SECTION IFeedstock Policy
The Partnership accepts no mined product for refining. Feedstock is confined to documented, non-mined silver-bearing material. Any material whose character or documentation cannot be established to the satisfaction of the compliance officer is declined and returned. This policy is deliberate: it removes the House from the risk categories that attach to mined material at origin, and it is verified at every annual audit.
SECTION IIOECD Due Diligence Guidance
The Partnership maintains its due diligence in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, applying its five-step framework across the House:
| Step | Obligation | Application at SCPCP |
|---|---|---|
| 1 | Establish strong management systems | A written supply chain policy, a designated compliance officer, and a chain-of-custody record opened for every lot at intake. |
| 2 | Identify and assess risk | Know-your-counterparty files and red-flag screening for every account and every lot, maintained by the compliance office. |
| 3 | Manage identified risks | Enhanced monitoring or refusal. The House declines material and business before either dilutes its standard. |
| 4 | Independent third-party audit | An annual audit of the House's due diligence practice, described in Section IV. |
| 5 | Report annually | A due diligence report made available to clients and, on request, to counterparties and their auditors. |
No lot is melted without a complete file. The framework is examined by an independent reviewer at every annual cycle.
SECTION IIIUAE Ministry of Economy Framework
The Partnership is established in the United Arab Emirates and conducts itself within the Ministry of Economy's regulatory framework for the precious metals sector, in particular:
- Due Diligence Regulations for Responsible Sourcing of Gold (2022) — the Ministry's mandatory due diligence framework for the sector, built on the OECD five-step model, observed by the House in its gold trading and applied by policy to its silver operations to the same standard.
- AML/CFT legislation — the obligations arising under Federal Decree-Law No. (20) of 2018 concerning anti-money laundering and combating the financing of terrorism, as amended, and its executive regulations, applicable to dealers in precious metals and stones.
- Ministerial Decree No. (68) of 2024 — the responsible sourcing requirements applying to refining and recycling operations and to participants in the supply chain.
- Annual reporting — the independent third-party review of due diligence practice conducted for each twelve-month cycle, with the report submitted to the Ministry within the prescribed period following completion of the cycle.
Registrations, and the House's standing under the framework, are documented and available to clients through the compliance office.
SECTION IVAnnual Supply Chain Audit
Once in every calendar year, the Partnership engages an independent auditor to examine the House end to end — from counterparty due diligence files, through intake, laboratory, and refining records, to the vault register.
Scope of the audit
- Conformance of the House's due diligence with the OECD five-step framework;
- Observance of the feedstock policy — no mined product accepted;
- Integrity of chain-of-custody records from intake to cast bar;
- Conformance with the UAE Ministry of Economy framework;
- Reconciliation of the vault register against clients' recorded positions.
The auditor's summary findings are made available to clients by the compliance office. Material findings, should any arise, are remediated on a plan agreed with the partners and re-examined at the following cycle.
SECTION VAudit Consultation
Ahead of each annual cycle, the compliance office holds consultations with clients and counterparties who wish to prepare documentation, understand the audit scope, or raise matters for the auditor's attention. To request a consultation, submit the particulars below or write to compliance@scpcp.ae; the compliance office replies by correspondence.