Compliance

Organization for Economic Cooperation and Development
The Organization for Economic Cooperation and Development (“OECD”) is an association of governments that work with each other to promote economic growth, prosperity, and sustainable development. The OECD allows governments to work together to solve common problems, identify good practices and coordinate domestic and international policies.The OECD has issued its Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “Guidance”). Its objective is to help organizations respect human rights and to avoid contributing to conflict-heavy jurisdictions. Accordingly, Metals House has implemented internal policies that adhere to the OECD Guidance.

Financial Action Task Force
The Financial Action Task Force (“FATF”) is an inter-governmental body established by its member jurisdictions with the objective of setting standards and promoting the effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other threats related to the integrity of the international financial system. The FATF has developed a series of recommendations that are recognized as the international standard for the combating of money laundering, the financing of terrorism and proliferation of weapons of mass destruction.  The FATF issued its 40 Recommendations (the “Recommendations”), a comprehensive and consistent framework of measures for combating money laundering and terrorist financing. Metals House has implemented the Recommendations and has adopted internal know your client (KYC) due diligence procedures to safeguard against money laundering and terrorist financing.

In addition, Metals House is further regulated in the jurisdictions in which it does business, including the Dubai Multi Commodities Center (“DMCC”), the United Arab Emirates, Hong Kong, Brazil, and the United States. Accordingly, Metals House is subject to the various U.S. federal regulations which include the SEC and the Dodd-Frank Act.

Finally, Metals House only conducts business with refiners that meet the standards to be on the London Bullion Market Association Good Delivery List.