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Policy of Compliance and Ethics

It is the policy and practice of Metalor Technologies SA to maintain high standards of ethical conduct, to comply with all applicable laws, and to do business only with persons who themselves abide by laws and ethical principles. In particular, when dealing in precious metals, we will operate only with transparency by all parties and with assurances of legitimacy in all transactions.

This policy is applicable to all business units, subsidiaries, affiliates, partnerships and other business organizations over which Metalor Technologies has control. It covers all of our employees, officers and directors. We expect, and will assist and ensure, that all of these persons learn and comply with company standards and laws applicable to their job responsibilities, and to adhere to the guiding principles of this policy. We will supplement and administer this policy through more specific codes and procedures, effective communication and training, regular monitoring and periodic review.

In addition to adherence in our home country, Switzerland, to the Precious Metal Control Act and the Money Laundering Act, we apply the same principles, expressed through this policy, throughout the world, wherever Metalor Technologies operates and does business. We will endeavor to promote and follow a uniform code of conduct in all countries. We recognize that there are differences in laws and standards throughout the world, and that a single rigid code of conduct will not fit all circumstances. The principles of honesty, fairness and high ethical standards will not, however, be compromised.

We also recognize that in some parts of the world governments are weak, that legal and ethical infrastructures are poor, and that sometimes armed conflict takes place. We will not, under any circumstances, engage in business that arises from criminal activities, or from criminals or terrorist groups, or that is used to finance criminal or terrorist activities ( Supply Chain Due Diligence Policy ). However, following the guidance of the United Nations, we will not simply embargo such areas; we will not unthinkingly deprive them of our technical and financial expertise, and of the opportunity to improve their situations through legitimate, transparent trade. We will, instead, exercise particular diligence to uphold this policy.

In January 2011, Metalor became only the fourth certified member of the Responsible Jewellery Council having passed an audit which provides evidence of responsible business practices in compliance with the Responsible Jewellery Council's Code of Practices and its commitment to operating its business according the said Code. Metalor supports the achievement of the Code of Practice as the driver for improving responsible business practices. RJC Policy .

For more information on our due diligence process, please contact us.