Our Commitment to Ethical Conduct

At Ozzione Group LTD, we recognise that the global commodities trade, spanning scrap metals, precious metals, and mineral resources, operates across diverse jurisdictions, some of which present elevated risks of bribery, corruption, and unethical business practices. We are unwavering in our commitment to conducting all business affairs with the highest standards of integrity, transparency, and legal compliance.

We have zero tolerance for bribery, corruption, or any form of improper influence, whether direct or indirect. This policy applies to all directors, employees, agents, contractors, and business partners acting on behalf of Ozzione Group LTD, and we hold every stakeholder accountable to these principles.

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Our Approach to Risk Management

To safeguard our reputation and uphold our legal obligations, we implement a proactive and rigorous framework to prevent, detect, and address corrupt practices:

• Mandatory Risk Assessments: Before entering into any business relationship or transaction, our employees are required to conduct thorough anti-bribery and corruption risk assessments on all counterparties, including suppliers, clients, intermediaries, and joint venture partners. These assessments evaluate jurisdictional risks, ownership structures, business practices, and any potential red flags.
• Due Diligence Protocols: We perform enhanced due diligence on high-risk parties, including politically exposed persons (PEPs), entities in high-risk jurisdictions, and any transaction involving cash, precious commodities, or third-party intermediaries.
• Clear Rules and Prohibitions: Our code of conduct explicitly prohibits:
  • Offering, promising, or giving bribes or kickbacks
  • Receiving or soliciting improper payments or gifts
  • Facilitation payments (speed money) under any circumstances
  • Using agents or consultants to circumvent anti-bribery laws
  • Engaging in any form of fraud, money laundering, or sanctions evasion
• Record-Keeping and Transparency: All financial transactions and business records must be accurately documented, transparent, and auditable. We maintain strict accounting controls to ensure no payment is made without proper authorisation and legitimate business justification.

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Reporting and Investigation

We encourage a culture of openness and accountability, where all employees and stakeholders feel empowered to speak up about concerns without fear of retaliation.

If any suspicion arises that our anti-bribery and corruption policies are being abused, circumvented, or ignored, we commit to:

• Conducting a prompt, thorough, and impartial investigation into the matter
• Engaging external legal or forensic experts where necessary to ensure objectivity
• Taking decisive and proportionate disciplinary action against any individuals found to have violated this policy, up to and including termination of employment, contract termination, and referral to relevant law enforcement authorities
• Cooperating fully with regulatory bodies and law enforcement agencies where required

We also provide confidential whistleblowing channels through which concerns can be reported anonymously, and we strictly prohibit any form of retaliation against those who raise genuine concerns in good faith.

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Our Guiding Principles

Our anti-bribery and corruption framework is rooted in a broader ethical foundation that defines who we are as an organisation. All employees, partners, and stakeholders are made aware of and expected to uphold the following core principles:

• Respect for Human Rights: We actively support and align with the Universal Declaration of Human Rights, ensuring that our business activities do not contribute to human rights abuses, forced labour, or exploitation anywhere in our supply chain.
• Environmental Responsibility: As a trader of metals and mineral commodities, we recognise our duty to operate sustainably. We are committed to sourcing materials responsibly, minimising environmental harm, and promoting circular economy practices within our industry.
• Compliance and Ethics: We adhere strictly to all applicable laws and regulations, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act (FCPA), international sanctions regimes, and anti-money laundering legislation. Beyond legal compliance, we hold ourselves to a higher ethical standard—doing what is right, even when no one is watching.

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Training and Awareness

We believe that prevention begins with education. All employees receive regular training on anti-bribery and corruption risks, recognising red flags, and understanding their personal obligations. We also ensure that our business partners are made aware of our expectations and agree to comply with our ethical standards.

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Monitoring and Continuous Improvement

Our anti-bribery and corruption programme is subject to ongoing review and enhancement. We regularly assess our policies, controls, and risk landscape to ensure they remain effective and aligned with evolving regulatory requirements and industry best practices. We also conduct periodic internal and external audits to verify compliance.

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Contact for Concerns

If you have any questions about this policy, require guidance, or wish to report a concern, please contact:

Compliance & Ethics Officer
Ozzione Group LTD

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Ozzione Group LTD — Conducting Business with Integrity, Everywhere We Operate.