Responsible Sourcing

Bright Gold Mining Inc Responsible Sourcing and Supply Chain Sustainability Policy

 

1. Introduction

The Ghana Gold Board (Bright Gold Mining Inc) is the exclusive national authority for buying, selling, assaying, grading, and exporting gold and other precious minerals in Ghana. This policy outlines Bright Gold Mining Inc’s commitment to responsible sourcing, ethical supply chain practices, and alignment with international best practices including the OECD Due Diligence Guidance, the London Bullion Market Association Responsible Gold Guidance, and Ghana’s regulatory frameworks.

2. Due Diligence Commitments

Bright Gold Mining Inc is committed to ensuring that all sourced gold originates from legitimate and ethical sources. We expressly reject and will not benefit from, contribute to, or tolerate:
  • Human rights abuses including torture, forced labour, and child labour
  • War crimes, crimes against humanity, and genocide
  • Bribery or kickbacks to any individual or organisation
  • Misrepresentation of product origin or evasion of taxes and royalties
  • Money laundering or terrorist financing activities
  • Environmental and labour law violations
We assess the ESG (Environmental, Social, Governance) practices of our suppliers and customers, including:
  • Regulatory compliance on environmental, health, and labour matters
  • Pollution control and hazardous chemical management
  • Community and labour relations including resettlement, cultural heritage protection, and fair labour practices

3. Due Diligence Framework

Bright Gold Mining Inc has instituted a robust due diligence framework to identify, assess, and mitigate risks associated with the acquisition and trading of gold. This framework is guided by international best practices and aims to ensure transparency, accountability, and integrity throughout the supply chain.

3.1 Governance Framework

The following governance structures and systems have been established to ensure effective implementation of our due diligence commitments:
  • A dedicated due diligence policy on gold acquisition
  • Defined management structures and transparent acquisition controls
  • Confidential grievance mechanisms

3.2 Risk Identification and Assessment

To proactively detect and assess risks in our supply chain, Bright Gold Mining Inc undertakes the following measures:
  • Detection of red and amber flags such as human rights violations, bribery, and chemical hazards
  • Enhanced due diligence for high-risk sources

4. Due Diligence Application Process

Each new aggregator, supplier, or off-taker must complete a comprehensive onboarding process to ensure KYC and AML/CFT compliance. This includes:
The onboarding process involves:
  • Meetings to collect operational and territorial details
  • Verification of relevant documentation from authorities
  • Security and financial background checks
  • On-site verification
  • Document retention for third-party verification and limitation periods

5. Supply Chain Risk Assessment

Based on onboarding documentation, each counterparty is assigned a risk profile (low, medium, high, extreme). Enhanced due diligence is conducted for high-risk categories, including site visits and ESG reviews. Approval or rejection is based on this risk-based approach.
Ongoing monitoring consists of:

6. Ongoing Monitoring and Traceability

Agent and Aggregators Responsibilities in Terms of Anti-Money Laundering Regulations.
  • Unique ID numbers are assigned to each supplier and lot of gold
  • All employees must report suspicious activity or changes in supplier information
  • Updates to supplier information must be authorised by senior management
  • Re-onboarding is required for suppliers inactive for over one year

7. Record Retention

Due diligence records must be securely stored for at least seven (7) years per the Limitation Act. This applies to both approved and rejected counterparties.

8. Training

Bright Gold Mining Inc provides mandatory training on due diligence, AML/CFT, and ESG compliance to all employees, agents, and partners.

9. Anti-Bribery and Corruption Policy

Bright Gold Mining Inc enforces a zero-tolerance policy against bribery and improper payments.
  • Bribery includes direct or indirect inducements to improperly influence actions
  • Improper payments include gifts, political donations, or sponsored travel intended to secure unfair advantage
  • Written approvals are required before engaging in high-risk interactions

9.1 Political Contributions

  • Bright Gold Mining Inc remains politically neutral
  • Employees may not contribute company resources to political entities

9.2 Hospitality and Gifts

  • Gifts must be of nominal value and pre-approved
  • Interactions with government officials require prior compliance approval

10. Anti-Money Laundering and Terrorist Financing

10.1 Policy Statement

Bright Gold Mining Inc implements measures to prevent its systems and operations from being used for money laundering or terrorist financing.

10.2 AML Responsible Party

  • A designated officer oversees AML/CFT compliance
  • Must be professionally competent and ethically sound

10.3 KYC and Customer Due Diligence (CDD) Obligations

Bright Gold Mining Inc will verify identity and gather full profile data on all agents, aggregators, suppliers, and employees. This includes:
  • Company details and legal documents
  • Beneficial ownership verification
  • Sanctions screening and foreign entity vetting

10.4 Employee Vetting

  • Mandatory police clearance
  • Lifestyle audits and suspicious behaviour monitoring

10.5 Supplier and Aggregator Registration

Aggregators must complete registration forms and submit physical identity verification

11. Conclusion

Bright Gold Mining Inc remains committed to sustainable and responsible sourcing of gold. Through this policy, we ensure traceability, transparency, and ethical practices aligned with global standards such as those of the OECD, World Gold Council, and Responsible Jewellery Council.

This Policy is binding on all staff, agents, aggregators, suppliers, and off-takers of the Bright Gold Mining Inc. Non-compliance may result in termination of contract or legal action.