Code of Conduct and Anti-Bribery Policy

We do not offer, pay, request or accept bribes, facilitation payments or improper advantages, directly or through agents, to public officials or private parties, including to obtain mining, export or customs documents. We record gifts and hospitality above a nominal value and never give them to influence a decision.

• We describe material, grades, origins and documents accurately, and we say plainly when we cannot supply something.
• We never present documents from one lot, mine or company as belonging to another.
• We keep supplier identities confidential where agreed, but never at the cost of misrepresenting origin.

We expect suppliers to respect the rights of workers and communities, to meet health, safety and environmental law in their country, and to avoid child and forced labour. We visit producers, and we ask for evidence rather than assurances.

Anyone acting for ARAM is bound by this code under written agreement, is subject to due diligence before appointment, and is paid only by traceable bank transfer against documented services.