Effective Date: [Insert Date]

At Paragon Bullion, we are committed to conducting business with integrity, transparency, and respect for applicable laws and internationally recognized responsible business practices.

This policy outlines our approach to responsible sourcing, Anti-Money Laundering (AML), Know Your Customer (KYC), sanctions compliance, and ethical business conduct.

Responsible Sourcing

Where applicable, Paragon Bullion seeks to source precious metals, diamonds, gemstones, and related materials from suppliers that demonstrate responsible and ethical business practices.

We encourage our suppliers to:

• Operate in compliance with applicable laws.
• Respect human rights.
• Maintain responsible labor practices.
• Avoid child or forced labor.
• Promote environmentally responsible operations.
• Maintain appropriate business records.

Supplier Due Diligence

Where appropriate, Paragon Bullion may conduct reasonable due diligence on suppliers, including:

• Business verification
• Regulatory status
• Reputation assessments
• Compliance reviews
• Ownership verification

Anti-Money Laundering (AML)

Paragon Bullion is committed to helping prevent money laundering, terrorist financing, fraud, and other financial crimes.

Where required by applicable law or internal risk assessment, we may:

• Verify customer identity.
• Request supporting documentation.
• Assess transaction risks.
• Decline suspicious transactions.
• Report activities where legally required.

Know Your Customer (KYC)

For certain transactions, Paragon Bullion may request:

• Government-issued identification.
• Business registration documents.
• Proof of address.
• Authorized representative information.
• Source-of-funds information where appropriate.

Failure to provide requested information may result in delayed or declined services.

Sanctions Compliance

Paragon Bullion seeks to comply with applicable economic sanctions and trade restrictions.

We reserve the right to refuse or terminate business relationships that may violate applicable sanctions laws.

Record Keeping

Where required by applicable law, Paragon Bullion may retain records relating to customer identity, transactions, and compliance activities for legally required retention periods.

Fraud Prevention

Paragon Bullion reserves the right to verify information provided by customers and may suspend or refuse transactions where fraud, misrepresentation, or unlawful activity is reasonably suspected.

Reporting Concerns

Employees, suppliers, business partners, and customers are encouraged to report suspected unethical or unlawful conduct.

Reports will be reviewed appropriately and handled with reasonable confidentiality.

Continuous Improvement

Paragon Bullion periodically reviews its compliance practices and may update this policy to reflect legal developments, evolving industry standards, and operational improvements.