Introduction
- Kafaalat is a leading gold/mineral trading company in East Africa.
- Commits to ethical sourcing, aligning with OECD, LBMA, and Kenya’s regulations.
Due Diligence Commitments
Zero Tolerance For:
- Human rights abuses (child Labor, forced Labor).
- Corruption, money laundering, or tax evasion.
- Environmental/Labor law violations.
ESG Assessments Include:
- Supplier compliance with environmental/health laws.
- Pollution control and fair Labor practices.
Due Diligence Framework
- Governance: Dedicated policy, management controls, grievance mechanisms.
- Risk Identification: Flags for human rights violations, bribery, etc.
- Enhanced Due Diligence (EDD): For high-risk sources.
Onboarding Process
- KYC/AML Checks: Document verification, background checks, on-site visits.
- Document Retention: 7+ years (per Limitation Act).
Risk Assessment & Monitoring
- Suppliers categorized as Low/Medium/High/Extreme Risk.
- EDD for high-risk: Site visits, ESG reviews.
- Ongoing Monitoring: Annual re-onboarding for inactive suppliers.
Anti-Bribery & Corruption
- No bribes/gifts to influence decisions.
- Political Neutrality: No company donations to political entities.
- Gifts/Hospitality: Must be nominal and pre-approved.
AML/CFT Measures
- Designated AML Officer oversees compliance.
- KYC/CDD: Verify identities, beneficial ownership, sanctions screening.
- Employee Vetting: Police clearance, lifestyle audits.
Training & Compliance
- Mandatory training for staff/partners on due diligence, AML, ESG.
Consequences of Non-Compliance
- Contract termination or legal action.