreign corrupt Practices Act; The Drug Trafficking Offenses Act 1986, The Criminal Act 1988, the Prevention of Terrorism (Temporary Provisions) Act 1989, The Criminal Justice (International Co-operation) Act 1990, The Criminal Justice Act 1993, and the Money Laundering Regulations 1993 as amended. Accordingly, TRAWW complies with law enforcement requests for information as well as all validly issued orders of courts of competent jurisdiction. Moreover, if TRAWW uncovers suspicious activity during our risk assessment and review, we will elevate that risk assessment in compliance with relevant statutory regimes.

 

Monitoring, Zero-tolerance, Training & Records: TRAWW monitors the provenance of all precious metals transiting any phase of its intermediation services to ensure compliance. TRAWW is committed to a zero-tolerance approach to money laundering, bribery and corruption and will: (i) conduct all our business dealings and relationships in a fair, honest, and ethical manner; (ii) adhere to all applicable national and international laws and regulations relevant to countering money laundering, bribery and corruption; (iii) implement and enforce effective systems to counter the risk of money laundering, bribery and corruption; and (iv) prohibit the use of its businesses and services for money laundering, bribery, corruption or other illegal activities conducted through commercial transactions. If a potential or existing Counter-Party either refuses to provide the information requested, or appears to have intentionally provided misleading information, TRAWW will terminate engagement with that entity or individual TRAWW maintains AML, KYC and COC documentation regarding each counter-party and transaction. TRAWW maintains ongoing employee training under the leadership of a designated Compliance Officer TRAWW’s training is based on its policies, procedures and internal controls as well as applicable statues and regulations. TRAWW’s training addresses: (i) identification of red flags; (ii) action upon risk identification, (iii) employees’ roles in compliance efforts; (iv) record retention; and (v) disciplinary consequences of non compliance.

 

CHAIN OF CUSTODY POLICY

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Chain of Custody Regimen: TRAWW participates in the worldwide effort to ensure that precious metals come from legitimate and ethical sources. Toward this end, TRAWW cooperates with both law enforcement and its supply chain industry transportation, insurance, banking and refining counter-parties as well as industry organizations such as the OECD, LBMA and World Gold Council.

To ensure that the precious metals have not been associated with criminal or terrorist activity, human rights abuse or armed conflict TRAWW implements its COC policy through a comprehensive set of management systems and procedures. These procedures implement the general standards of business conduct set forth above, as well as setting forth internal compliance standards that comport with applicable statues and regulations. TRAWW’s procedures govern not only our internal corporate conduct and culture; they also govern TRAWW’s interaction with counter-parties and government agencies. These procedures penultimately find voice in rigorous contractual negotiations and clearly drafted agreements with all of TRAWW’s counter-parties that both drive compliance and clearly set forth the wages of noncompliance.

 

Chain of Custody Documentation: TRAWW maintains internal legal counsel as well as specialized external legal professionals for international regulatory, corporate, tax, and litigation matters. TRAWW counter-parties engage TRAWW services and infrastructure exclusively through written agreements. It is through the integrated AML, KYC and COC procedures mandated by these agreements that TRAWW’s compliance regimen is both enforced and documented.

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Legal, Compliance & Logistical Coordination: All TRAWW purchase, sale, and transport agreements with counter-parties are subjected to both legal and compliance risk evaluation. Accordingly, TRAWW counter-party ore acquisition agreements routinely require and attach documents as required, including but not limited to: (i) mining licenses; (ii) mining inspection reports and compliance, certifications, (ii)export licenses; (iii) certifications of payment of taxes and duties; (iv) declarations of ethical standards, (v) principal and signatory passports, (vi) insurance coverage, (vii) LBMA refinery assay and or hallmark certifications and (viii) engagement of secure LBMA transport.