Compliance

COMPLIANCE &

RISK MANAGEMENT

Hambrox Ltd takes its compliance and risk management responsibilities as commodities brokers in the metals and minerals sector very seriously. In our role as an intermediary in the commodities supply chain we ensure that we act in a professional manner in relation to international trade, financial integrity and ethical sourcing. We hold ourselves accountable for ensuring that the commodities that are traded in transactions that we facilitate between upstream producers and downstream buyers are legally, ethically and responsibly sourced and produced.

Hambrox Ltd adopts a thorough and methodical approach in its compliance and risk assessment processes to comply with all the applicable laws, regulations and protocols of the jurisdictions in which we operate. We follow a holistic risk management system in the following core segments to protect the integrity of all our business practices and the interests of all our stakeholders.

1. Responsible Sourcing & Conflict Minerals Due Diligence

We ensure that supply chains are transparent, ethical and compliant with all regulations by regularly assessing suppliers for practices relating to forced and child labour or human rights abuses especially when dealing with the 3TG minerals.

OECD Framework Alignment: We follow the applicable proposals of the OECD Due Diligence Guidance which establishes a framework for assessing supply chain risks.

Monitoring CAHRA Sources: We monitor the practical implementation of suppliers of the OECD Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRA).
Reasonable Country of Origin Inquiry (RCOI): When practicably feasible, we actively trace the physical chain of custody of the minerals back to their original provenance instead of where they were processed.
Supplier Declaration Tracking: We prioritise working with suppliers who follow the guidelines of the Responsible Mining Initiatives (RMI) and utilise their standardized tools such as the Conflict Minerals Reporting Template (CMRT) to collect and verify data from upstream supply partners. We also ensure that 3TG minerals suppliers are scrutinised by credible impartial third party organisations like ITSCI.

2. Financial Integrity, AML and Sanctions Compliance

Hambrox Ltd carries out all the necessary initial research on prospective counterparties to reduce the vulnerabilities of our stakeholders to illicit financial flows.

Enhanced Know-Your-Counterparty (KYC): We perform background checks on suppliers, logistics providers, and buyers to verify their legal legitimacy and beneficial ownership.
Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF): We implement monitoring systems to flag unusual transaction patterns or unexplained third-party routing.
Sanctions Screening: We cross-reference all potential counterparties against publicly available international sanctioned-party lists (e.g., US OFAC, EU, and UK sanctions) to avoid trading with prohibited entities.

3. Anti-Bribery and Anti-Corruption (ABAC) Compliance

The mining industry is predominantly located in jurisdictions where the regulatory frameworks can be very complex to navigate and private interests frequently intersect with state-owned enterprises and government officials for licensing and customs.

Regulatory Compliance: We monitor the strict adherence to all extraterritorial laws like the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act especially in countries with high corruption risks.
Facilitation Payments: We actively monitor and forbid side payments to government officials, customs brokers or port officials to expedite mineral clearance.

4. Import/Export Controls and International Trade Compliance

Cross-border operations require compliance with various export controls and trade laws. Violations can result in shipment delays, fines, and restrictions on business activities.

Customs Broker & Entry Management: We ensure the proper registration, correct Harmonized System (HS) product classification code selection, and accurate valuation of commodities.
Permit Verification: We ensure that all the necessary export/import permits, licences, environmental transit certificates and tax/duty compliance are met prior to cargo dispatch.

Summary of Major Regulatory Drivers