The overall risk rating as for KYC or KYP can be
Low: The supplier/client presents no specific risk, no mitigation measures.
Medium: Requires ongoing monitoring however no further mitigation measures.
High: Requires ongoing monitoring and appropriate mitigation measures.

2.2 Risk Management Process & Traceability
At Isabella Jewellers & Refiners (Pty) Ltd the risk management system is based on the structured and
systemic process which considers Isabella Jewellers & Refiners (Pty) Ltd internal and external risks
assessments.

2.3 The main elements of the risk management process:
2.3.1 Communicate and consult: communicate and consult with internal and external stakeholders
as appropriate at each stage of the risk management process
Initial Risk Assessment -After a due diligence process the risk level for a new potential Supplier/
client shall be assigned.
2.3.2 Establish the context: Establish the external, internal and risk management context in which
the rest of the process will take place – the criteria against which risk level will be evaluated should
be established and the structure of analysis defined (See supplier assessment form)
2.3.4 Identify risk: identify where, when, why and hoe events could prevent, degrade, delay or
enhance the achievement of Isabella Jewellers & Refiners (Pty) Ltd objectives.
Periodic risk level reviews shall be conducted by the managing director annually.

As per the OECD due diligence guidance for responsible supply chain of Minerals from conflict-
affected and high-risk areas, Isabella Jewellers & Refiners (Pty) Ltd has adapted their policy as per

the standard requirement.
2.3.5 Record Risk: Document the risks that have been identified in the risk assessment forms
2.3.6 Analyse risk: Identify and evaluate existing controls. Determine consequences and like hood
and hence rate the level of risk by analysing the range of potential consequences and how these
could occur.

Guidelines on assessments know-how to assess the specific risk as follows:
1. Supplier/ Client registered office location: –
Rated Level Risk – High
• Information & documents obtained through Isabella Jewellers & Refiners (Pty) Ltd –
KYC process.
Low – where the registered entity is outside of South Africa and in a low-risk area.
Medium – where the registered entity is in South Africa.
High – where the registered entity is outside of South Africa and in high-risk area.
2. The Mined Gold or Recycled Gold originates from, has transited or has transported or has
been transported via a conflict affected or human rights abuse high risk area.
Rated Level Risk – High
• Review the context of each location of gold origin and transport, relying on evidence
from credible sources, and use fair efforts to make reasonable determinations based
on the destination of conflict-affected and high -risk areas advised in the ‘Red-Flag
Country list’
Low – where no material is sourced from these areas (if a SA entity and has no import
permit, this reduces the risk). All source is recycled or scrap.
Medium – where supplier/client does have an import permit but based upon the
information collected in KYC & KYP documentation can assess that they do not purchase,
mine or transport any gold in or from a conflict affected or high risk areas.
High – where supplier does produce or transport gold in a conflict-affected or high-risk area.
3. The Mined Gold is claimed to have originated from a country that has limited known
reserves, likely resources or expected production level of gold.
Rated Level Risk – High
• Review the information provided against available reports for the country in
question relying on evidence from credible sources, and fair efforts to make
reasonable determinations based on the information at hand.
Low – where no mined material is sourced from countries outside of SA, or where the
material is sourced from a country where it is well known to have significant gold reserves
Medium – where mine material is sourced from a country that has limited known reserves,
likely resources or expected production levels of gold, but the volume is significant in
comparison to the total market share, but sufficient information is obtained to substantiate
their market share.
High – where mine material is sourced from a country that has limited known reserves, likely
resources or expected production levels of gold and the volume is in excess of the total
market share for that country.
4. The Recycled Gold comes from a country where gold from conflict affected and human
rights abuse high risk areas are known, or reasonably suspected, to transit
Rated Level Risk – High
Low – where no material is sourced from these areas (if a SA entity and has no import
permit, this reduces the risk significantly).

Medium – where supplier does have an import permit but based on information collected in
the KYC and KYP documentation can assess that they do not purchase, mine or transport any
gold in or from a conflict affected or high risk areas.
High – where supplier does produce or transport gold in a conflict-affected or high-risk area.
5. Gold Supplying supplier/ client or other known upstream companies are in a country
representing high-risk for money laundering.
Rated Level Risk – High
• Review the context of each location of countries representing high risk for money
laundering relying on evidence from credible sources and use fair efforts to make
reasonable determinations based on the information obtained during the KYC & KYP
processes

Low – where no material is transacted by Gold-supplying supplier/client or other money-
laundering (if a SA entity and has no import permit, this reduces the risk significantly)

Medium – where no material is transacted by gold supplying supplier/client or other known
upstream companies located in a country representing high risk of money-laundering.
Where entity does have an import permit but based on information collected in the KYC and
KYP documentation can assess that they do not purchase, mine or transport any gold in or
from a conflict affected or high-risk areas.
High – where the Gold-supplying counterparty or other known upstream companies are in a
country representing high-risk for money-laundering.
6. Gold supplying supplier/client or other known upstream companies or their beneficial
owners with significant influence over the gold supplying supplier/client are politically
exposed persons.
Rated Level Risk – High
• Review the context gold-supplying supplier/client or other known upstream
companies or their beneficial owners with significant influence (significant control,
greater than 25% voting rights) relying on evidence from credible sources and use
fair efforts to make reasonable determinations based on the information obtained
during the KYC & KYP processes
• Gold -supplying supplier/client or other known upstream companies or their
beneficial owners (counterpart)
Low – where the supplier/client are not PEPs (where ownership and supply chain easily
identified)
Medium – where supplier/client have identified PEPs but do not have/exercise significant
control and /or influence.
High – where the supplier/client have identified PEPs but do have / exercise significant
control and or influence.
7. Gold-supplying supplier/client or other known upstream companies are active in higher
risk business activity such as arms, gaming and casino industry, antiques and arts, sects
and their leaders.
Rated Level Risk – High
• Review the context of gold supplying supplier/client or other known upstream
companies, relying on evidence from credible sources, and use fair efforts to make
reasonable determinations based on the information obtained during the KYC & KYP
processes.