This statement sets out the steps that SeventyNine have taken to prevent slavery and human trafficking in its supply chains and in other parts of its business.

About SeventyNine

Seventy Nine is a trading brand of Saith Deg Naw Ltd of 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. We are based in the UK and provide bullion related services for wealth managers, family offices, and corporate clients. We recognize that clients have sensitive and correct  ESG requests and are looking for ethical gold that has been sourced compliantly. Thus at SeventyNIne we want to establish our brand as in supporting and recognizing human right and ethical initiatives in the precious metals supply chain. Our statement policy below have been made in accordance with section 54(1) of the Modern Slavery Act 2015 which we vow to continue as part of our ethical policy framework within the business.

SeventyNIne Ethos

SeventyNine does not permit, condone or otherwise accept any form of slavery and/or human trafficking or link to corporate entities or ultimate beneficiary owners that may have links (as defined in the Modern Slavery Act 2015). This includes any SeventyNine employees, subcontractors, contractors, agents, partners or any other organization, entity, body, business or individual with whom we engage or do business.

We support ILO conventions and standards and will regularly conduct audit reputational trails of partner organizations and entities to ensure that we are not involved in any irregular practice that will infringe anti-money laundering requirements.

As we particularly work with Wealth Managers and other private bankers, Know your Customer (KYC) we will undertaker not just basic due diligence but EDD (Enhanced Due Diligence) particularly for high value orders to make sure that we are enabling any form of layering  or integration of illicit funds into the banking or non-banking system. This includes following up on customers and other business partners to report to the SeventyNine management, legal or compliance teams for any concerns they may have regarding our direct activities in sourcing bullion. Wherever possible we will recommend Ethical or Green Gold  where the supply chain can be fully traced in order to ensure that our customers have access to compliant fine minted bars, and coinage. This is to ensure that we reduce the exposure to enabling investment proceeds increasing the plight of those trapped by slavery or human trafficking.

If SeventyNine suspects any agent, partner organization or employee are involved in slavery and human trafficking by an associated entity, we reserve the right to report such suspicions, provide appropriate information to the relevant authorities and to suspend or terminate any associated engagement, business arrangement or contract.

This policy reinforces other relevant policies including the No Child or Forced Labour policy, Diversity policy, Freedom of Association policy and Wage and Hour Practices policy. For further information please refer to:

• Universal Declaration of Human Rights: http://www.un.org/en/documents/udhr/
• International Labour Organisation’s Core Conventions: http://ilo.org/global/standards/introduction-to-international-labourstandards/conventions-and-recommendations/lang--en/index.htm

Prioritizing Ethical and Green Gold

We want to make sure that our customers have chance to purchased LBMA certified bullion which has come from Refiners who have derived bullion from mining sources that have been verified . Our goal is to also increase education and awareness so that there is a deeper connection between precious metal mine workers and the knowledge where there principal product has come from. Responsible mined source precious metals are being demanded by the Next Generation and at SeventyNine we want to be at the forefront of providing ethical green gold to our customers.

Green Gold refers to bullion where the whole supply chain from mining to refinement to eventual minting can be tracked with the ethical ordinance. Traceable gold is important so that our customers know that the product origins have not only fully documentation but there has been environmental stewardship, human fights and health safety of the labour force have been put  first. Green gold is handled in segregated refining centres so that casting, minted and semi-finished products are not tainted with non green gold.

Our supply Chain

SeventyNine source from a number bullion from a number or well established refiners across the world with the majority and contract marketing mainly to local agencies concentrated in the UK and Europe. Such contractors are involved in timely project work to advance our advertising platform, production work, market research operations and other marketing support services.

We work with a network of affiliates and partners across the European region to serve clients where we do not have a physical presence.  We conduct due diligence when considering new firms for addition to our affiliate network and are closely engaged with the clients they serve on our behalf so that we would be made aware of any concerns regarding the affiliates’ work.

Addressing Risks in the Supply Chain

While SeventyNine, as a professional services firm, may have a low risk of slavery or human trafficking within our business activities, we have established a broad policy approach to reflect our commitment to principles-based behaviour and delivering on societal and operational responsibilities.

SeventyNine specifically requires suppliers to comply with the Modern Slavery Act 2015 in contracts where appropriate. In our standard contract terms with agencies, we require contractors to confirm they have not committed an offence under anti-slavery laws, are not under investigation for such an offence, are not aware of circumstances in their supply chain that could give rise to an anti-slavery offence and have effective controls in place to ensure compliance with anti-slavery laws.

We know that maintaining high standards of conduct is not achieved solely by good intentions.  It is achieved by clarity in articulating our mission and values to both our employees and stakeholders. To conclude SeventyNine is committed to the following core statements:

 –        We are committed to honesty, transparency, and fair dealing;

 –        We ensure business activity aligns with the interests of all stakeholders: clients, employees, and parties with whom we interact; and

 –        We strive to model best practice in all areas of our business. We do not violate legal obligations.

Hitherto, SeventyNine team believe that there is not a significant risk of slavery or human trafficking in our business nor we do not have any key performance indicators specific to this area.  We endeavour to continue monitor and review our customer policy and  business practices to reduce any slavery or human trafficking risk particularly in compliance and anti-money laundering training for our employees.