Advanced Chemical Company - Step 5 Procedure
The purpose of this procedure is to help make informed decisions about responsibly sourced minerals in our supply chain based on the Responsible Minerals Assurance Process (RMAP) Standard. RMAP uses an independent third-party audit of smelter/refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards. The RMAP audit validates our company level management processes for responsible mineral procurement. Companies can then use this information to inform their sourcing choices. For more information on the RMAP standard please visit www.responsiblemineralsinitiative.org.
I. Company Information
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Company Name
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Advanced Chemical Company
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CID Number
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CID000015
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Company Address
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131 Bellows Street, Warwick, RI 02888
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Assessment Date (s)
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1/1/19 – 2/1/21
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Assessed Material
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Gold
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II. RMAP Assessment Summary
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Date of RMAP assessment
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4/13/21 – 4/15/21
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Assessment Firm
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SCS
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URL to most recent assessment summary report
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www.rba-online.org
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III. Company Supply Chain Policy
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Advanced Chemical is conformant with the RMAP assessment
and our supply chain policy is accessible on our website.
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www.advchem.com
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IV. Company Management Systems
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Management Structure
- CFO – Oversees due diligence to COO - oversees due diligence
- Finance Manager – Manages due diligence
Departmental Expectations
- Customer Service – Exercises due diligence regarding KYC procedures, receiving procedures
- Sales – Exercises due diligence regarding KYC procedures, ID Red Flags, ID CAHRA, ID Supply Chain Risks
- Refining – Exercise due diligence regarding receiving procedures, ID Red Flags, CAHRA
Relevant Trainings
- Finance, Customer Service, Sales, Refining annual RMI review was conducted on 5/31/22
- Onboarding training is conducted for any new member or Finance, Customer Service, Sales, Refining
Implemented management review and documentation on 6/30/22. Recent improvements to our due diligence program include updating our sourcing policy, CAHRA identification procedure, grievance mechanism and process, and supplier due diligence.
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Internal Systems of Control
- Responsible Sourcing Policy states that we uphold RMAP expectations and avoid sourcing from high risk sources
- Enforce supplier expectations and requirements through KYC procedures
- Review material upon receipt through our Lot Receipt Procedures
- Assign a unique lot number to, account for, and reconcile all gold containing material received, processed, and sold
- Conducting inventory controls throughout the refining process
- Continually update and monitor suppliers with annual account review and request updated KYC when applicable
- Ensure our Grievance Mechanism is accessible to all through the company website, utilize our Grievance Response Procedure as needed
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Record Keeping System
- KYC information is stored on our internal cloud accessible only by management for review and maintenance
- Refining lot retention kept in storage for 5 years – contains receiving, processing, settlement information
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V. Risk Identification
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Procedure to Identify CAHRA
The purpose of this procedure is to identify conflict-affected and high-risk areas (CAHRAs) that may exist in our gold supply chains. This procedure will be applied to supply chains (i.e. material, transit routes, suppliers) of all mined gold, recycled gold, and financial or refinery sources that are not conformant with the Responsible Minerals Assurance Process Standard annually or prior to sourcing new material or form new suppliers. The resources and criteria used to define CAHRAs are:
Table 1
CAHRA Identification Sources and Criteria |
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CAHRA criteria |
The country (or sub-country region) is classified a CAHRA if it: |
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US Dodd-Frank Act
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OECD Annex II risks: Direct or indirect support to non-state armed groups, or public or private security forces.
- Presence of armed conflict and widespread violence (Democratic Republic of the Congo)
- Transit risks (nine surrounding countries)
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- Listed as a Covered Country (i.e., Democratic Republic of the Congo, Central African Republic, South Sudan, Zambia, Angola, the Republic of Congo, Tanzania, Burundi, Rwanda, and Uganda)
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| European Union CAHRAs List |
- OECD Annex II risks: All risks.
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Global Risk Map Tool (RMI Risk Profile – overall risk)
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- OECD Annex II risks: All risks.
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- Ranked high or extremely high for overall risk on RMI’s Global Risk Map Tool
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Know Your Supplier (KYC)
- The purpose of this procedure is to complete Know Your Counterparty (KYC) evaluations of each supplier of gold material. We establish and implement basic KYC requirements to determine the identity, type of business relationship and legality of business operations for each supplier of gold material in accordance with Responsible Minerals Assurance Process (RMAP) standard. Our KYC procedure includes an evaluation of beneficiaries against global sanctions lists.
Supply Chain Risk Identification
- We evaluate any posed risks associated with Annex II of the OECD Due Diligence Guidance for Responsible Supply Chain of Minerals in our gold supply chains by leveraging our CAHRA identification and KYC procedures in addition to validating the type and origin of each transaction of gold containing material we source. Advanced Chemical Company has not identified any supply chain risks.
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VI. Risk Mitigation
- Advanced Chemical Company has not identified supply chain risks. However, we do have processes in place to respond to future risks should they arise. These include:
Map the Supply Chain:
Complete RMI Supply Chain Mapping Tool, conduct desktop research, on-site visits, assessment of anti-money laundering and counter-terrorism financing policies and procedures
Upon completion of supply chain mapping complete Responsible Minerals Initiative’s Audit High-Risk Workbook details OECD conformance expectations for high-risk sourcing
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