Compliance and Due Diligence

Great Lakes Gold Origins Ltd is founded on responsibility, transparency, and strict adherence to international standards. Gold trading is a highly regulated industry, and we place compliance at the center of our operations. Every supplier, shipment, and transaction undergoes rigorous verification to ensure full legal integrity and traceability from source to destination.

Responsible sourcing is not just a requirement—it is essential for building a trustworthy and sustainable supply chain in the Great Lakes and East African region.

Our Commitment to Responsible Gold Trade

We follow globally recognised guidelines for ethical mineral supply chains. Our processes align with international frameworks that guarantee gold is sourced legally, responsibly, and without contributing to conflict or illicit trade. By doing so, we protect our buyers, partners, and the communities where our gold originates.

OECD Due Diligence Framework

Our company adheres to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals. This framework guides how we assess suppliers, evaluate risks, and verify the legitimacy of every shipment.

Risk Identification

When onboarding any supplier, we evaluate potential risks in their mining area, licence compliance, and production methods. We avoid high-risk zones and perform enhanced checks in sensitive regions.

Supplier Verification

All suppliers undergo legal verification, including licence authentication, KYC screening, and operational checks. Only government-approved miners, cooperatives, and dealers are allowed in our supply network.

Transaction Review

Every transaction is documented and verified to ensure the gold is sourced legally, recorded accurately, and transported under proper authorization.

Traceability and Recordkeeping

We maintain complete documentation for each shipment, including origin details, assay reports, sealed weights, and customs approvals. Records are securely stored and available for audits.

External Testing and Assessment

Independent laboratories conduct purity analysis, and third-party assessments confirm origin, quality, and compliance when necessary.

KYC and AML Standards

We maintain strict Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures. All buyers and suppliers must complete verification before engaging in trade.

Identity and Company Verification

Buyers and suppliers provide identification documents, corporate registration certificates, and proof of legal existence.

Sanctions and PEP Screening

Names are checked against international sanctions lists and politically exposed person (PEP) databases to prevent illicit involvement.

Source of Funds Assessment

Buyers must provide proof of a legitimate source of funds, ensuring financial transparency and compliance with global AML standards.

Licence and Permit Verification

Suppliers must demonstrate valid mining, trading, or export licences issued by relevant authorities in their countries. These requirements ensure engagement with legitimate and transparent partners.

Conflict-Free Sourcing Policy

We maintain a strict policy against trading minerals associated with conflict financing or illegal operations. Great Lakes Gold Origins Ltd does not buy or sell gold from embargoed areas, conflict regions, sanctioned individuals, or unverified artisanal sites. Our conflict-free policy ensures our supply chain remains ethical, transparent, and fully compliant with international standards.

Documentation Provided with Every Shipment

Each export is accompanied by a complete compliance and documentation package for traceability, customs clearance, and refinery intake. This package typically includes:

• Assay Certificate: Confirms purity and composition from an accredited laboratory.
• Certificate of Origin: Identifies the country and region of origin.
• Export Permit: Government authorization for shipment.
• Commercial Invoice and Packing List: Details weight, purity, and sealed packaging.
• Air Waybill: Issued after the shipment is booked and handed over for export.
• Supplier KYC File (where applicable): Supports due diligence for origin and legitimacy.

Each document provides buyers with confidence and meets the requirements of their destination markets.

Why Compliance Matters

Compliance protects everyone in the gold supply chain.

• For international buyers: It assures legitimacy, traceability, and freedom from conflict or illegal activity.
• For miners and communities: It promotes fair trade, improved livelihoods, and responsible economic development.
• For our company: It reinforces our reputation and ensures long-term market stability.

At Great Lakes Gold Origins Ltd, compliance is not a box to tick; it is a culture we uphold. It is the standard by which we measure every transaction and partnership.