Due Diligence

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 B.W NVest

Crafted Precious Metals Dealer OCCC (Texas, USA). B.W NVest has business locations in the United States of America Austin, Texas April 2025, along with United Arab Emirates Dubai opening June 2025. Import Permits will be in Dubai with the companies opening. 

United States does not require Import Permit. 

We must declare on Import with Government Form FinCEN 105 USA

Supply Chain

Avoiding any type of conflicted minerals that directly or indirectly finance or benefit Armed Groups and/or involve other serious human right abuses in high risk and conflict affected regions. B.W NVest has developed a supply chain policy that we believe will become the NEW “standard”.  We utilize a robust 5 Step Procedure aligned with UAE MoE Due Diligence. We follow the OECD guidelines for responsible mineral supply chains. Programs such as Lexis Nexis, along with teaming up with Moody’s for a 3rd party investigation we can assure we are getting the most data possible to base logical business decisions. We also have the ability once we collaborate with a customer to be immediately notified when a RED FLAG arises. This gives us a 24/7 monitoring system for our customers. Teaming up with Salesforce to help implement a tracking of the Supply from Mine to Refinery. CEO Brian Warembourg and CFO John Macliver approved the policy, which will be reviewed monthly.   

Company Management 

The company prioritizes commitment to its supply chain policy, ensuring thorough adherence. Internally, a meticulous due diligence procedure is in place, encompassing the following key aspects:

CEO - Brian Warembourg 

CFO - John Macliver

The company has appointed a due diligence program manager (CFO) to coordinate the efforts of purchasing, quality, production department, and production). This ensures that each department adheres to their roles and responsibilities in implementing the due diligence program and reports any identified red flags and potential risks. The company trains key staff on the due diligence management system annually. Additional training is provided if the program is updated.

Internal Systems

In April of 2025, the B.W NVest updated its due diligence management system to align with OECD Guidance and MoE Guidelines to Due Diligence.

Record Keeping System

The company requires that all records related to due diligence programs be retained for a minimum of five years, utilized appropriately, and stored securely within the company's database.

Risk Identification

The company has a robust 5 Step Procedure to identify risks in the supply chain. Firstly, referring to the risks in the company's supply chain policy, the company established a procedure to identify CAHRAs the procedure includes the resources used, the criteria to define a "conflict-affected and high-risk "area as well as the frequency with which our determination is reviewed. The company uses the following resources to determine CAHRAs:

1) Lexis Nexis suite of software to navigate through complex environmental, social and governance data - enabling quick and easy identification of areas of risk and opportunity.

2) Moody’s 3rd Party Investigations. One of the most recognized companies of their kind for due diligence and risk assessments.

3) Internet Crime Complaint Center www.ic3.gov

4) The European Union's financial sanctions list is available on its external website at WWW.eeas.europa.eu.

5) Human Rights Index from the Human Rights Watch Report (www.hrw.org/world-report/2018)

6) World Justice Project Report. (http://worldjusticeproject.com)

7) U.S Sanctions List (http://sanctionsearch.ofac.treas.gov)

8) Five Step Procedure in accordance with MoE Due Diligence.

The company has implemented a comprehensive Know Your Counterparty (KYC) process, focusing on supplier legal status, identity verification, supplier mapping, and risk assessment. Our dedicated due diligence CFO meticulously reviewed the submitted information in collaboration with the MoE Due Diligence (UAE), OECD Standards, and the UN Sanction List, working closely with the purchasing team. In cases where discrepancies, errors, or missing details arose in the KYC documentation, the company promptly communicated these concerns to suppliers, urging them to provide updated and accurate information. When red flags arise, we will proactively engage with suppliers to promptly address and resolve issues.  B.W NVest reviewed all collected information following CAHRAs, sanctions list, local laws, and internal sourcing requirements.   Ensuring compliance and accuracy is paramount in our processes.

Risk Assessment

For material and supply chains identified as "high-risk," the company conducted enhanced due diligence. This process included:  

Assessing the context of Conflict-Affected and High-Risk Areas (CAHRAs)· Clarifying the chain of custody· 

Evaluating the activities and relationships of upstream suppliers· Identifying locations, conditions, and qualities related to the extraction, trade, handling, and export of minerals.

Ground Assessments

To effectively map factual circumstances, conduct on-site evaluations, and assess risks within high-risk supply chains, we utilize the following methodology for risk assessment in the absence of an upstream program:

1) The company undertakes fundamental research on the CAHRAs identified within our supply chain. This includes examining publicly available reports concerning the governance, security, and human rights contexts of the relevant countries, as well as reports specifically addressing human rights abuses associated with gold mining practices.

2) The company performs stakeholder mapping to guide its stakeholder engagement strategy. The company conducts a comprehensive KYC process for all suppliers and mines. The company, in partnership with others, collects minting documentation certificates for each material transaction and ensures that the refining facility is identified for every transaction.

Risk Mitigation

The company's supply chain policy outlines three risk mitigation strategies in accordance with OECD Guidance. Identified risks within high-risk supply chains are addressed as follows:

1) If the company identifies the supplier as a high-risk sourcing supplier to the senior manager, it may choose to continue business with the supplier while implementing a risk mitigation plan.

2) The company consults its suppliers, customers, and local stakeholders regarding the risk mitigation strategy to ensure its feasibility and effectiveness. Upon reaching a consensus with all parties, the company formulates a risk mitigation plan. The trader and the concentrator are required to participate in the implementation of this risk mitigation plan. The company collaborates with Moody’s and Lexis Nexis to continuously assess risks.