GoldBod Responsible Sourcing and Supply Chain Sustainability Policy

#### 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, GoldBod 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 GoldBod provides mandatory training on due diligence, AML/CFT, and ESG compliance to all employees, agents, and partners. ### 9\. Anti-Bribery and Corruption Policy GoldBod 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 - GoldBod 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 GoldBod 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 GoldBod 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 GoldBod 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 GoldBod. Non-compliance may result in termination of contract or legal action. [](https://goldbod.gov.gh) The Ghana Gold Board **(GoldBod)** is the sole authority with exclusive rights to buy, sell, weigh, grade, assay, value and export gold and other precious minerals in Ghana. ##### Contact us ** info@goldbod.gov.gh ** Goldbod Head Office, 7 Thorpe Road, Accra, Ghana ** +233 030 295 3279 / 84 ##### Company - [About us](https://goldbod.gov.gh/about-us) - [Licensing](https://goldbod.gov.gh/licensing) - [Right to information](https://goldbod.gov.gh/right-to-information) - [CSR](https://goldbod.gov.gh/corporate-social-responsibility) Copyright © 2026 Ghana Gold Board. All Rights Reserved [**](https://web.facebook.com/Ghanagoldbodofficial) [**](https://www.instagram.com/ghanagoldbod/) [**](https://x.com/GhanaGOLDBOD) [**](https://www.linkedin.com/company/ghanagoldbod/) [**](https://www.tiktok.com/@ghanagoldbod?_r=1&_t=ZS-99Q13PIRzuf) [**](https://www.youtube.com/@GhanaGoldBoard) [**](https://whatsapp.com/channel/0029VaOvrdHDZ4LWCCh7SK2e)