By previous communications, you have been made aware of QML/MST’s staunch commitment to the highest standard of ethical behavior, supply chain integrity and anti-money laundering controls. This unfailing commitment requires constant internal reviews of our own policies and the practices of our business partners as well.
The essence of all of the aforementioned programs requires that we know our customers, (who you are, what you do), and have a reasonable idea who you are conducting your business with to ensure compliance with U.S. and foreign laws. Because you are dealing with products containing precious metals, you are subject to U.S. laws and other proprietary laws within your country.
In addition to the legal requirements regarding money laundering, anti-bribery/ethical behavior, QML/MST stays true to the highest standard of ethical sourcing of precious metals materials, as set forth in our Supply Chain Due Diligence Program. We do not, for example conduct business that is any way associated with armed conflict, widening of violence, violation of human rights, money laundering, environmental pollution, child labor or terrorism. We therefore particularly need to know the Countries of Origin from which you acquire your inventory to guide in our due diligence process. We encourage you to join QML/MST in these robust policies and practices.
This document concerns all companies, units, branches, business and business partners of QML/MST. Every unit, All QML/MST employees engaged in the precious metals business within the organization are responsible for meeting the requirements of corporate Supply Chain Integrity, Anti Money Laundering (AML), and the highest levels of ethical business practices. We are all responsible for meeting these requirements and immediately addressing any problems within the shortest period and carrying out appropriate corrective actions.
QML/MST’s polices, programs and the due diligence procedures that implement it, are founded upon our general standards of business conduct and a commitment to:
We implement these policies through a comprehensive management system. This system will not only carry forward the general standards of business conduct set forth above, but will also direct our compliance with laws and regulations that address or bear upon our acquisition of precious metals, not only internally, but in our outside commercial relationships and transactions. In that regard, we commit to the following principals:
1. We will not deal with, and will immediately discontinue engagement with, suppliers that pose a reasonable risk that they are committing (or are sourcing from, or are linked to any party committing) abuses described above;
2. None of the below subjects will be tolerated by QML/MST concerning direct, or indirect support of non-governmental armed groups or those in collusion during the sourcing, transportation, trade, import/export stages:
3. We affirm that the role of public and private security forces is to provide security to workers, facilities, equipment and property in accordance with the rule of law, including law that guarantees human rights. We will not provide direct or indirect support to public or private security forces that commit abuses or that act illegally or in ways that violate this policy;
4. We will not attempt to improperly influence others or offer, promise, give or demand bribes or kickbacks in any form, and will resist their solicitation, and will not permit QML/MST company funds, assets, or property to be used to benefit individuals, including government officials, our customers, contractors and suppliers illegally in a manner that violates this policy;
5. QML/MST supports all preventative measures, efforts and applications to obstruct money laundering during the process covering our acquisitions, transportation and trade processes;
6. QML/MST will not conduct business directly, through its customers or through third-party relationships in the following countries (updated 10/12/17):
7. QML/MST will regularly review the Sanctions Programs and Country Information provided by the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury (OFAC Link);
8. QML/MST, its clients and third party vendors will comply with all economic sanctions laws, regulations, embargoes and restrictive measures administered, enacted and enforced by the United nations, the European Union or by Sweden , Finland, Norway and Ireland;
9. All transactions by QML/MST and its clients are observed and monitored by the Compliance Officer and fully validated against our customers’ acceptance of this policy. Internal and external audits concerning this subject are conducted annually;
10. In order to protect itself and its employees from being a target accused with violation of national and international laws, QML/MST continuously applies effectively practiced Know Your Customer (KYC) procedures and supply chain assessments and most importantly, our customer’s acceptance of these policies and principles.
