LAST UPDATED 4 APRIL2025

AML & CTF POLICY & PROCEDURE

1. Introduction

Bale Capital Pty Ltd (referred to as “the Company”) recognizes the critical importance of implementing and maintaining robust AML and CTF measures to safeguard its operations and financial transactions against the risks of money laundering and terrorist financing. The Company is fully committed to adhering to the highest standards of compliance as required by international and domestic laws and regulations governing its activities, with a specific focus on its international trading practices, including the trading of precious metals.

2. Policy Statement

The Company hereby establishes a zero-tolerance stance against money laundering and the financing of terrorism. This policy mandates comprehensive and proactive measures to identify, prevent, and report any suspicious activities that may arise within the scope of its operations. It applies universally across all levels of the organisation, including its employees, officers, directors, and any third parties acting in its name.

3. Legal Framework and Compliance Obligations

This policy is structured to ensure full compliance with:

1. The United Nations Security Council resolutions 1173, 1176, and 1306 related to the trade of precious metals and stones, including gold and diamond, highlighting the importance of preventing illicit trade practices.
2. The Financial Action Task Force (FATF) Recommendations, providing an international standard for fighting money laundering and terrorist financing.
3. Domestic regulations such as the Bank Secrecy Act (BSA), the USA PATRIOT Act, and other applicable legislations and guidelines across the jurisdictions the Company operates in.
4. Additional international treaties, regulations, and best practices relevant to AML and CTF.

The Company will ensure that its compliance program is updated to reflect any changes in legislation or regulatory guidance.

4. Comprehensive Risk Assessment

A detailed risk assessment will be performed annually, or more frequently if significant changes occur within the business or regulatory environment. This assessment will:

1. Identify and evaluate the risks of money laundering and terrorist financing specific to the Company’s operations, including geographical risks, customer-based risks, and service/product-related risks.
2. Develop strategies to mitigate identified risks, including enhanced due diligence procedures for higher-risk categories.
3. Regularly review and adjust risk assessment methodologies to remain aligned with current threats and vulnerabilities.

5. Enhanced Know Your Customer (KYC) and Due Diligence Measures

1. Customer Identification Program (CIP): A robust CIP will be established to verify the identity of the Company’s customers using reliable, independent source documents, data, or information.
2. Due Diligence Procedures: These procedures will be tiered, ranging from standard due diligence for all customers to enhanced due diligence (EDD) for customers presenting a higher risk, such as those from high-risk countries, politically exposed persons (PEPs), and those involved in high-risk industries.
3. Ongoing Monitoring: Continual monitoring of business relationships and transactions will be enforced to identify and report any suspicious activities promptly. This includes monitoring for transactions that appear to have no apparent purpose or are unusually complex.

6. Detailed Record-Keeping Practices

The Company will maintain detailed records of all financial transactions, customer identification information, account files, and business correspondence for at least the minimum period required by law, ensuring the availability of this information for inspection by regulatory and law enforcement authorities as needed.

7. Reporting Obligations and Cooperation with Authorities

1. Suspicious Activity Reporting: A clear process for reporting suspicious activities internally and to the relevant authorities will be established. Employees will be trained to recognise signs of money laundering or terrorist financing and understand the procedure for reporting internally.
2. Compliance with Legal Requests: The Company commits to fully cooperating with law enforcement and regulatory bodies, providing requested information promptly and accurately in support of AML and CTF investigations.

8. Employee Training and Awareness Programs

A comprehensive training program will be developed and implemented to ensure that all employees are aware of the risks of money laundering and terrorist financing, understand the legal requirements, and know how to identify and handle suspicious activities. Training will be tailored to the role and level of risk exposure, with mandatory annual refreshers.

9. Continuous Policy Review, Audit, and Improvement

1. Regular Policy Reviews: The AML and CTF policy and procedures will be reviewed at least annually to ensure they remain effective and compliant with current laws and regulations.
2. Independent Audits: External audits by qualified third parties will be conducted periodically to assess the effectiveness of the Company’s AML and CTF measures and recommend improvements.

10. Leadership and Commitment

Senior management at Bale Capital Pty Ltd commits to providing the necessary resources and support to ensure the effective implementation of this AML and CTF policy, demonstrating the Company’s unwavering dedication to preventing its operations from being exploited for money laundering or terrorist financing activities.

Adherence to these guidelines is mandatory for all employees and associated parties.