Hatton Garden Metals - AML Policy Statement
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Policies and Statements

AML Policy Statement 2021

As a bullion Company operating in the scrap metal industry we must be vigilant to the possibility that criminals may use our business to launder money. We are vigilant and aware of the risks associated with the industry in which our business operates. As a Company we are committed to our Company policy and procedures ensuring that any risks associated with money-laundering are identified and suitably mitigated. Our procedures are in line with the latest money-laundering and anti-terrorism legislations. We are fully compliant with all current regulations; Money Laundering Regulations 2007, Proceeds of Crime Act 2002, the Terrorism Act 2000 and The Money Laundering and Terrorist Financing (Amendment) Regulations 2019.

As a Company we are committed to providing all employees with training at their point of employment and also regularly throughout the year, further to this, any changes to regulations are clearly communicated with employees in compulsory staff training. These processes are then reviewed periodically. We also ensure that our response in turn is thus reviewed. Our Company has a Nominated Officer (Chris Lyons) who is supported by Zoe Lyons.

Hatton Garden Metals have a policy that all employees must read and understand, so that they know what is expected of them, including the process of reporting any suspicious activity. Our training provides our employees with the skills to be able to identify a suspicious transaction and report this as an SAR (Suspicious Activity Reports) which in turn will be forwarded to the National Crime Agency if applicable. Our policies and procedures depict that all records are retained for a period of 5 years after the business relationship have ended with the customer. These are readily available along with any computer records being kept fully up to date.

As a company we conduct customer due diligence and carry out checks where appropriate for customer transactions. Our internal Hatton Garden Metals system is fully co-operative with our needs as a business to be able to identify any suspicious behaviour, including but not limited to, the safe storage of customers personal details, photographic ID’s and IP addresses. We retain this information in full compliance with GDPR legislation.

Social, Ethical & Environmental Principles

Hatton Garden Metals Ltd has a set of SEE policies which all employees are to read and understand and operate within. HGM has adopted a statement to ensure that its business responsibilities to our various stakeholders are met. Director, Christopher Lyons has been designates as of office for SEE matters.

Our Fair Gold policy – HGM operates ensuring that all our Public customers registering with us through our site are agreeing to the following condition before transacting with us.

If using the Services of HGM as a public customer , you hereby warrant to us in the following terms:

  • You are at least 18 years of age
  • You have the capacity to enter into a legally binding contract
  • You have good title to the gold, silver platinum or precious (Metal) which you intend to sell. Such metal will, in the event of a sale to us in accordance with these terms and conditions, be sold free from any liabilities or adverse claim of any type whatsoever
  • You are using the services privately, independently and in your personal capacity only (and not on behalf of any other person) and you are not using them for any commercial, business or retail purposes (whether directly or indirectly)
  • All information which you submit to us (irrespective of the manner in which this is submitted) is true and accurate in material respects. If the metal which you intend to sell or buy to or from us is worth in aggregate value £1,000 or more, you agree that you will provide us with such proof of identification and/or proof of address as we may require this to satisfy our legal obligations

If using the Services of HGM as a trade customer, you hereby warrant to us in the following terms:

  • The beneficial owner and has the legal right to sell goods to Hatton Garden Metals
  • It has acquired such goods from persons who have provided evidence to be the legitimate owners of the goods
  • It has taken all necessary precautions to prevent acquisitions of trade of goods obtained through or related criminal activities
  • It has received such goods in compliance with the relevant legislation of their country and origin
  • It does not use child labour to carry out any work or service
  • It, if applicable complies with all environmental legal regulations

The company further declares that it makes this present declaration on behalf of its shareholders, members of the board, employees and representatives. The Company undertakes to advise Hatton Garden Metals Ltd of any changes to this declaration.