In accordance with the US Patriot Act, Noble Metal Services maintains and regularly updates its Anti-Money Laundering Program.

January 1, 2006 was an important date in the precious metals industry. The US Government, under the direction of the US Treasury’s Financial Crimes Network (FinCEN) ruling in July 2005 requires that all precious metals dealers implement an AML program by January 1, 2006. Refiners of precious metals fall within these guidelines.

The goal of Noble Metal Services’ AML program is to prevent the purchase and or sale of precious metal goods from being used to facilitate money laundering or terrorist financing.

The basis of Noble Metal Services’ AML program is to assess the risks associated with precious metal transactions through business and customer knowledge.

Accordingly, Noble Metal Services’ AML program includes these three key points:

1. Maintain and update policy, procedures, and internal controls reasonably designed to assure compliance with the Bank Secrecy Act (BSA). This includes monitoring and reporting cash transactions more than $10,000.
2. Designate a compliance officer that has full knowledge of the Noble Metal Services business and be responsible for updating, implementing, and employee training.
3. Maintain on-going training and education programs.

Please contact us for more information.

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 pro-active 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 pro-actively 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.

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;
  • The worst forms 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.