Supply Chain Management Policies

Solid Rock Capital Supply Chain Policy:

Solid Rock Capital (SRC) uses the following policy to ensure our business partners and practices both external and internal adhere with the world wide standards of human rights, ethical business, crime and/or money laundering in any form.  SRC will in no form participate in unethical, child labor, human rights violations, war crimes and/or any form of illegal activity.

SRC follows these principals.

1)          SRC follows OECD procedure and guidance of conflict mineral policy in Annex II.

2)          SRC ensures our origin of material is licensed by the local government and managed with best practices of human labor.  All transactions are vetted prior due diligence and all discovery is presented to management in a transparent manner.

SRC will terminate relationships with any operation not in good standing with the local government.  SRC will terminate relationships with any operation employing illegal and or unethical labor practices.

3)          SRC will not participate in money laundering and will only pay for material that is weighed and inspected by a third party top tier agency and or invoices for transportation that are previously agreed with management.

4)          SRC in no way shape or form will participate in business with non-state armed groups. 

5)          SRC will pay any taxes that are for its account and we affirm our counterparties shall be do the same when appropriate.  In no way will SRC participate in business that avoids taxation or maliciously avoids any government tax.

6)          SRC will not deal in business with bribery.  SRC officers will immediately cease business that demands a bribe and/or unwarranted incentive fee.

7)          SRC encourages all members to raise issues of concern immediately.

SRC encourages all business surrounding precious metals and conflict material to be well documented with paper files for at least 5 years.  SRC commits to training it’s employees and counterparties on the dangers of conflict minerals and to avoid any business as outlined but not limited to the above.

Solid Rock Capital (SRC) Anti-Money Laundering (AML) Policy:

SRC AML Policy is designed to ensure that all external and internal counterparties and procedures comply with the requirements and obligations set out in Bahamas Investment act and Central Bank regulations for AML/KYC, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by SRC Companies and includes:

1)   The appointment of a 3rd party oversight of sufficient seniority, who have responsibility for oversight of Group and Business Unit compliance with relevant legislation, regulations, rules and industry guidance;

2)   Establishing and due diligence towards assessing and eliminating any money laundering and terrorist financing risks to the Group;

3)   Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;

4)   Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

5)   The maintenance of appropriate records for the minimum prescribed periods;

6)   Training and awareness for all relevant employees; and

7)   The provision of appropriate management information and reporting to senior management of the Group’s compliance with the requirements;

SRC enforces this AML policy and trains staff to adjust and improve upon this policy.