Responsible Supply Chain Policy for Precious Metals

PRECIOUS METALS RESPONSIBLE SUPPLY CHAIN COMPANY POLICY

1. INTRODUCTION

As Kâr Katılım Gold Refinery Inc. (“Kâr Katılım”, “Company”), we are aware of the significant potential adverse impacts associated with the extraction, trading, handling, and export of precious metals from conflict-affected and high-risk areas. We recognize our responsibility to prevent money laundering and the financing of terrorism, to avoid contributing to conflicts, to prevent the financing of the proliferation of weapons of mass destruction, to combat bribery and corruption, to comply with local legislation, and to respect human rights and the environment.

In this context, we commit to:

Adopting and disseminating this policy to a wide audience as a common reference for suppliers' risk awareness, in compliance with responsible supply practices from the point of extraction to the end user;
Refraining from any action that contributes to the financing of conflict and complying with relevant United Nations sanctions, European Union, UK Treasury, and US Treasury sanctions, FATF recommendations and decisions, and domestic legal rules implementing these decisions to the extent applicable;
Ensuring that while performing our activities, we activate our strong management system and observe our national and international responsibilities regarding sustainability, environmental, social, and governance (ESG) issues, with a sense of social responsibility.

This Precious Metals Supply Chain Company Policy (“Policy”) has been prepared within the framework of Annex II of the Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and the requirements of Borsa İstanbul’s (BIST) Responsible Supply Chain Compliance Guide.

2. PURPOSE AND SCOPE

This policy has been prepared to share with suppliers the core principles, values, and references derived from domestic law and international regulations adopted by Kâr Katılım, and to serve as a guide in establishing and maintaining business relationships.

All employees and managers of Kâr Katılım are responsible for complying with this Policy and for implementing and supporting Kâr Katılım’s relevant procedures. Kâr Katılım expects its external stakeholders and business partners to act in accordance with this policy.

This policy consists of the following sections:

Organization and Responsibilities
Identification and Assessment of Risks
Criteria for High-Risk Supply Chains
(Know Your Customer) Principle and Supply Chain Due Diligence
Traceability of Transactions
Record Keeping of Supply Chain Due Diligence
Training
Our Commitments
Conclusion

A. Organization and Responsibilities

Conscious of its responsibilities, Kâr Katılım places great importance on ensuring that precious metals originate from legal sources. In this regard, Kâr Katılım pays the utmost attention to the following matters and maintains strict practices while conducting its activities:
Kâr Katılım commits to ensuring compliance with the following regulations, which are listed but not limited to, by establishing a comprehensive management system with an investigation and control-oriented organization at every stage of its precious metals activities, and to updating its policies and procedures accordingly:
- OECD, Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
- Borsa İstanbul A.Ş., Responsible Supply Chain Compliance Guide
- Borsa İstanbul A.Ş., Responsible Supply Chain Compliance Directive
- Borsa İstanbul A.Ş., Directive on Internal Control System and Compliance Principles for Precious Metals Intermediary Institutions and Refineries
- Regulation on the Principles of Activity of Precious Metals Exchange Intermediary Institutions and the Establishment of Precious Metals Intermediary Institutions
- Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism
- Regulation on Program of Compliance with Obligations Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism
Kâr Katılım conducts its activities by observing its commercial reputation, adopting rules of honesty, and high moral, ethical, and social values; it enters into commercial relationships only with legitimate and law-abiding business partners.
Kâr Katılım has established an organizational structure and an internal control system to ensure that all its business and transactions are carried out regularly, efficiently, and effectively in accordance with management strategies and policies within the framework of existing legislation and rules. This includes ensuring the integrity and reliability of accounting and recording systems, the timely and accurate availability of information in the data system, the creation, backup, and preservation of document and record systems, and the prevention and detection of errors, fraud, and irregularities.

B. Identification and Assessment of Risks

Kâr Katılım identifies and assesses its risks within the scope of the Responsible Supply Chain.

In this context, it considers the existence of the following matters, including but not limited to:

Widespread human rights violations that may occur during the extraction, transport, or trade of precious metals (including but not limited to torture, cruel, inhuman, and degrading treatment, forced and compulsory labor under threat of punishment, the worst forms of child labor, widespread sexual violence, and other major human rights violations, war crimes, crimes against humanity, and genocide). Sourcing minerals from or making payments to non-state armed groups or their affiliates, or providing them with logistical aid or equipment by other means. Bribery and corruption. Misrepresentation of the origin of the precious metal. Contributing to conflicts. Prevention of money laundering and financing of terrorism. Prevention of the financing of the proliferation of weapons of mass destruction. Countries that do not have sufficient regulations on the prevention of terrorism financing and money laundering, do not cooperate sufficiently in combating these crimes, or are considered risky by authorized international organizations (countries announced by the Ministry and their citizens, companies, and financial institutions). Non-payment of taxes, fees, and royalties related to the extraction, trade, and export of precious metals from Conflict-Affected and High-Risk Areas (CAHRA).

The processes related to the identification and early detection of risks that may jeopardize the existence, development, and continuity of the Company and its supply chain, the assessment of identified risks, the implementation of necessary measures, and the management of risks are detailed in the Company's written procedures.

Kâr Katılım has established an effective internal control system within the scope of risk assessment. In this regard, monitoring and control activities are ensured, and transactions are examined with a risk-based approach to verify whether they are carried out in accordance with relevant legislation, guides, company policies, and procedures.

In the event of a serious suspicion, finding, or determination that the matters specified under “Organization and Responsibilities”, “High-Risk Criteria”, and “Our Commitments” in this Policy have been abused or violated, relations with our suppliers are immediately suspended or terminated.

Kâr Katılım may develop an effective risk mitigation plan for shortcomings or high-risk elements identified within the scope of risk management. This plan may include measurable improvement planning for business partners, potentially in cooperation with local and central authorities, international organizations, and non-governmental organizations where appropriate. If a significant measurable improvement in preventing or reducing the risk is not achieved within six months after the creation of this plan, the commercial relationship is suspended or terminated. Along with the suspension, a revised risk management plan specifying performance targets for gradual progress required before the resumption of the commercial relationship is prepared.

Risk assessment and internal control activities are carried out by the internal control and supply chain compliance officer. This includes reporting risks, deficiencies, errors, and abuses identified within the framework of responsible supply chain policies and procedures, other company policies, and other legislation and guides, along with measures to prevent their recurrence, to the Board of Directors. These activities related to risk management, monitoring, and control are performed under the supervision and audit of the Board of Directors.

C. Criteria for the Supply Chain of High-Risk Precious Metals

In transactions related to precious metals carried out within the scope of its field of activity, Kâr Katılım considers the red flags determined in accordance with Borsa İstanbul’s responsible supply chain program, along with its written procedures established with a risk-based approach, to determine whether a high-risk supply chain exists.

D. Know Your Customer Principle and Supply Chain Due Diligence

Kâr Katılım acts in accordance with the “Know Your Customer Principle” in all processes from the beginning to the end of the commercial relationship with its suppliers. The customer recognition process covers the identification, assessment, and monitoring of all elements in the supply chain, starting from the source of the precious metals. Kâr Katılım has a procedure that adopts a risk-based approach and ensures the monitoring of transactions to ensure due diligence.

Kâr Katılım transparently operates strong internal investigation, control, and traceability systems starting with the identification of precious metal supply chain actors. In this context, suppliers are requested to provide information and documents related to their activities, market areas, products and services, payment methods, the origin and forms of the precious metals they supply, and other relevant information within the scope of legislation and guides, along with Know Your Customer (KYC) forms.

Before entering into a business relationship with both current precious metal suppliers and new/potential suppliers, Kâr Katılım checks the information and documents obtained within the scope of Know Your Customer. Kâr Katılım requests additional information/documents from suppliers for enhanced due diligence in a risky situation identified according to the risk criteria determined within the scope of the responsible supply chain. Assessments regarding customer recognition and customer risks throughout the supply chain are followed throughout the duration of the business relationship, and customer information is updated at certain intervals.

E. Traceability of Transactions

Kâr Katılım appropriately examines and monitors transactions with a risk-based approach to confirm that transactions performed and/or to be performed throughout the supply chain are consistent with the supplier's risk profile.

Monitoring activities include, at a minimum but not limited to, the following:

Monitoring and control of customers and transactions in the high-risk group.
Monitoring and control of transactions carried out with risky countries.
Monitoring and control of complex and unusual transactions.

F. Record Keeping of Supply Chain Due Diligence Records

Records related to the necessary information and documents regarding the supply chain are kept for at least 8 years.

G. Training

The internal control and supply chain compliance officer is responsible for organizing training programs. In this context, minimum levels of training are provided on relevant subjects based on need, including but not limited to the following:

Exchange legislation and practice
Concept of Conflict-Affected and High-Risk Areas and other Compliance Guide concepts
Legislation regarding the responsible supply chain, responsible supply chain steps, and case studies on this subject
Risk areas
Company policy and procedures
Principles regarding Know Your Customer within the framework of exchange regulations and other relevant legislation, principles regarding notifications to be made to relevant institutions and organizations, obligation of preservation and submission, obligation to provide information and documents, and sanctions to be applied in case of non-compliance with obligations
International regulations in the field of combating money laundering and the financing of terrorism.

If deemed necessary, support may be obtained from expert trainers.

H. Our Commitments

As Kâr Katılım, we strive to prevent harm to people and/or the environment and operate with a sense of social responsibility and the protection of environment and human health.

When sourcing from or operating in conflict-affected and high-risk areas, we will in no way tolerate, contribute to, assist, profit from, or facilitate torture, cruel, inhuman, and degrading treatment, forced and compulsory labor, the worst forms of child labor as defined in ILO Convention No. 182, human rights violations and abuses, widespread sexual violence, war crimes, violations of international human rights law, and crimes against humanity or genocide.

If we identify a reasonable risk that our supplier is committing the abuses described above or has a relationship with any party committing or connected to such abuses, we will suspend or immediately terminate our commercial relationship with these persons.

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. We will not tolerate any direct or indirect support to non-state armed groups including, but not limited to, sourcing minerals from or making payments to these groups or their affiliates, or providing them with logistical aid or equipment by other means. In this context, we will not tolerate direct or indirect support through non-state armed groups for matters including but not limited to:
- Controlling mine sites, transport routes, points where precious metals are traded, and upstream actors in the supply chain;
- Illegal taxation of or extortion from money or precious metals at access points to mine sites, along precious metal transport/logistics routes, or at locations where precious metals are traded;
- Illegal taxation of or extortion from intermediaries, export companies, or international traders.

We will not tolerate this under any circumstances.

If we identify a reasonable risk that our suppliers are sourcing minerals from or making payments to non-state armed groups or their affiliates, or providing them with logistical aid or equipment by other means, we will suspend or immediately terminate our commercial relationship with these persons.

We commit to eliminating direct or indirect support to private or public security forces that illegally control mine sites, transport routes, or upstream actors in the supply chain; or that illegally collect taxes or extort money or minerals at access points to mines, along transport routes, or at locations where minerals are traded.
We recognize that the role of private or public security forces is solely to protect human rights in and/or around mine sites and/or along transport routes, to ensure the safety of mine workers, equipment, and facilities, and to prevent interference with the mine site or transport routes.
As Kâr Katılım, if we or any company in our supply chain contracts with public or private security forces, we commit to adhering to voluntary principles on security and human rights or to making efforts to ensure that the security forces we contract with comply with these principles. In particular, we will support screening policies aimed at ensuring that individuals or security force units known to be responsible for gross human rights violations are not hired, and we will take steps toward establishing such policies.
As Kâr Katılım, we will support efforts and take steps to work with central or local authorities, international organizations, and non-governmental organizations to contribute to viable solutions on how to improve transparency, proportionality, and accountability in payments made to public or private security forces for ensuring security.
Due to our specific position in the supply chain, in cases where we determine a reasonable risk that direct or indirect support is being provided to public or private security forces, we will immediately create and implement a risk management plan together with upstream suppliers and other stakeholders to prevent or reduce this risk. In such cases, if initiatives to reduce the risk fail within six months following the creation of the risk management plan, we will suspend or terminate our commercial relationship with upstream suppliers.
As Kâr Katılım, we will not offer, promise, or demand bribes to hide or cover up the true origin of minerals, or for the extraction, trade, transport, and export of precious metals, or for the misrepresentation of taxes, fees, and royalties paid to states, and we will resist bribery demands.
As Kâr Katılım, in cases where we reasonably identify a money laundering risk arising from illegal taxation or extortion of minerals at access points to mine sites, along transport routes, or at points where minerals are traded by upstream suppliers as a result of or in connection with activities related to the extraction, trade, handling, transport, or export of precious metals, we will support efforts to effectively prevent money laundering and take steps to contribute to its prevention.
As Kâr Katılım, we will ensure that all taxes, fees, and royalties related to the extraction, trade, and export of minerals in conflict-affected and high-risk areas are paid to states, taking international standards into account.
As Kâr Katılım, due to our specific position in the supply chain, we commit to cooperating with suppliers, central or local government authorities, international organizations, non-governmental organizations, and affected third parties to prevent or reduce the risk of adverse impacts through measurable steps taken according to a reasonable timeline. If initiatives to reduce the risk fail, we will suspend or terminate our transactions with upstream suppliers.
As Kâr Katılım, we will immediately suspend or terminate our commercial relationship if we identify a reasonable risk that our suppliers are providing direct or indirect support to non-state armed groups and/or are sourcing goods from a party that provides such support and/or are connected to such a party.
Kâr Katılım ensures that payments related to the sale of precious metals are made through official bank channels. Any payment involving Kâr Katılım made in cash outside of a bank is only possible with the approval of Senior Management and if the information regarding the payment is reliable and verifiable.

Kâr Katılım adopts a “zero tolerance” principle regarding, but not limited to, the following:

If we identify a reasonable risk that our suppliers are sourcing precious metals mined from areas declared as “World Heritage Sites” by UNESCO, we will immediately terminate our commercial relationship with these persons.
In the event that it is determined that mined or recycled precious metal has been obtained in violation of international sanctions (including but not limited to United Nations, European Union, UK Treasury, US Treasury, and FATF sanctions), we will never enter into a business relationship.
We will not tolerate business partners, upstream companies, and/or their ultimate beneficiaries involved in mining precious metals or recyclable precious metals engaging in money laundering, fraud, terrorism, gross human rights violations, or providing direct and/or indirect support to non-state armed organizations.

I. Feedback from Interested Parties

Importance is attached to the feedback and opinions of interested parties regarding this Policy. Any feedback regarding the Policy can be reported through one of the following channels within the scope of the Whistleblowing Policy. Compliance with laws regarding the Protection of Personal Data is essential in these reports.

E-mail address: uyum@kargold.com
Address: Yarımburgaz Mah. 1. Cumhuriyet Cad. No:50/1
Küçükçekmece/İstanbul/Turkey
Phone No: +90 444 6 527

J. Conclusion

Responsible Precious Metals Supply Chain practices are a principle and obligation of Kâr Katılım. Employees of Kâr Katılım are obliged to act in accordance with all applicable laws and regulations, and Company policies and procedures. Kâr Katılım closely follows all developments related to the matters specified in this Policy and applies all updates made in national and international legislation and practice to its activities.

K. Effectiveness and Revision

The Board of Directors is authorized and responsible for updating this Policy as needed. Update studies regarding the Policy are carried out by the Compliance Unit and submitted for the approval of the Board of Directors.

Board of Directors Decision Date: 13.01.2026
Version No: V.0

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