Our Code of Business Conduct and Ethics
We operate under the strictest custodial guidelines and corporate governance, insuring the total integrity and safety of the gold and silver that you own in your Clear Title Account. Accordingly, the Company has adopted a Code of Business Conduct and Ethics (the “Code”).
In addition the Company adheres to the business standards established by the London Bullion Market Association (“LBMA”). The LBMA is an international trade association, representing the London market for gold and silver bullion which has a global client base. This includes the majority of the gold-holding central banks, private sector investors, mining companies, producers, refiners and fabricators.
The Company’s designated Corporate Compliance Officer has over thirty years experience at the senior executive level in the back office functions and operations of financial services organizations. The Senior Management Committee and Corporate Compliance Officer operate under strict corporate policies and guidelines to insure the total integrity and safety of the bullion and cash holdings within all client Clear Title Accounts. The Company maintains and reviews written compliance policies and procedures which are included in its Code of Business Conduct and Ethics. Included in the Code is a policy for the handling and safeguarding of all material, non-public information. Part of the Corporate Compliance Officer’s duties includes a review and attestation from all key personnel for the safeguarding of this information.
Corporate Risk Management
Strategic Gold Corporation believes that risk management is fundamental to its mission. The Company was created to respond to the systemic risks to the financial system identified during the financial crisis of 2007-2009 and which we believe continue to pose an ongoing threat.
The Company believes that the only way to insure against systemic risk is to directly own reserve assets or safe haven assets which are held outside the financial system. Direct ownership of physical gold and silver uniquely meets this criterion since they are the only non-financial assets that are highly liquid and easily held outside of the financial system.To ensure that we fulfill this business strategy and philosophy, we have developed a comprehensive Enterprise Risk Management (ERM) program which arms the Company with the tools and capabilities to overcome the barriers that arise in striving to protect our clients. By realizing that risk and control is everyone’s responsibility, the Company proactively identifies and manages the risks that it is exposed to in the normal course of operations.
By incorporating risk management into our daily business practices and by integrating the related performance measures into our operations, the ERM program ensures that we maintain the highest ethical standards by living our core values. Utilizing a “top down” and “bottom up” approach to measuring, responding and controlling risk exposures and any correlations at client account and enterprise levels we strive to continuously improve our enterprise-wide risk controls.
Our ERM program allows us to identify not only the risk mitigation activities, but also to anticipate and act on potential opportunities – therefore challenging conventional wisdom to create better solutions for our clients. Risk management is a circular process. The undertaking of risk management procedures leads to the identification of previously unidentified sources of risk. For this reason, our ERM program is expected to be a living process, and will be continuously updated for changes in risk management opportunities and threats.
Our ERM program proactively identifies, assesses, reports and controls risks. This comprehensive approach to risk management promotes broad strategic thinking and analysis, while fundamentally integrating the Company’s core values and beliefs. To this end, we believe that risk management is one of our key features.
Independent Bullion Auditor
An Independent Bullion Auditor, BDO International, is assigned to provide sight verification of all bars and serial numbers to match Strategic Gold inventories and verifies that our bullion inventories match client accounts. All bullion holdings are independently inspected and verified by BDO International on a quarterly basis. Each owner receives a personal audit report with their quarterly account statement.
Clients at all times own a clear, unencumbered and defined amount of gold or silver bullion held exclusively in the form of investment grade ‘Good Delivery’ bars that are professionally managed in accredited vaults, and are fully insured.
Independent Transaction Auditor
Our objective is to provide the highest levels of transparency while maintaining privacy and security for our clients. To this end, we have implemented a control system of governance and audit trail to protect the assets we administer on behalf of our clients. Strategic Gold retains the services of Livingston and Haynes, an Independent Transaction Auditor to act as a third party verifier of all client account transactions and to prevent un-authorized cash or bullion withdrawal.
This policy ensures that:
- The client’s transactions are properly authorized;
- The client’s assets are safeguarded against unauthorized or improper use; and
- The client’s transactions are properly recorded and reported.
To ensure internal control and governance, client funds are segregated in a secure bank account. Within this account, the control of a two-man rule is employed to achieve the highest level of security. Under this rule, all transactions require the verification of both the Independent Transaction Auditor and an officer of Strategic Gold.
With this policy, all funds transferred to your account maintained by Strategic Gold Corporation remain your sole property and under your direct control. Strategic Gold has no authority or control over these funds except pursuant to written instructions from you or your Designated Representative that have been verified by the Independent Transaction Auditor. Independent oversight and authorization of transactions ensures that you remain in control of your cash assets at all times.
Bullion Delivery Withdrawals
Likewise, all bullion assets in your Clear Title Account remain your sole property and under your control. Strategic Gold has no authority or control over these bullion assets except pursuant to written instructions from you that have been verified by the Independent Transaction Auditor. Independent oversight and authorization of bullion withdrawals ensures that you remain in control of your bullion assets at all times.