Our Policies

Committed to Responsible Business

At Noble Metal Services, responsible business practices are at the core of what we do. We embrace our corporate and social responsibility and are committed to ensuring that our facility, equipment, and processes operate responsibly and efficiently. Our goal is to lead the precious metals recovery industry through safe, sustainable, and accountable practices.

Noble Metal Services of Cranston Rhode Island is aware of and actively supports the international efforts to investigate, monitor and mitigate activities that contribute to illegal armed groups, human rights violations, or financial wrongdoings in gold supply chains as defined in Annex II of the Organization of Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas Third Edition (OECD Guidance).

We respect the dignity and importance of human rights and consider any mineral that may pose risks of contributing the harm listed in Annex II of OECD Guidelines to be classified as ‘conflict minerals’.

Noble Metal Services will only purchase gold-containing materials from sources that have been verified as not involving or contributing to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of the OECD Guidance and listed here:

  • Serious abuses associated with the extraction, transport or trade of minerals:
    • Any forms of torture, cruel, inhuman and degrading treatment;
    • Any forms of forced or compulsory labor;
    • Any form of child labor;
    • Other gross human rights violations and abuses such as widespread sexual violence;
    • War crimes or other serious violations of international humanitarian law, crimes against humanity or genocide.
  • Direct or indirect support to non-state armed groups.
  • Direct or indirect support to public or private security forces.
  • Bribery and fraudulent misrepresentation of the origin of minerals.
    • Money laundering.
    • Non-payment of taxes, fees and royalties to governments.

In support of the above, our relevant staff members are directed to follow and be trained on procedures to implement a conflict minerals due diligence system that aims to:

  • Exercise due diligence with relevant suppliers consistent with the OECD Guidance and the Responsible Business Alliance’s Responsible Minerals Assurance Process (RMAP) and encourage our suppliers to do the same.
  • Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm gold in our supply chain does not contribute to illegal armed groups, human rights violations, or financial wrongdoings as defined in Annex II of OECD Guidance.
  • Strengthen long-term relationships with our immediate suppliers.
  • Consider ways to support and build capacities of gold supplying counterparties to improve performance and conform to this supply chain policy.
  • Suspend or discontinue engagement with upstream suppliers after failed attempts at mitigation.
  • Immediately discontinue engagement with suppliers who pose a reasonable risk to be causing severe human rights abuses.

Noble Metal Services communicates this sourcing policy to our suppliers and customers and make it publicly available for review on our website.

If through due diligence, we become aware that our customer is engaging in suspect practices that do not meet our responsible sourcing requirements, we would immediately suspend sourcing from the supplier and develop a plan for mitigation and risk. Should mitigation fail to resolve the issue, or we uncover further negative findings, Noble Metal Services would discontinue business operations with that supplier.

CAHRAs

Although Noble Metal Services does not source ore, concentrate or high-risk materials, we have established a process to identify risks in our supply chain as well as procedures to identify conflict-affected and high-risk areas (CAHRAs).

Noble Metal Services consults with various advisory organizations and agencies to continue to upgrade our practices and improve our processes to safeguard our supply chain from conflict materials. Noble Metal Services is committed to helping our customers/suppliers create and improve their own supply chain due diligence policies.

Noble Metal Services is committed to helping our customers/suppliers create and improve their own supply chain due diligence policies.

CAHRA’s listings – Dodd Frank and the EU Regulation 2017/821
Updated June 30, 2021

CAHRAs Dodd Frank Countries

DRC The Democratic Republic of the Congo
Angola
Burundi
Central African Republic
Republic of the Congo
Rwanda
South Sudan
Tanzania
Uganda
Zambia

The current indicative, non-exhaustive list of CAHRAs under Regulation (EU) 2017/821
The Americas: Mexico, Colombia and Venezuela;
Europe: Ukraine;
The Middle East: Yemen;
Africa: Burkina Faso, Burundi, Cameroon, Central African Republic, Chad, Democratic Republic of Congo, Egypt, Eritrea, Libya, Mali, Mozambique, Niger, Nigeria, Somalia, South Sudan, Sudan, and Zimbabwe;
Asia: Afghanistan, India, Myanmar, Pakistan and The Philippines.

Noble Metal Services publically affirms our commitment and respect for human rights. We demonstrate our commitment not only in words, but also in the actions we take. Our dedication to upholding human rights continues as an integral part of our socially-responsible business activities as we adhere to the following human rights tenets:

  • Promote a workplace environment where discrimination, harassment and persecution are not tolerated—regardless of a person’s race, color, religion, national origin, gender, sexual orientation, gender identity, age, physical ability, mental disability, and veteran status.
  • Promote equal opportunity employment for all qualified applicants.
  • Maintain an inclusive and diverse work environment for all employees.
  • Expect all employees to respect and honor the human rights of their fellow employees.
  • Maintain high standards for a safe and stable workplace.
  • Strive to deploy eco-efficiency methodologies that lessen our imprint on our local community.
  • Engage in business transactions only with customers that also affirm and respect human rights and responsible business practices.
  • Require the highest standards of ethical and business conduct within the process of procuring goods and services.
  • Require all employees to follow the ethical standards in our employee handbook in order to ensure our employees perform with honesty and integrity.
  • Invest in our community by utilizing financial and human capital.
  • Improve the quality of life in our neighborhood and the surrounding areas.

Noble Metal Services is fully committed to protecting our environment and we recognize that we have a corporate and social responsibility to ensure that our facility, equipment, and processes fully support our goal to be a leader in responsible environmental management.

Our Commitment to Sustainability is threaded throughout our organization. We have implemented a proactive joint eff­ort of our management team and labor force to continually monitor and refine our processes to further support our goal to reduce environmental impact.

Noble’s state-of-the-art equipment and modernized technologies help to ensure that the handling and treatment of material in our plant is fully compliant with the Environmental Protection Agency (EPA) regulations and the State of Rhode Island’s Environmental Management Group (RIDEM).

In addition, Noble follows the science of BACT – Best Available Control Technologies and proactively installed a highly efficient incineration system, fully compliant with the current EPA regulations and permitted by RIDEM. Noble’s incineration systems are employee safe, environmentally sound, computerized, and extremely effective.

Practicing environmental responsibility requires sound policy, procedures, and personnel. Noble takes these tasks quite seriously and is continuously monitoring our procedures and systems. Operating the business since 1998 as an industrial precious metal refiner, Noble has always proactively engaged with governmental authorities prior to enhancing or adding processing capabilities to our facility.

Hazardous wastes are defined as wastes that have properties that make it dangerous or potentially harmful to human health or the environment. In regulatory terms and as defined in Subpart C of 40 CFR Part 261, a RCRA hazardous waste is a waste that appears on one of the four hazardous waste lists (F-list, K-list, P-list, U-list) or exhibits at least one of these four characteristics: ignitability, corrosivity, reactivity, or toxicity (source the Environmental Protection Agency (EPA)).

Sound hazardous waste management demands specific protocols for storage, transportation, and treatment.

We have the experience, track record, and personnel to manage your waste streams correctly and ensure EPA compliance. State, and local compliance issues may vary, so always consult your local regulatory authorities.

UN approved containers are a requirement to hold and store hazardous wastes. Proper storage, labeling, coding, preparation of the manifest and final treatment of the material are also requirements. During transport, Noble Metals provides 24-hour emergency contact and shipment profiles.

All wastes received into our plant in Cranston, RI are treated within EPA guidelines and monitored by the Rhode Island Department of Environmental Management.

Additionally, we have open communications with our first responders, community, and employees, and maintain a well-defined Emergency Action Plan.

Executive Summary
Noble Metal Services, Inc. is fully compliant with the USA PATRIOT Act and all applicable Anti-Money Laundering (AML) regulations, including the Bank Secrecy Act and FinCEN requirements governing dealers in precious metals. We maintain a comprehensive, risk-based AML compliance program overseen by designated compliance personnel, and we hold every customer, supplier, and business relationship to these same standards without exception.

USA PATRIOT Act Overview
The USA PATRIOT Act strengthens the United States’ ability to detect and prevent money laundering and the financing of illicit activity across industries that handle high-value goods – including precious metals. For our industry, this means verifying the identity of the businesses and individuals we work with (Know Your Customer, or KYC), understanding the source and legitimacy of the material that moves through our supply chain, and monitoring transactions for activity that could signal fraud, sanctions violations, or other illicit conduct. In practice, this translates to due diligence at onboarding, ongoing account monitoring, and recordkeeping that allows us to trace material and transactions with confidence and transparency.

Commitment to Improvement
Regulatory compliance is not a fixed achievement but an ongoing responsibility. Noble Metal Services is committed to regularly reviewing, auditing, and strengthening our internal controls to keep pace with evolving regulatory standards, emerging risks, and industry best practices. We invest in ongoing staff training and independent reviews of our AML program to ensure it remains effective and current. We welcome questions from customers, suppliers, and partners about our compliance practices and view transparency as central to earning and keeping the trust placed in us.

For questions regarding this policy, please contact our compliance department.

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We combine technical expertise with responsive, personalized service to deliver a better experience from start to settlement.

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401.808.6630

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