Question: Has the company established a system to accurately review the information they gathered in Step 1?
Answer:
Yes
7983854
2018
Unverified - Added by Steward
p. 4 "The supplier due diligence process includes collecting and verifying the suppliers' business and financial details, verifying that the supplier and/or its beneficial owners are not on international money laundering and terrorist financing watch lists or listed as Politically Exposed Persons, obtaining trade reference information, and confirming that the suppliers maintain an active bank account with a financial institution. The Mint also requests copies of the suppliers' AML/ATF/CFS policies, as applicable. For new mining suppliers, the Mint conducts a mining capacity analysis where capacity information has been made available. In the case of high-risk supply chains, in addition to assessing the suppliers, the Mint has conducted an assessment of the third-parties involved in the supply chain, namely the transportation companies used to transport the gold-bearing material to the Mint. Furthermore, for those high-risk suppliers who send the Mint material tha has been sourced outside of North America, the Mint has performed a review of the suppliers' company details and site visits, and has conducted a country risk assessment to determine the risk associated with receiving material from the international site. In addition, the Mint conducts appropriate scrutiny and monitoring of transactions undertaken through the course of the relationship for all suppliers rated moderate or high-risk. All shipments fo matieral received for processing are subject to inspection and validation that the material shipped conforms to the suppliers' previously established material type. The Mint Office employees verify that the required supporting documentation and written declarations have been received before the material is accepted for processing."