Security

USAR is consistently committed to safety and security. USAR facilities are equipped with on-site security personnel available 24/7, consisting of professionally trained law enforcement personnel. In addition, USAR employs state-of-the-art surveillance cameras that are monitored continuously, along with controlled access to critical processing areas.

Access to our gated facility is monitored and controlled by access control devices and law enforcement personnel. Each client lot is checked in, assigned a lot designation, and digitally documented with photographs. All client lots are tracked throughout the processing phase via a series of gateways, which include area signoffs and additional photographs. Each lot can be referenced at every stage of our refining process.

No Metal Policy

For the safety of our employees and visitors, all individuals entering USAR facilities must remove all metal objects from their bodies before accessing process areas.

Employees and visitors must pass through an X-ray system to detect any metal being brought into production areas. Personal items are stored in a secure locker and returned upon exiting the facility.

Responsible Supply Chain Due Diligence

USAR is dedicated to safeguarding our clients, our country, and ourselves by ensuring that every prospective Lot that enters our facility complies with the expectations set forth by the U.S. government, industry standards, and our own criteria for securing the supply chain.

USAR conducts thorough due diligence on all our suppliers or counterparties. In accordance with the US Patriot Act, the OECD’s Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas and the London Platinum & Palladium Market’s Responsible Platinum and Palladium Guidance.

While USAR may be viewed as a supplier for your company in search of a refining or catalyst partner, by sending your precious metal bearing materials to USAR, you effectively become a supplier to USAR. As such, USAR is obligated to adhere to the requirements established by the US Government and industry organizations. To ensure compliance and safeguard all parties involved, US Assets Recovery has implemented policies designed to meet these critical expectations. USAR employs a dynamic approach to managing due diligence by gathering supplier information, including understanding where in the process our clients and suppliers utilize precious metals. In addition to our industry expertise regarding the use of precious metals, information is collected by means of supplier surveys, which are designed to meet the standards set by the US Government and industry organizations. Completing these surveys is a requirement for USAR to effectively serve your organization.

The USAR Supply Chain Due Diligence Policy, which is based on internationally recognized human rights standards, sets out USAR’s expectations for its suppliers to ensure compliance with human rights and environmental standards. Through this Supplier Code of Conduct (“Code of Conduct”) we aim to collaborate exclusively with suppliers who are equally committed to the principles established in the USAR Supply Chain Due Diligence Policy. The principles and commitments detailed in this Code of Conduct (Sections 1-8 below) apply globally to all suppliers and service providers of USAR (“Supplier”) who have confirmed their compliance with this Code of Conduct. The Supplier acknowledges and agrees that adherence to the principles laid down in this Code of Conduct is the prerequisite to qualify as a supplier of USAR. 

1. Compliance with Laws, Rules and Regulations and Internationally Recognized Standards

 The Supplier hereby commits to USAR to comply with all legally binding rules and regulations, in particular with all applicable laws for the protection of fair competition, all export and import prohibitions in force, all applicable customs and tax regulations as well as all applicable legal regulations for occupational health and safety and for the protection of the environment.

2. Bribery and Corruption

The supplier commits not to offer, promise, or grant, either directly or indirectly, any benefits to employees of USAR as consideration for the procurement of products or services. If, during its business relations with USAR, the supplier collaborates with consultants or sales intermediaries, it must ensure that these consultants and intermediaries also refrain from offering, promising, or granting any benefits to employees of USAR in exchange for the procurement of products or services. 

3. Social Responsibility and Environmental, Health, and Safety Standards

We expect our suppliers to respect the dignity and human rights of their employees and to engage in business only with partners who also commit to upholding the dignity and human rights of their own employees. In this context, we understand employees to mean all people who work for the supplier because of a contractual relationship.

4. Environmental Protection 

The Supplier commits to complying with all applicable legal provisions for environmental protection, including requirements under chemicals and waste legislation. The Supplier aims to minimize environmental impacts on soil, water, and air while continuously improving its environment.

5. Management System

The Supplier confirms that it has established appropriate processes and structures, particularly for the timely identification of human rights risks, the initiation and implementation of remedial measures in the event of identified risks or violations, and the enhancement of awareness among its employees. 

6. Protection of Trade Secrets

The supplier agrees to refrain from unauthorized disclosure of any business and trade secrets belonging to USAR or its business partners. The supplier also commits to not transmitting any such business and trade secrets to third parties without the written consent of USAR, and to not using these business and trade secrets for its own purposes. For the purposes of this provision, business and trade secrets include all documents and information that are designated or marked as confidential, or in which USAR has a vested interest, and that are not generally available to the public or in the public domain.

7. Audits

Upon the existence of valid reasons, USAR shall be entitled to verify the Supplier’s compliance with the principles outlined in this Code of Conduct after providing prior notice and to demand corrective measures in the event of any deficiencies. A valid reason for auditing the Supplier shall particularly be deemed to exist if there are specific industry or country risks, or if information received from or obtained by third parties or the Supplier itself warrants such an audit. Unless otherwise expressly agreed upon, an audit of the Supplier will be limited to the subject areas specified in Sections 1-6 above. Within the scope of an audit, USAR may request access to the Supplier’s documents and records that demonstrate the Supplier’s compliance with the commitments outlined in Sections 1-6 above. During the review of such documents and records, appropriate consideration will be given to the protection of the Supplier’s trade secrets. USAR may have the Supplier audit conducted by its own employees or by qualified third parties. If there are serious indications of a significant violation or a material breach of the commitments undertaken by the Supplier under Sections 1-6 above, USAR may, as an exception, also conduct unannounced audits.

8. Applicability to Sub-suppliers and Subcontractors

The commitments and obligations outlined in this Code of Conduct also apply to all business partners of the Supplier who assist in fulfilling the Supplier’s contractual obligations to USAR. The Supplier is committed to ensuring that its own suppliers comply with this Code of Conduct and reserves the right to conduct audits of its suppliers for this purpose. USAR may terminate all contracts, agreements, and undertakings with the Supplier without prior notice, effective immediately, if the Supplier violates or breaches any commitment under this Code of Conduct, or if any information provided by the Supplier to USAR is found to be incorrect, incomplete, or materially false, such as in a questionnaire. Furthermore, the Supplier is obligated to indemnify and hold USAR harmless from any third-party claims asserted against USAR due to, or in connection with, a violation of the commitments set forth in this Code of Conduct.

The Supplier commits to the following – Supplier Code of Conduct:

• Not to employ children below the minimum age for admission to employment as permitted by applicable law. 
• In any case, not to employ children under the age of 18, unless exceptions are permitted by applicable law, particularly for educational training, by applicable law.
• To respect the personal dignity, privacy, and rights of every individual.
• Not to employ anyone against their will or to coerce anyone into working, such as by withholding identification documents or employment contracts. 
• Not to tolerate any unacceptable treatment of employees, including psychological coercion, sexual harassment, or personal harassment.
• To ensure equal opportunities and rights for all employees.
• To provide appropriate compensation and guarantee at least the statutory national minimum wage. 
• Not to mandate or allow excessive working hours that could lead to mental or physical fatigue among employees. 
• To comply with and adhere to the applicable maximum working hours. 
• To ensure a safe working environment, particularly regarding exposure to toxic or hazardous substances.
• To comply with statutory requirements for occupational safety. 
• To recognize and respect the freedom of association and not to impede or restrict employee associations. 
• To ensure that the use of private security personnel respects the human rights and dignity of employees.

Responsible Supply Chain Policy

This policy is adapted from the Organization for Economic Co-operation and Development’s (OECD) “Model Supply Chain Policy for a Responsible Global Supply Chain of minerals from Conflict-Affected and High-Risk Areas.” It has been tailored to reflect US Assets Recovery’s role in the global supply chain as a privately held refiner of precious metals. This policy pertains specifically, though not exclusively, to the sourcing and procurement of all metal-bearing materials that we refine, including those containing gold, silver, or any platinum group metals.

Recognizing the risks of significant adverse impacts associated with the extraction, trading, handling, and exporting of minerals from conflict-affected and high-risk areas and acknowledging our responsibility to protect human rights and avoid contributing to conflict, we voluntarily commit to adopt this policy. We will widely disseminate it, incorporate it into contracts and agreements with our suppliers, to embed it into our standard operating procedures, processes, and systems where possible, and communicate it to and train our employees accordingly.

As a refiner, we believe this policy serves as a common reference for conflict-sensitive sourcing practices and risk awareness, from the point of extraction to the end user.

We are committed to refraining from any actions that contribute to the financing of conflict, and we pledge to comply with relevant sanctions resolutions as well as any applicable domestic laws that implement such resolutions.

Included above is a voluntary commitment to conduct due diligence in accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act, HR 4173, Section 1502. This commitment includes taking necessary actions to prevent sourcing from regions identified as financing or benefiting, directly or indirectly, armed groups in the Democratic Republic of the Congo (DRC) or any adjoining country.

This policy may be revised in the future and supersede any existing policies related to material sourcing and supply chain responsibility.

US Assets Recovery will not source or process any material from or operating in conflict-affected and high-risk areas, we will neither tolerate nor profit from, contribute to, assist with, or facilitate the commission of any party’s actions that involve:

• Any forms of torture, as well as cruel, inhuman, and degrading treatment, are unacceptable.
• Any form of forced or compulsory labor refers to work or service that is exacted by an individual under the threat of penalty, for which the individual has not volunteered.
• The worst forms of child labor.
• Other egregious human rights violations and abuses include widespread sexual violence, war crimes, serious violations of international humanitarian law, crimes against humanity, and genocide.
• War crimes, serious violations of international humanitarian law, crimes against humanity, and genocide.

We will promptly suspend or discontinue engagement with upstream suppliers if we identify a reasonable risk that they are sourcing from, or are linked to, any party committing serious abuse as defined as described above.

We will not tolerate any direct or indirect support to non-state armed groups through the extraction, transportation, trade, handling or export of materials. “Direct or indirect support” to non-state armed groups through the extraction, transportation, trade, handling or export of minerals includes, but is not limited to, procuring minerals from, making payments to, or otherwise providing logistical assistance or equipment to non-state armed groups or their affiliates who:

• Illegally control mining sites, transportation routes, trading points for minerals, and upstream actors in the supply chain.
• Illegally tax or extort money or minerals at access points to mine sites, along transportation routes, or at locations where minerals are traded.
• Illegally tax or extort intermediaries, export companies, or international traders.

We will promptly suspend or discontinue engagement with upstream suppliers if we identify a reasonable risk that they are sourcing from, or are linked to, any party providing direct or indirect support to non-state armed groups.

Anti-Bribery and Corruption

USAR maintains a zero-tolerance policy regarding the giving and receiving of bribes, as well as bribery and corruption in any form. USAR strives to adhere to best practice standards and complies with all relevant laws in every jurisdiction in which it operates, including the requirements of the Foreign and Corrupt Practices Act (US) and OECD guidelines.

Any suggestion of corruption or any official investigation may damage the reputation of USAR, its officers, and employees, and could affect its ability to conduct business. USAR is committed to conducting business ethically, even if this limits its ability to acquire new business, restricts the use of agents or business partners, or results in delays in ongoing operations.

Our Policy is:

• We will neither pay bribes nor condone the offering of bribes on our behalf.
• We will neither request nor accept bribes, nor will we agree to their acceptance on our behalf.
• We will establish procedures to minimize the risk of bribery or corrupt behavior, including a clear whistleblowing policy and mechanism.
• We will provide training for our staff and representatives on our Anti-Bribery and Corruption Policy.
• We will conduct monitoring to ensure compliance with our Anti-Bribery and Corruption Policy.
• We will make reasonable efforts to ensure that all individuals conducting business on our behalf adhere to these principles or similar standards.
• We will conduct thorough due diligence on all our new and existing business partners.
• We will regularly review and revise our Anti-Bribery and Corruption Policy as necessary to reflect changes in corruption risk, legislation, and best practices.

Anti-Money Laundering (AML) / Know Your Customer (KYC)

USAR acknowledges and fully supports the necessity of preventing money laundering and the financing of terrorist and criminal activities. In accordance with the US Patriot Act and international regulatory standards, USAR has established an Anti-Money Laundering (AML) policy that includes formalized procedures and inquiries to assess our business relationships. By providing regular training to enhance the identification of risks and suspicious activities, we strengthen our programs. Additionally, USAR ensures the effectiveness of its program by conducting independent audits.

USAR requires that all businesses are vetted. USAR surveys customers to gather identifying information about themselves, key management personnel, and beneficial owners of organizations. USAR utilizes tools to check for negative news and sanctions lists for both companies and individuals. If we are unable to verify an identity or if a customer poses a risk of money laundering or criminal activity, we will refrain from conducting business with them. All customers are subject to regular monitoring of suspicious activity or changes in their status.