CONTEXT
STK Capital Investment Fund LLC is a company specializing in trading gold and precious metals for
the luxury industry.
STK Capital Investment Fund LLC we are fully committed to ensuring that all our sources of supply
are ethical, legitimate, conflict-free and respect human rights.
STK Capital Investment Fund LLC adheres to the high standards set by the OECD, LBMA and RJC, as
well as, in particular, the UAE Anti-Money Laundering/Finance of Terrorism (AML/CFT) law, the
Control of Trade in Precious Metals and Articles of Precious Metals (PMCA) and the Due Diligence
and Transparency Regulations on Conflict Minerals and Metals and Child Labor (DDTrO). These
high standards and laws are designed to combat money laundering, terrorist financing and human
rights abuses at every point in the precious metals supply chain. Our compliance with these
standards and laws is certified by recognized third-party audits.

HOW WE DEAL WITH COMPLIANCE ISSUES
We operate with high ethical, moral and socially responsible standards, offering fair prices to our
partners. Integrity, honesty and transparency are the foundations on which our business is built.
We require our employees and business partners involved in the precious metals supply chain to
comply with our Gold Supply Chain Policy and to implement it rigorously through appropriate
management systems.
Our policy is implemented through a comprehensive management system that includes a rigorous,
risk-based approach to due diligence.
STK Capital Investment Fund LLC Risk Management Policy has been developed and implemented
to ensure that our commitments and procedures are strictly aligned with the OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas,
the Gold Supplement, the LBMA Responsible Gold Guidance, the RJC Code of Practice and Chain of
Custody, and UAE law.
We are committed to aligning our practices with international standards for responsible sourcing,
fully integrating the UN Sustainable Development Goals.

GRAVE ABUSE RELATED TO THE EXTRACTION, TRANSPORTATION OR TRADE OF MINERALS
When supplying or operating, we will not tolerate or profit from, contribute to, assist or facilitate
the commission by any party of:
i) Any form of torture, cruel, inhuman or degrading treatment or punishment;
ii) Any form of forced or compulsory labour, which includes any work or service which is exacted
from a person under the menace of any penalty and without his or her voluntary consent;
iii) The worst forms of child labour;
iv) Other gross human rights violations and abuses, including widespread sexual violence;
War crimes or other serious violations of international humanitarian law, crimes against humanity
or genocide.

SUPPORT FOR ILLEGAL NON-STATE ARMED GROUPS OR PUBLIC/PRIVATE SECURITY FORCES
We will not tolerate any direct or indirect support for illegal non-state armed groups or illegal
public/private security forces in the extraction, trade, processing or export of minerals. “Direct or
indirect support” includes the procurement of minerals from, payment to, or provision of logistical
or material assistance to such groups or their affiliates that:
i) Illegally control mining sites, transportation routes, mineral trading points, and upstream actors;
and/or
ii) Illegally tax or extort money or minerals at access points to mining sites, transportation routes,
or mineral trading points; and/or
iii) Illegally tax or extort middlemen, export companies, or international traders.
We recognize that the role of public or private security forces at mining sites or along
transportation routes should be solely to uphold the rule of law, protect human rights, and protect
legitimate mining and trade routes from interference with legitimate mining and trade.

BRIBERY AND MISREPRESENTATION OF THE ORIGIN OF MINERALS
We will neither offer nor accept bribes and will actively oppose any attempts to solicit bribes to
conceal or falsify the origin of minerals or to misrepresent taxes, fees and royalties paid to
governments in connection with the extraction, trade, processing, transport or export of minerals.
Our policy prohibits employees from offering or receiving bribes or facilitation payments. We also
require transparency and full compliance from all partners in the supply chain to ensure that our
sourcing is legal, conflict-free, ethical and socially responsible.

MONEY LAUNDERING
We actively support initiatives to eliminate money laundering where we identify a reasonable risk
of it occurring in connection with the extraction, trade, processing, transport or export of
minerals. This includes illegal taxation or extortion at access points to mining sites, along transport
routes or at trading points operated by upstream suppliers.

TRAINING
A regular training programme is conducted to keep relevant staff up to date with standards, due
diligence, KnowYourCustomer (KYC) and KnowYourProduct (KYP) best practices.

BEYOND REGULATIONS
Our ultimate goal is to supply our customers with responsible gold. Compliance with the LBMA and
RJC standards for environmental protection and corporate social responsibility is particularly
important to us and the local communities we serve. We ensure that our suppliers’ processes
minimise environmental impact, promoting responsible and sustainable practices. Responsible
gold for us means not only meeting standards, but also actively participating in the development of
the local community.

GRIEVANCE MECHANISM
STK Capital Investment Fund LLC has established internal and external communication
mechanisms. Concerns regarding our supply chain can be raised anonymously via email:
compliance@stkcif.com. Any suspicion or knowledge of illegal or unethical practices should be
reported to the Legal and Compliance Department or via email. The Compliance Officer handles all
external communications related to supply chain risks and informs management of any newly
identified risks. Management will then develop an action plan for prompt resolution.
Internal communication mechanisms are governed by the Code of Conduct and Ethics for
Employees.

ANNUAL REPORT
STK Capital Investment Fund LLC has performed due diligence on its precious metals supply
chain as required by various laws and standards, such as the DDTrO. In 2025, the company did
not identify any risk of sourcing precious metals from Conflict-Affected and High-Risk Areas
(CARAH).
STK Capital Investment Fund LLC has also fulfilled its duty of care with respect to human rights,
having identified no adverse impacts in 2025, neither among its employees nor among its
direct suppliers. Similarly, no cases of child labor were identified in 2025.
STK Capital Investment Fund LLC’s LBMA Compliance Report and third-party audit report are
available on its website. STK Capital Investment Fund LLC’s Supplier Code of Conduct can be
requested via compliance@stkcif.com.
STK Capital Investment Fund LLC is audited annually by the UAE Central Precious Metals
Control Office and an accredited independent audit firm to verify compliance with its duty of
care and validate its procedures.

Approved by the Mr, Zapryan Todorov CEO .