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ISTANBUL GOLD REFINERY / IGR GLOBAL COMPLIANCE DIRECTIVE
REFERENCES:
Istanbul Gold Refinery (IGR) Co. Intercorporate regulations and instructions
LBMA Good Delivery Rules for Gold Bars, October 2012
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-affected and High Risk Areas, Second Edition November 2012
OECD Due Diligence Guidance Gold Supplement, 17 July 2012
World Gold Council Conflict-Free Gold Standard, 01 October 2012
SCOPE AND EXECUTIVES:
This document concerns all companies, units, business and business partners of Istanbul Gold
Refinery / IGR Global involved in the business of gold and gold containing valuable metals. It does
not include business or business partners not involved with gold refinement.
MANNER OF IMPLEMENTATION:
Istanbul Gold Refinery / IGR Global Compliance Directive shall become effective on the date of its
publication. Potential changes to it shall be issued by the Compliance Officer indicating revision
number. Unit officers/managers are responsible for ensuring full understanding of the principles and
application of this directive by all personnel, for establishment of their own internal communication
systems, to facilitate an operational style to meet the requirements of unit internal conformance
systems, and from application of unit internal instructions and directives.
Corporate Compliance Officer has the primary responsibility for Compliance Process and Due
Diligence activities and stages toward the Istanbul Gold Refinery / IGR Global Board of Management,
our clients, accrediting organizations and other 3rd parties. Compliance Officer reports the
activities to the Top Management and to the Chairman of the Board.
1. GENERAL PRINCIPLES:
Compliance; concerns gold refinement and is put into effect by Istanbul Gold Refinery / IGR Global in
consideration of the scope of activities and implementations meeting the requirements of accrediting
institutions and organizations, national and international regulations and standards. In Istanbul Gold
Refinery / IGR Global Compliance constitutes the common point for the work undertaken within the
scope of gold refinement, and related practices.
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The fact that we are a credible trademark in the world market is related with our certifications by
respectable institutions such as London Bullion Market Association (LBMA); our place in the Good
Delivery List of London Bullion Market Association (LBMA); our product quality in consistence with
accredited standards;
and that we internalize and implement the requirements of Compliance Principles and Due Diligence
Our whole commercial affairs with our customers are run based on the compliance principles.
Implementing all the related national and international legal regulations and instructions, as well as
the rules and instructions by respectable institutions of the sector such as London Bullion Market
Association (LBMA); so as to establish all of our commercial relationships on those basic principles,
sharing them in the beginning with our customers; and training all of our employees and raising
awareness among them within the scope of those principles; are the basic principle of our Company
Gold Supply Chain Responsibility Policy.
Istanbul Gold Refinery / IGR Global personnel, shall never make purchase, refinery, and sales of gold
and gold containing valuable metal outside the below specified principles; and shall not risk the
refinery’s /company’s credibility for their own interests. In the first place the Chairman of the Board,
Compliance Committee and all the department managers of the refinery are responsible for
implementing and having implemented above specified principles. If during the process, any Istanbul
Gold Refinery / IGR Global personnel including laborers, face any non-compliance which they
consider to be a risk within the scope of the principles of Gold Supply Chain Responsibility Policy,
they have the self-confidence to inform the management about the situation. Commercial relations
with our customers shall also be formed with this awareness.
2. MAIN PRINCIPLES:
Istanbul Gold Refinery / IGR Global Compliance Directive; is in the nature of a guiding directive for
the necessary practices so as to ensure that the tasks with a continuous applicability and required to
be performed by all departments and employees of the refinery /company within the scope of
London Bullion Market Association (LBMA) compliance process and sustainability, and each step
required to be taken within the scope of Compliance Process Due Diligence work are consistent with
accreditation principles we committed to, and in compliance with market rules and international
validity standards; and to provide that all the transactions and applications in the process are run
according to the principles we are subject to. This instruction also constitutes the basis of Gold
Supply Chain Responsibility Policy document. Gold Supply Chain Responsibility Policy shall be
prepared by Compliance Officer and be published following the approval of Board, and policy
updates shall be followed.
3. APPLICABILITY AND RISK MANAGEMENT
With the objective of enabling compliance of the existing system and its applications to this process,
ensuring continuity of accreditation principles and to meet the Good Delivery List requirements of
London Bullion Market Association(LBMA); and providing compliance of present system and
practices of the refinery with this process; and in order to establish and provide functionality of a
particular Refinery / Company Compliance System which meets the minimum requirements of
London Bullion Market Association (LBMA), Istanbul Gold Refinery Inc. / IGR Global Inc. is under
the commitment to:
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a. Establish a strong corporate management system,
b. Identify and assess the risks in the gold supply chain,
c. Design and implement a management strategy to alleviate the risks identified,
d. Appoint an independent auditor for gold supply chain Due Diligence,
e. Report the results.
This is the focal point in the work and efforts of Corporate Compliance Officer, Unit Compliance
Officers and Compliance Committee.
Within the entire process, everything which will contribute to:
Armed conflict,
Growing of violence,
Violation of human rights,
Money laundering,
Financing of Terrorists
are considered to be high risk, customer with high risk, or transactions with high risk.
The motto “Choose honesty without hesitation when you have to choose between honesty and
interest “ ,which has been defined with this intention, is our main principle. Acting outside this
principle and generating simple solutions will damage our commercial credit; and will require too
much time and effort for the reinstallment of the trust and respectability of our refinery/company.
All the managers and the workers at Istanbul Gold Refinery / IGR Global shall be in the awareness of
that.
With this objective, Istanbul Gold Refinery / IGR Global shall put into effect the Gold Supply Chain
Policy, maintain its currency, and through sharing, achieve a common collective consciousness
among all company personnel, clients, business partners and other concerned 3rd persons.
Gold Supply Chain Risk Management Plan and Risk Analysis shall be undertaken by the Corporate
Compliance Officer, and shall be published upon approval by the Chairman of the Board.
Related Departments of Istanbul Gold Refinery / IGR Global shall implement all the rules of London
Bullion Market Association (LBMA)’s Good Delivery List, and shall run all the refining and fixing
operations within the scope of those principles.
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4. COMPANY COMPLIANCE SYSTEM ORGANIZATION:
A Compliance Officer has been appointed by the Chairman of Management Board at Istanbul Gold
Refinery / IGR Global Corporate Compliance Officer works in coordination with all managers and
units, and while reporting operation, observation and inspection results to the concerned unit
managers for corrective action, also informs the Management Board Chairman. Depending on the
level, confidentiality and character of matter requiring correction, when necessary reports directly
to the Chairman. Corporate Compliance Officer conducts all monitoring and applications of
statutes related to compliance.
At the same time, corporate Compliance Officer is also the Chief Compliance Trainer. The
Corporate Organizational Structure chart which also incorporates the Compliance Officer is
provided in Appendix-A and Compliance Officer Operation instructions are given in Appendix-B.
A Corporate Compliance Committee has been formed to operate under the supervision of Board
of Management. Compliance Committee Organization Chart is presented in Appendix-C and the
Compliance Committee operation instructions are presented in Appendix-D.
A Non-Compliance Notification System has been installed as a communication mechanism
enabling the reporting to the Top Management of any kind of non-compliance, which has been
evaluated during the process as a risk within the scope of the Gold Supply Chain Refinery Policy
principles; and to that end, Compliance Access Points have been formed. Functioning of
Non-Compliance Notification System and Compliance Access Point utilization instructions are
given in Appendix- E. Non-compliance Notification Form and the refinery Compliance Officer,
Departmental compliance officers, Compliance Committee, Compliance- access point relation are
given in Appendix-F and Appendix-G respectively.
Unit officers/managers and department Compliance officers are responsible for providing
compliance in their departments. They are in direct communication with the Corporate
Compliance Officer during their operations. Unit Officer/Unit Manager operation
instructions and Unit Compliance Officer Operation instructions are given in Appendix-H and in
Appendix-I respectively.
In order to inform all the employees in the company including managers and workers
about Compliance Process and Due Diligence; to update their available knowledge; and to build a
common consciousness; Corporate Supply Chain Compliance Training Instructions shall be prepared
by the Compliance Officer; and internal Supply Chain Compliance Trainings shall be planned and put
into practice.
In order to raise the same consciousness among the customers regarding the Compliance and DueDiligence; and to implement a common understanding, a Good Will/Compliance Settlement shall bemade; and regarding the process management, the customers shall be supported through regularand periodical visits to the customers.
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In order to evidence that activities are conducted as per requirements of Due Diligence, and
regulations, instructions, directives are complied with at each stage of process, all records and
documents relating to gold supply chain are archived at least for 5 years in classic manner and in
preserved in a database environment, and the corporate Archive Directive is revised accordingly.
Within the scope of Know Your Customer System, Customer Files shall be prepared by the related
units in Istanbul Gold Refinery / IGR Global and their content shall always be kept update. A reference
and lot system which are consistent with each other, shall be installed to enable the transparency and
in a systematic structure functionality of all the transactions, registers, input and outputs of Gold and
Gold containing precious metals within the process of Gold Supply Chain; and measures shall be taken
to provide that all the commercial transactions are run within the scope of requests by accredited
institutions.
Following the closing of fiscal year, a Corporate Annual Report shall be prepared and be distributed
to the appropriate points by the Accounting and Finance Unit. Company shall submit the Compliance
process and Due Diligence systems together with their records to the annual auditing; and shall share
the auditing results with both its staff and third parties in related platforms. To that end, an annual
Auditing Contract shall be made by the Compliance Committee according to the provisions of the
London Bullion Market Association (LBMA) Audit Guidance. In that context, an Internal Audit Plan
and Corrective Action Plan shall be prepared; and their implementations shall be monitored. Papers
and documents to be submitted to the Auditing Unit by the related units, shall be made ready at a
time sufficiently prior to end of that fiscal year. Control and coordination, as well as the reporting
required at the end of the auditing shall be performed by corporate Compliance Officer.
London Bullion Market Association (LBMA) corporate Compliance Process Analysis chart, which
summarizes the whole process and lists the operations, is presented in Appendix-J.
5. RESPONSIBILITY
Every unit and all employed personnel engaged in gold and gold containing metal business within
Istanbul Gold Refinery Inc. / IGR Global Inc. are responsible for meeting the requirements of
Compliance Directive as well as those of the Gold Supply Chain Responsibility Policy, to inform any
problems or shortcomings within the shortest period, and to carry out appropriate corrective actions.
Istanbul Gold Refinery / IGR Global
7 No’lu Fabrika Kuyumcukent Sitesi 34197 Yenibosna/Istanbul
P: +90 212 603 01 01 F: +90 212 603 01 10
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Appendix-A
COMPLIANCE OFFICER OPERATIONAL DIRECTIVE:
1. Corporate Compliance Officer shall be appointed by Chairman of the Management Board.
Operations and activities shall be reported to the Upper Management and to the Chairman.
2. Appointment shall be notified to the accrediting organizations and necessary 3rd persons.
3. Compliance Officer shall monitor all national and international statutes concerning the field
of activity. Within this framework, prepares all corporate instructions and implementations,
ensures follow-up and control.
4. Prepares the corporate Gold Supply Chain Responsibility Policy document and ensures its
currency.
5. Conducts corporate Due Diligence activities.
6. Guides and directs the Due Diligence efforts of Corporate Units.
7. Conducts the Due Diligence Risk Analysis. Establishes the Risk Management Plan.
8. Reports activities to the Upper Management and Chairman of the Management Board.
9. Represents the Corporation by participating in accreditation organization collaboration.
10. Chairs the Compliance Committee, reports results to the Chairman of Management Board.
11. Presents high risk clients to the approval of Chairman, Management Board.
12. Monitors non-compliance notification system, reevaluates non-compliance notifications,
processes, and when required issues timely calls for Compliance Committee meeting with
appropriate representation.
13. Conducts periodic compliance inspections and reports results to the relevant managers and
Chairman, Management Board.
14. Prepares a Corrective Action Plan and implements it when required.
15. Functions as Compliance Chief Trainer. Plans corporate in-training and applies such plans.
16. Trains Unit Compliance Officers, monitors their activities.
17. Establishes a relevant unit archiving system.
18. Conducts the relationship with auditing firm.
19. Conducts client visits when required and shares Compliance Process as well as Due Diligence
information, also contributes to formation of identical awareness.
20. Acts as an subject advisor, provides assessments and suggestions to the Upper Management
and Chairman, Management Board.
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A .Özcan HALAÇ President&CEO
Director General Compliance O cer Manager, Internal Audit Unit Director
Financial A airs Group nterna onal Branch Mangers
Department Managers
Department Compliance O cer Department Compliance O cer Department Compliance O cer
PRESIDENT&CEO
COMPLIANCE COMMITTEE
COMPLIANCE COMMITTEE
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Appendix-C
COMPLIANCE COMMITTEE OPERATION DIRECTIVE:
1. Compliance Committee shall have a structure providing supportive services to the
compliance system and is under direct supervision of Chairman, Management Board.
2. Compliance Officer serves as a secretary and rapporteur of the Compliance Committee.
Minutes and reports are recorded by the rapporteur. Matters of utmost significance shall be
issued as Management Board decisions. Compliance Committee is response to the
Chairman, Management Board.
3. Compliance Committee consists of following Officers:
Director General
Compliance Officer
Manager, Internal Audit Unit Director,
Financial Affairs Group
International Branch Mangers
4. Committee serves as the decision taking authority in matters concerning the Compliance
Process and Due Diligence. Evaluates high risk clients. Determines corrective actions to be
taken and guides their execution in subjects under consideration due to non-compliance
notifications.
5. Submits high risk clients to the approval of Chairman, Management Board.
6. Compliance Committee meets once every 3 months. If investigative commission
subcommittees are appointed concerning non-compliance notifications, commissions take
the necessary decisions and corrective action plans are implemented, and necessary
information are provided to the Chairman, Management Board as well as to parties who
supplied the notification.
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Appendix-D
NON-COMPLIANCE SYSTEM OPERATION and COMPLIANCE ACCESS POINT DIRECTIVE :
1. Compliance Access Points are parts of both London Bullion Market Association(LBMA) andcorporate Quality Control Management System.
2. It has been established as a communication mechanism facilitating non-compliance
notifications resulting from compliance failures considered as risks by employees/workers
within the context of corporate Gold Supply Chain Process.
3. Compliance Access Points are used jointly with Total Quality Management System
complaint/suggestion facilities. These facilities are drop-form locked boxes positioned in all
appropriate Unit locations and employee/worker gathering places such as corporate
cafeterias and rest rooms. These boxes at all times provide a supply of blank forms to be
filled and pens. Intranet internet system may also be used.
4. Non-compliance notification forms possess CONFIDENTIAL level secrecy. If the notifier
wishes to disclose his/her name than he/she must also sign the form. Corporate
management guarantees non-prejudice, non-criticism, and non-denunciation to persons
providing notifications, and further warrants that notifies are under protection in such
matters. Unit Compliance Officers shall directly inform the Corporate Compliance Officer of
any non-compliance identified.
5. If the Compliance Officer or Compliance Committee fined the notification worthy of
consideration and investigation, than the Chairman, Management Board shall be informed.
If it is a problem concerning the e n t i r e Corporation than a s u b c o m m i t t e e may
be commissioned to carry out investigations in support of decisions to be taken.
6. Compliance Access Points shall be monitored on weekly basis by corporate Compliance
Officer/Unit Compliance Officers/Total Quality Management Officer and if any, submitted
notification forms shall be evaluated and assessed by the Compliance Committee. Necessary
corrective action plan shall be initiated and Chairman, Management Board shall be informed.
Findings and conclusions, corrective action plan results shall also be provided as feedback to
the notifying person.
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Appendix-D
NON-COMPLIANCE SYSTEM OPERATION and COMPLIANCE ACCESS POINT DIRECTIVE :
1. Compliance Access Points are parts of both London Bullion Market Association(LBMA) and corporate Quality Control Management System.
2. It has been established as a communication mechanism facilitating non-compliance
notifications resulting from compliance failures considered as risks by employees/workers
within the context of corporate Gold Supply Chain Process.
3. Compliance Access Points are used jointly with Total Quality Management System
complaint/suggestion facilities. These facilities are drop-form locked boxes positioned in all
appropriate Unit locations and employee/worker gathering places such as corporate
cafeterias and rest rooms. These boxes at all times provide a supply of blank forms to be
filled and pens. Intranet internet system may also be used.
4. Non-compliance notification forms possess CONFIDENTIAL level secrecy. If the notifier
wishes to disclose his/her name than he/she must also sign the form. Corporate
management guarantees non-prejudice, non-criticism, and non-denunciation to persons
providing notifications, and further warrants that notifies are under protection in such
matters. Unit Compliance Officers shall directly inform the Corporate Compliance Officer of
any non-compliance identified.
5. If the Compliance Officer or Compliance Committee fined the notification worthy of
consideration and investigation, than the Chairman, Management Board shall be informed.
If it is a problem concerning the e n t i r e Corporation than a s u b c o m m i t t e e may
be commissioned to carry out investigations in support of decisions to be taken.
6. Compliance Access Points shall be monitored on weekly basis by corporate Compliance
Officer/Unit Compliance Officers/Total Quality Management Officer and if any, submitted
notification forms shall be evaluated and assessed by the Compliance Committee. Necessary
corrective action plan shall be initiated and Chairman, Management Board shall be informed.
Findings and conclusions, corrective action plan results shall also be provided as feedback to
the notifying person.
Appendix-E
COMPANY COMPLIANCE OFFICER, DEPARTMENT COMPLIANCE OFFICERS, COMPLIANCE
COMMITTEE, COMPLIANCE ACCESS POINT CORRELATION:
BOARD OF CHAIRMAN
COMPLIANCE COMMITTEE Compliance Officer
Department Compliance Officer
Department Compliance Officer
Department Compliance Officer
COMPLIANCE ACCESS
POINT
EMPLOYEES / WORKERS
CORRECTIVE ACTION CORRECTIVE ACTION
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Appendix-F
UNIT OFFICER/ UNIT MANAGER OPERATIONAL DIRECTIVE:
1. Ensures Compliance Process awareness among all unit personnel.
2. Monitors relevant statutes.
3. Appoints and supervises Unit Compliance Officer.
4. Applies corporate Gold Supply Chain Responsibility Policy and Compliance Directive
principles and provisions.
5. Conducts in-Unit Due Diligence, identifies risks and proposes resolutions.
6. Applies any corrective actions set out.
7. Follows-up in-Unit non-compliance notifications.
8. Prepares the Unit Compliance Directive in accordance with the Corporate
Compliance Directive.
9. Ensures preparation of Unit Compliance File.
10. Prepares In-Unit Compliance Instructions and ensures notification of personnel.
11. Executes Compliance Agreement with clients.
12. Ensures maintenance of Client Information Files.13. Conducts client visits when required and for the purpose of raising awareness, and
shares information on Compliance Process and Due Diligence.
14. Participates in related meetings.
15. Establishes a relevant Unit Archive system.
16. Prepares the Unit for audit.
17. Works in coordination with Corporate Compliance Officer
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Appendix-G
UNIT COMPLIANCE OFFICER WORK DIRECTIVE:
1. Unit Compliance Officer is appointed by Unit Manager. Officer is responsible to theUnit Manager.
2. Appointment and duty reassignments shall be notified to the Corporate Compliance Officer.
3. Unit Compliance Officer works in coordination with Corporate Compliance Officer.
Monitors relevant statutes. Develops In-Unit directives and applications, ensures
execution and control.
4. Conducts In-Unit Due Diligence jointly with Unit Manager.
5. Works in coordination and cooperation with the Corporate Compliance Officer.
6. Reports his/her activities to the Unit Manager and Corporate Compliance Officer.
7. Participates in related compliance meetings.
8. Monitors In-Unit non-compliance notification system.
9. Functions Unit internal trainer.
10. Coordinates Unit audit preparations.
11. Maintains the relevant In-Unit records and Unit Compliance File.
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Annex-I
LBMA COMPLIANCE PROCESS ANALYSIS
Item no.
To do Responsible Unit Remarks
1. To appoint a Company Compliance Person and inform the LBMA about it.
Compliance Person LBMA was informed on the 18th of December 2012.
2. Organizational chart of the company was reviewed and arranged to include the Compliance Person
Compliance Person Arranged and published.
3. Company Compliance Directive was prepared Compliance Person Prepared.
4. Preparing and constant updating the Gold Supply Chain Responsibility Company Policy
Compliance Person Prepared and updated
5. Announcing the GSC Responsibility Company Policy to all stakeholders/and publishing it on the
Compliance Person/IT Prepared and added to web site.
6. Entering into an agreement with an independent auditor who acts in accordance with the LBMA standards, and having him/her audit anytime during the year and reporting the results to the LBMA.
Compliance Person Compliance Committee
Audit from independent auditor every year and report to LBMA
7. The format of the Refinery Compliance Report of the company, which should be prepared at the end of the audit, shall be prepared according to the Draft Audit Guidance Annex B), and developing the in-house applications in the framework of
Compliance Person Refinery Compliance Report has been preparing every year.
8. Creating a Compliance Committee, holding periodic meetings and keeping the meeting minutes.
Compliance Person Compliance Committee
Committee was established.
9. Commissioning a Unit Compliance Person for each unit
All units Nominated Compliance Officer at each departments.
10. Preparing a Unit Compliance Directive for each unit
Compliance Persons of the Units Company Compliance Directive has been prepared, and send to units.
11. Preparing an LBMA Compliance File for each unit (The unit compliance directive which includes company policy, special issues to be considered in the unit, the unit instructions, commissioning, notification lists etc)
Compliance Person / All units A sample file is prepared by the Compliance Person and be given to the units.
12. Holding a supply chain training program, determining a chief trainer and trainers, holding periodical trainings, and keeping the minutes on trainings.
Compliance Person Compliance Officer has been organizing the training programs.
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13. Holding periodical in house audits by the Compliance Committee and the Company Compliance Person and submitting quarterly reports to the top management
Compliance Person Audit Unit
An audit plan and a calendar are to be published by the Compliance Person.
14. Preparing a Corrective Action Plan and implementing it through periodical audits.
Compliance Person To be prepared and published by the Compliance Person
15. Creating a lot system/ or a compliance reference system where each refined lot could be monitored, and where the compliance of all processes with each other could be seen.
Compliance person/ Istanbul Gold Refinery Manufacturing/Gram Gold manufacturing/ Accountancy / All commercial Units
A working group is to be established and the system will be set up within January.
16. Strengthening the current relations with the customers, holding customer visits as well as documenting the visits to this effect
Compliance person/All commercial units
Commercial units will schedule a quarterly Customer visits and the Compliance Person is to be informed about it.
17. Creating an in-house Report System that will provide an early-warning that covers in-house participation and communication, in order to determine – and take action- the new risks that emerges at each stage related to the supply chain, and implementing a mail/notification box and the Compliance Access Points, to this effect.
Compliance Person Prepared by the compliance officer and set Compliance Access Points.
18. Entering into Good Will/ Due Diligence agreements with our customers, revising the current agreements (if any) in the process of compliance to the LBMA and raising awareness amongst them in the framework of our policy.
Compliance Person/All commercial units
Prepared by compliance officer.
19. Creating a risk management plan and holding a general risk analysis on the Supply chain
Compliance Person Prepared by compliance officer.
20. Keeping a Customer File, which is separate for each customer, and holding a risk analysis in the scope of KYC (Know Your Customer) system, creating a customer databank format, appointing a reference number and risk rating to each customer, and those with high risk rate should be approved by the Top Management(Private).
Compliance person/Istanbul Gold Refinery Manufacturing/Gram Gold Manufacture/ Accountancy /All commercial units
risk rating to each customer has been doing by compliance department.
21. Creating and publishing the lists of customer reference numbers
Compliance person/All commercial units
Customer lists are to be prepared by the commercial units according to a format to be determined by the Compliance person and are to be submitted to the Compliance Person
22. Creating a classical archiving and a database archiving system that will keep the processes/documents for at least 5 years
Human Resources/Information technology/All commercial units/Accountancy/Manufacture units
Trying to make better
archiving system.
23. Holding the on-site observations on refinery units and other related offices, and making them ready for the audits
All units Things to be put in order and organized by all the units before the audit
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24. Keeping all instructions, directives etc ready in the framework of Total Quality Management-ISO…, all workers should be notified of their job definitions, powers and responsibilities, related instructions and directives, and keeping all records including the in-house trainings. And any type of instructions, directives etc that will be prepared in this scope should be updated in accordance with the principles of the Company Gold Supply Chain Responsibility.
All Units/Human Resources/Total quality management person.
Regarding the actions/documents to be carried out/prepared by the Human Resources/Total Quality Management Person pursuant to the ISO 9001,14001, OHSAS(Occupational Health and Safety Management System) 18001 etc., these actions/documents should be adapted to comply with the Company Gold Supply Chain Policy Principles
25. Performing the refining and manufacturing processes in accordance with the requirements of the LBMA Good Delivery List (marking, branding, labeling, registering etc)
Production Units/ Laboratory/Adjustment house
Following the processes and the maintaining the adjustment processes to the requirements of the LBMA Best Manufacturers List
26. Preparing an Annual Financial Report at the end of each fiscal year and submitting it to the LBMA
Finance/Accountancy Audit done by independent auditor
27. Participating the meeting/seminary events of the LBMA during the year and keeping a close contact with it.
Compliance Person LBMA Annual Calendar is to be followed and participated accordingly
28. Preparing the file and the brief that will be submitted to the auditor.
Compliance Person Done by every year.
29. In order to submit to the auditor, preparing the lists –of the audit term- indicating the amount and name/addresses of all types of commercial activities related to the gold refining, including the countries and risk rates of those who supplied the gold
Compliance person/Finance/Accountancy/ Related Units
To be prepared in agreement with the auditing company
30. Preparing the lists -within its term- detailing the date, weight and types of all materials containing gold that was purchased outside or provided through the in-house transfers for refining as well as the lists that cover all commercial processes including the details on the excavation points of the materials that come from recycling or those materials that are used for investment such as ingot, bar, coin and such ones that contain gold for submission to the auditor.
Compliance Person/Finance/Accountancy/Related Units
To be prepared in agreement with the auditing company
31. Preparing the lists –of the audit term- on offices related to the materials containing gold outside the refinery, including their place of operation, and their storage areas (if there is any) as well as the name/addresses for submission to the auditor.
Compliance Person To be prepared in agreement with the auditing company
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