NAPLES PRIME CORPORATE COMPLIANCE POLICY CONDUCTING THE BUSINESS ACCORDING TO DUE DILIGENCE AND COMPLIANCE MEASURES TO PROMOTE GREATER ACCOUNTABILITY

 

At NAPLES PRIME LLC we firmly believe that compliance is our license to operate worldwide. We all share the aim of providing our customers, suppliers, and partners with innovative solutions that improve the quality of life.

 

Taking into consideration that minerals, but particularly Gold supply chains are complex and risky, making transparency challenging, requesting due diligence in the supply chains to identify, assess and address all kinds of risks.

 

What does Naples Prime do to acknowledge Due Diligence?

 

We work daily to create the enabling conditions in our company to exercise due diligence over the gold supply chain in accordance with internationally recognized frameworks, including the OECD Minerals Due Diligence Guidance overall and the Supplement on Gold in particular.

 

Since Naples Prime LLC got into the minerals business, due diligence became its priority, developing numerous actions, programs, and commitments to audit all of the supply chains, starting from the miners and finishing with the export of the minerals to refineries and worldwide clients. Encouraging responsible sourcing of gold, especially on the artisanal and small-scale gold mining (ASGM) level.

 

Our company has been developing among some, the following programs, tools, and resources to support their due diligence on gold supply chains:

• Mapping the supply chain using the national and international recognized frameworks, as well as all of the legal mandates;

• Consulting the list of active gold refiners and conformant gold refiners to learn about entities that undergo an independent third-party assessment in accordance with the Responsible Minerals Assurance Process.

• Developing permanent training sessions for the members of our company, as well as our suppliers and gold refiners on due diligence in gold supply chains.

• Implementation of a legal framework to assure due diligence, including anti-money laundering measures adopted by Colombian and US Authorities (SAGRILAFT); review of the legal framework (LBMA) for the safe and good commercial of minerals (due diligence implemented by London Association); plus a number of upstream assurance mechanisms

• Implementation of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, as well as CRAFT (Code of Risk mitigation for Artisanal and small-scale mining engaged in Formal Trade), the Alliance for Responsible Mining, the Public-Private Alliance for Responsible Minerals Trade (PPA) and Solidaridad’s improvement program for small-scale mining, among some.

 

NAPLES PRIME LLC actively supports and encourages member involvement in initiatives that create economic and development opportunities for artisanal and small-scale miners in the social, environmental, and labor issues, taking into consideration that gold miners are highly mobile and that their operations are mainly informal. Changing circumstances in artisanal gold mining make it challenging for upstream assurance mechanisms to implement robust systems of compliance and due diligence on all of the artisanal and small scale miners, which are one of the most important suppliers of Naples Prime gold and other minerals that are exported to the U.S. and Europe.

 

Why is Corporate Compliance Policy important for NAPLES PRIME LLC?

 

Naples Prime LLC Corporate Compliance Policy outlines the company’s principles of business conduct and defines the boundaries within which our employees, suppliers, and partners must act in the gold supply chain in compliance with local and international laws, regulations, and internal policies. Doing so protects Naples Prime LLC, our suppliers, and allies from money laundering, illegal mining, and each of us. This Policy does not cover every situation we may encounter. However, it is our compass for acting with integrity and observing the principles of the founders of our company, based on legal observation, responsibility, ethics, transparency, accountability, respect, and good judgment. So as to prevent and address all the risks associated to gold and mineral activities as they arise.

 

Cooperating with Authorities in the aim to prevent Illegality and Money Laundering

 

Naples Prime LLC employees make daily every effort to cooperate with government authorities and national, regional and local agencies in respecting and accomplishing all legal regulations, regarding the minerals and gold supply chain, including providing them with company information, as well as from our suppliers and partners.

 

Why Is Our Compliance Policy so Important?

 

Naples Prime LLC Corporate Compliance Policy outlines our principles of business conduct as well as from our employees, feeling pride in doing things right, with social and environmental criteria based on good judgment, acting with integrity, and observing the principles of our policy.

Naples Prime Corporate Compliance Principles

 

Some of our main compliance principles are:

 

We act with integrity in all our business dealings

 

OUR COMMITMENT: NAPLES PRIME LLC does not tolerate corruption and will refuse any business opportunity that involves any form of bribery, corruption, money laundering, or any illegal activity. We never offer or give a benefit to try – or even give the appearance of trying to wrongfully influence someone else’s decision, action or point of view.

 

We conduct business with reputable parties and suppliers who engage in legitimate business activities regarding mining. To help ensure compliance, we follow all local and international laws designed to prevent money laundering. Additionally, NAPLES PRIME LLC will not do business nor have any kind or relationship with individuals or entities sanctioned for having a past or ongoing association with criminal or terrorist activities, or who have any kind of legal, tax or disciplinary sanction, nor with those that have had illegal procedure of its assets or of its activities.

 

We balance economic growth with ecological and social responsibility

 

OUR COMMITMENT: NAPLES PRIME LLC endeavors to develop, produce and sell products in a safe and sustainable way that meets the needs of our employees, customers and society, and protect the environment, particularly against any kind of threat against the environment, particularly regarding the use of mercury or any type of component that affects water, oxygen, rivers, etc.

 

We observe trade controls that regulate our global business

 

OUR COMMITMENT: NAPLES PRIME LLC obeys all trade controls at a local and international level, so as to perform its activity under legal frameworks

 

We keep accurate books and records

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OUR COMMITMENT: NAPLES PRIME LLC fully and accurately records its business activities and financial transactions to provide a fair and complete view of its operations, assets and financial condition.

 

We protect and secure personal data

 

OUR COMMITMENT: NAPLES PRIME LLC strictly adheres to the local laws designed to protect and secure the privacy and confidentiality of information about individuals and enterprises, including personal, health, family financial and similar information.

 

Steps Naples Prime has taken to support Artisan and Small Miners as the basis of its business

 

Taking into consideration NAPLES PRIME LLC business in mining, its main actions rely on artisan and small miners, and for its benefit and accomplishing the goal of obedience to the law, we:

1. Support responsible gold sourcing opportunities and livelihood opportunities in mining communities with financial investment and public support, especially for those miners members of indigenous communities established in conflict-affected and high-risk areas

2. Improve and support public and private reporting on supply chain due diligence.

3. Conduct continuous due diligence, in addition to investment in supporting responsible and legal sourcing.

4. Support the due diligence measures for smelters and refiners to conduct mine-level assessments, including artisan and small miners gold sites, facilitating sourcing from conflict-affected and high-risk areas where upstream mechanisms are not present.

 

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