THE Voluntary Modern Slavery Statement 2020

This voluntary Modern Slavery Statement is made on behalf of Gold Corporation group of companies trading as The Perth Mint. Voluntary Modern Slavery Statement 2020 Voluntary Modern Slavery Statement 2020

Contents

Our commitment 5 Our structure, operations and supply chains 6 Policies and governance 9 Modern slavery risk assessment and mitigation activities 10 Comprehensive due diligence 14 Looking forward 15 Approval 16

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Our commitment

The Perth Mint is committed to However, our strong commitment respecting human rights and to our corporate social responsibility opposes slavery in all its forms. and our enduring vision to be the We endeavour to operate our sustainability benchmark for the business activities in a manner precious metals industry means consistent with the United Nations we are voluntarily undertaking Guiding Principles on Business and to make this inaugural modern Human Rights, and with the Voluntary slavery statement describing the Principles on Security and Human risks of modern slavery within our Rights. operations and supply chains as well as the actions we are taking to assess, We seek to give all our employees, address and remediate these risks. and those who conduct work on our behalf, the tools and knowledge We recognise that this is a continuous to identify the risk of modern journey and commit to the ongoing The Perth Mint slavery practices across our business review of our current policies, is committed to operations and to empower them to processes, systems and procedures as take action against it. We expect our well as to working with our suppliers, respecting human customers, suppliers and external customers and stakeholders to identify stakeholders to be alert to possible and rectify any gaps in our current rights and opposes involvement in modern slavery, and to business practices that may cause slavery in all its forms. work to prevent and address it. an increased risk of modern slavery practices across our areas of operation. As a Government Trading Enterprise of the Western Australian Government In preparing this modern slavery governed by the Gold Corporation Act statement the Chief Sustainability 1987, Gold Corporation and its group Officer engaged with relevant officers of companies trading as the Perth across all three of the entities within Mint are not reporting entities for the Gold Corporation Group trading the purposes of the Modern Slavery as The Perth Mint in the processes of Act 2018 (Cth) and are not required to risk assessment and the development submit a modern slavery statement and implementation of relevant risk under that legislation. mitigation actions.

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Our structure Our structure, operations The Perth Mint employs some 500 employees and contractors across our Australian based operations, which comprise our precious metals refinery and mint, depository, treasury, shop and exhibition and supporting corporate functions. and supply chains

Government of Western

The Perth Mint is Australia’s largest, We are a precious metals refining, For the purposes of the fully integrated precious metals manufacturing, minting, marketing, Commonwealth Modern Slavery enterprise providing premium gold, distribution and storage business. Act, 2018, Gold Corporation is the silver and platinum products and Structured as a vertically integrated reporting entity. Holding Company Gold Corporation services to markets throughout the entity we operate across the entire world. precious metals value chain. Our business activities span the entire Management responsibility is based spectrum of the precious metal value on functional and business lines chain from refining of precious metals designed to provide a comprehensive to the delivery of physical products and and cohesive service to our many investment solutions to markets the customers around the world. GoldCorp Australia Western Australian Mint world over.

Trading Name The Perth Mint

Activities

Retail Tourism Precious Manufacturing Gold and Precious Treasury Precious metals Exhibition metal blank and marketing silver refining, metal linked services storage manufacture of investment manufacture investment and numismatic and marketing products , other of value-added minted items bullion bars and related products

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Policies and governance

The Perth Mint adopts the Modern Our commitment to sourcing socially Slavery Act 2018 (Cth) definition of responsible doré and secondary metal modern slavery. extends beyond these accreditations. Our refinery is also certified under Our internal controls include our the Conflict-Free Smelter Program Code of Conduct, Responsible Metals and abides by the responsible gold and Supply Chain Policy and our guidelines and standards set by the Human Rights Policy which require LBMA and the World Gold Council to employees, directors, officers, and all maintain industry best practice. Our operations Our supply chains third parties that conduct business We refine both newly mined and Although over 70% of our gold is with, or on behalf of The Perth Mint secondary gold and silver feed from sourced domestically in Australia, we to act with fairness and integrity, across Australia and beyond. Our do source up to 90 tonnes per year observing high standards of personal precious metals feedstock is sourced from other countries. 90% of the gold and business ethics. from 20+ countries around the globe. we source is from primary producers The Perth Mint is Australia’s only gold in the form of doré or semi-refined We produce a range of gold and silver We produce a range and silver refinery, weight master and bars, we also source up to 30 tonnes investment bullion bars, minted bars assayer accredited by all five of the per year in the form of accredited of gold and silver and coins for investment and collector world leading commodity exchanges – scrap metal. markets, supplying to over 130 investment bullion the London Bullion Market Association countries. We also provide precious Our silver feedstock is sourced from (LBMA), the New York Commodity metals storage and investment accredited suppliers from Australia and bars, minted bars and Exchange (COMEX), the Shanghai programs to over 60,000 customers overseas, both in the form of newly coins for investment Gold Exchange (SGE), the Tokyo across these 130 countries. mined metal and secondary metal. Commodity Exchange (TOCOM) and Our platinum feedstock is sourced in and collector markets, the Dubai Multi Commodities Centre Our Shop and Exhibition operate a its fully refined form from accredited (DMCC). To achieve and maintain retail and tourism function in Perth overseas suppliers. supplying to over these accreditations, The Perth that attracts customers both locally Mint’s standards and procedures are and internationally, with close to In addition to precious metal supply, 130 countries. continuously tested, reviewed and 60,000 visitors in FY20. we also source other goods and scrutinised, including audits of our services from local and international supplier and customer onboarding suppliers. Goods procured include processes to ensure adherence to the chemical reagents, packaging for Human Rights standards prescribed by our products, other consumable the accrediting organisations. items used in our refining and minting processes, and IT equipment. Services procured include precious metal logistics services, facilities management, insurance products and risk management solutions, corporate services including marketing, and equipment maintenance.

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Modern slavery risk assessment and mitigation activities

Although we strive to eliminate the Precious metal mining and extraction Precious metals investment activities risks of modern slavery practices processes Risks: Investment in precious across our business and supply Risks: In emerging economies, metals can present risks for money chains, the high intrinsic value of our mining operations tend to rely on laundering, terrorism finance, inputs and products, along with the large quantities of unskilled labour, corruption and trade with sanctioned international nature of our operations which may pose various human countries and other conflict means there are risks that require rights risks such as a forced labour, regions. The risk of modern slavery ongoing assessment, mitigation and at bonded labour or debt bondage, child is considerably higher in conflict times risk remediation. labour, excessive working hours, and countries and therefore precious During the FY20 financial year, The deceptive recruitment. metals investment activities may Perth Mint engaged a Big 4 accounting finance modern slavery practices firm to assist The Perth Mint in Precious metal transportation such as forced labour, bonded undertaking a risk review across our activities labour or debt bondage, forced child business, for all entities within our Risks: Metal transportation, particularly labour, excessive working hours, and Risk mitigation Our Whistleblower Policy describes This includes the requirement for structure. Our precious metals supply in emerging economies can result in deceptive recruitment. Our precious and non-precious metal how we protect any of our staff or suppliers to regularly re-affirm their chain was also assessed in detail by modern slavery risks including bonded supply chain risks are mitigated by the contractors who speak out about any commitment to The Perth Mint’s the LBMA and found to be compliant labour or debt bondage, excessive Non-precious metal supply chain following: concerns they have. Supplier Code of Conduct, and to provide The Perth Mint with the right with the LBMA’s Responsible Gold working hours, and deceptive risk assessment Our Human Rights Policy has been recruitment. to periodically audit suppliers. Guidelines (RGG). Our non-precious metal supply chain Holding our people accountable: reviewed by our external legal advisors The outcomes of these reviews inform faces many of the same risks as other All Perth Mint employees must comply and recommendations have been Precious metal refining activities Counterparty due diligence: the following section. organisations operating in a global incorporated. Risks: The secondary precious metals with key internal controls including economy. These include: our Code of Conduct and our Human All our metal sourcing is underscored sector including the buying and by our Responsible Metals and Supply Precious metal supply chain risk refining of precious metal scrap, Rights Policy. All employees involved in Holding our suppliers Sourcing of non-precious metals the sourcing or sale of precious metals accountable: Chain Policy, and all suppliers of assessment jewellery and other secondary goods and materials precious metals are subject to Know must also comply our Responsible We expect our customers and The global extraction and trade in materials can pose modern slavery Your Customer (KYC) checks at time Risks: Packaging, process chemicals Metals and Supply Chain Policy. suppliers to adhere to our standards, precious metals has a high risk of risks. These risks include providing of onboarding, as well as ongoing and reagents, IT hardware and other ethics and values. Our Supplier Code exposure to modern slavery practices. financial support to modern slavery Our employees are provided with reviews every 6 months for high and goods may be sourced from overseas of Conduct includes requirements This risk is evident in all areas of the practices as well as directly incurring the resources to ensure compliance medium risk customers, and every factories where there is a risk of a relating to labour practices and supply chain, from the extraction forced labour, bonded labour or debt with key policies and procedures. 12 months for low risk customers forced labour, bonded labour or debt modern slavery. Any counterparties and mining industries through to bondage, forced child labour, excessive Our employees undertake training as over 5000oz. bondage, forced child labour, excessive who compromise their commitment downstream value-added product and working hours, and deceptive working hours, and deceptive part of their induction process and investment industries. The intrinsic recruitment, especially when are required to complete a bi-annual to ethical business practices, conflict- In addition, all high-risk customers are recruitment. rd value and fungible nature of precious conducted in emerging economies. compliance training review which free sourcing, and human rights subject to a 3 party mine site visit compromise their ongoing business and audit at time of onboarding, and metals dictates that an enhanced level Supply of services includes modules relating to Human of due diligence is required to maintain Rights and modern slavery. with The Perth Mint. every three years thereafter. Additional Risks: Although considered low risk reviews may be triggered by adverse supply chain transparency and integrity, During FY19/20 we completed in Australia, there remains some risk We actively encourage all staff and media or other events, including and to ensure the risks of modern an operating model review of our that some organisations providing contractors to report any dealings Our Responsible Metals and Supply slavery practices are guarded against. non-precious metals supply chain services such as cleaning and facilities or transactions where they perceive Chain Policy was reviewed by external function and the findings have been management may engage in modern an increased risk of modern slavery parties during the FY20/21 financial implemented or are in the process of slavery practices including forced practices internally or amongst any year. The Policy was strengthened being implemented. labour, bonded labour or debt bondage, counterparties. where improvement opportunities excessive working hours and deceptive were identified. recruitment.

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In 2020 we selected not to commence or continue precious metal supply arrangements with a number of organisations due to concerns relating to Modern Slavery and other Environmental, Social and Governance (ESG) risks in those companies’ supply chains.

Customers for our minted products Where we identify any activity that Monitoring the effectiveness of and depository services undergo may indicate an increased risk of our actions Know Your Customer (KYC) checks at modern slavery practices, we suspend Our learning management system onboarding and are subject to ongoing all activity with the supplier, customer allows us to track the number of review as required by our AML/CTF or stakeholder pending review by our employees who have completed their program. Risk and Compliance function. Where human rights and modern slavery necessary, we engage third party All suppliers of goods and services not training modules. We will continue assessors to visit the counterparty directly related to our precious metal to monitor workforce compliance operations to undertake on ground supply chain (reagent and chemical with these compulsory training assessments. Pending outcome of the suppliers, packaging, transport, IT requirements. site visits, where a high-risk operation hardware etc) are subject to our is identified, The Perth Mint will cease We will also continue to report to our Supplier Code of Conduct and to Know all relationships with the identified executive team on our precious metal Your 3rd Party (KY3PS) review at time counterparty. supplier KYC reviews and implement a of onboarding. process of continuous improvement in Where the assessment process has Our KYC and KY3P procedures are terms on learnings from these reviews, revealed a risk that is considered compliant with the Australian Anti- especially where we identify changes medium to high, an increased Money Laundering and Counter in risk profile of our suppliers. assessment and review regime is Terrorism Financing Act 2006 and implemented with reduced tolerance include identification of conflict for any inconsistencies. affected and high-risk countries that are more likely to see modern slavery In 2020 we selected not to commence practices and other human rights or continue precious metal supply abuse. arrangements with a number of organisations due to concerns Our KYC and KY3P procedures are relating to Modern Slavery and other overseen by our central Risk and Environmental, Social and Governance Compliance team with customers or (ESG) risks in those companies’ supply suppliers who trigger further review chains. assessed by this team. As we continue to develop our due Our KYC systems, process and diligence activities and deepen our procedures were subject to an audit engagement with suppliers, we will by a Big 4 Accounting Firm during focus on developing remediation FY19/20. Whilst this audit was approaches for those impacted by focused on AML / CTF compliance, modern slavery. it did touch on modern slavery and other ESG related risks. A number of improvement opportunities were identified and are being actioned by the Risk and Compliance team in conjunction with the appropriate business areas.

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Comprehensive due diligence Looking forward

Our due diligence systems and Our due diligence activities in this The Perth Mint is committed to We engaged a dedicated Responsible We will continue to decline any procedures are compliant with the period has included: preventing modern slavery practices Metals Manager across our core business relationship with any entity standards of the Responsible Gold • Responsible Metals Audit under the in our supply chain. The recent operations. This role will be focussed that we deem to be unsuitable due Guidance, the OECD Due Diligences for Responsible Gold Guidance (LBMA) restructure of our executive team on the review, updating and to concerns about modern slavery or Responsible Supply Chains of Minerals • External review of our precious and introduction of a number of continuous improvement of relevant other ESG risks. from Conflict and High-Risk Areas and new senior roles in our business is policies and practices relating to metals sourcing by a Big 4 Finally, we will continue review our the relevant local legislations to which reflective of this commitment. responsible metals sourcing. accounting firm policies, standards and procedures, we comply. • Internal Audit Program, conducted As well as changes in our operations We have commenced the process seeking to improve our internal During the FY20-21 reporting period, by a Big 4 accounting firm leadership through the appointment of selecting a new enterprise wide controls beyond their current levels The Perth Mint has been reviewed • Non-precious metals supply chain of a Chief Operating Officer, we have KYC/KY3P software that will improve and provide dedicated, bi-annual by our external accreditors (LBMA) review, conducted by a Big 4 bolstered our risk and compliance accuracy and consistency across our training on the risks of modern slavery for compliance with modern slavery accounting firm function with the appointment of a customer, supplier and employee/ with a view to increasing awareness guidelines. We have also conducted • Operational Risk Review conducted dedicated General Manager Risk and contractor onboarding processes and of this key risk throughout the enhanced internal reviews of our by a Big 4 accounting firm Compliance and introduced a Chief assist us to further mitigate the risk of organisation. policies, processes and procedures. • Independent review of our non- Sustainability Officer to drive our vision modern slavery in our supply chains. precious metal supplier onboarding to be the sustainability benchmark for process by a specialist consulting the precious metals sector. firm Where opportunities for improvement were identified as part of these reviews, we moved quickly to implement these recommendations. We will continue to decline any business relationship with any entity that we deem to be unsuitable due to concerns about modern slavery or other ESG risks.

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Approval

This statement has been approved by the members of the Gold Corporation Board on 22 March 2021.

Sam Walsh AO Chairman

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