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China Banknote Great Wall Precious Metals Co., Ltd. Enterprise Standard Standard Category: Management Standard Standard Number: ZCCC / G. 营 .011 Standard Version: First Edition Standard Name: Gold and Silver Supply Chain Due Diligence Management Measures Alternative Document or Standard Number: No Effective Date : 2016.01.01 Main control department: No.

1 page, 6 pages of gold and silver supply chain due diligence management methods In order to combat systematic or widespread human rights violations, avoid donating to armed conflicts, and comply with high standards of anti-money laundering and counter-terrorism financing, according to the "London Precious Metals Market Association ( LBMA) Responsible Gold and Silver Guidelines require that the China Banknote Great Wall Precious Metals Co., Ltd. gold and silver supply chain due diligence management measures be specially formulated.

1. Scope This method applies to all suppliers related to China Banknote Great Wall Precious Metals Co., Ltd. (hereinafter referred to as the "Company") gold and silver transactions, gold and silver commissioned refining and other businesses. The sources of gold and silver involved in these measures include mineral gold and silver, recycled gold and silver, and various forms of stocked gold and silver produced after January 1, 2012.

2. Terms and definitions The terms and definitions involved in these measures adopt the content established by the LBMA Responsible Gold and Silver Guidelines.

3. Organizational structure and personnel responsibilities

3.1. Organizational structure The company has set up a special organization for the due diligence of the gold and silver supply chain. Its structure is as follows: Compliance Director (Company Executive) Compliance Specialist of the Planning and Finance Department (designated part-time) Compliance Specialist of Marketing Department (designated part-time)

3.2. Responsibilities of various personnel 3.2.1. Responsibilities of compliance director 1) Preside over and be fully responsible for the due diligence of the company's gold and silver supply chain. 2) Supervise and inspect the due diligence process of the gold and silver supply chain, and assess whether the due diligence is adequate; if it is deemed necessary, additional documents or information are required. 3) Take appropriate measures to reduce risks until the risks are eliminated for the gold and silver supply chain or transactions that have identified risks.

Standard number: ZCCC / G. 营 .011 Gold Supply Chain Due Diligence Management Measures Standard Version: First Edition Page 2 of 6

4) If there is a high-risk gold and silver supply chain or transaction, it should report to the company's senior management and take strict control measures; after being authorized by the top management, it is responsible for approving the new gold and silver supply chain that is rated as high risk.

5) Regularly train employees on responsible gold and silver standards and supply chain due diligence policy.

6) Responsible for drafting and revising the company's gold and silver supply chain related policies and guidelines.

7) Provide the necessary accurate information for the company's senior management to perform their due diligence responsibilities.

3.2.2. Responsibilities of Compliance Officer of Marketing Department

1) Strictly implement supply chain due diligence measures and high-risk gold and silver supply chain evaluation standards.

2) Responsible for collecting and maintaining sufficient gold and silver supply chain certification documents.

3) Verify the qualifications of the transportation company and insurance company, track and properly keep each batch of waybills, and analyze and evaluate the transportation routes through which the goods pass.

4) Conduct regular on-site surveys of important gold and silver suppliers.

5) Assist and encourage gold and silver suppliers to commit and confirm in writing to comply with the provisions in Appendix II of the OECD Conflict Affected Areas and High Risk Areas Responsible Supply Chain Due Diligence Guidelines.

6) Responsible for collecting and summarizing the opinions and suggestions of the internal employees of the company on the due diligence of the gold and silver supply chain.

7) The due diligence process and abnormalities in gold and silver transactions are reported to the compliance director in a timely manner. 3.2.3. Responsibilities of Compliance Officer of Planning and Finance Department

1) Strictly implement supply chain due diligence measures and high-risk gold and silver supply chain evaluation standards.

2) Responsible for collecting and maintaining sufficient gold and silver supply chain certification documents. 3) Completely save all transactions and financial documents of the gold and silver suppliers for a period of at least 5 financial years.

4) Evaluate financial data of gold and silver suppliers to clarify their business relationship purpose and original information.

5) Responsible for collecting and summarizing the opinions and suggestions of the internal employees of the company on the due diligence of the gold and silver supply chain.

6) The due diligence process and abnormalities in gold and silver transactions are reported to the compliance director in a timely manner.

3.2.4. Responsibilities of Compliance Specialist of Precious Metal Depot

1) Strictly implement supply chain due diligence measures and high-risk gold and silver supply chain evaluation standards.

2) Responsible for collecting and maintaining sufficient gold and silver supply chain certification documents.