Compliance

Six controls, applied to every transaction.

None optional. None applied selectively.

Bound registers and labelled document boxes on archive repository shelving
Transaction file 01 / 06
An open handwritten account ledger, entries ruled and totalled by hand
Art. 01 — on file

Counterparty due diligence

Identity, registration and business standing verified before any transaction proceeds.

The stripped interior of a steel mill hall during dismantling, bare columns and a riveted truss roof over a swept floor
Art. 02 — on file

Proof of material origin

Origin evidenced for every parcel, the underlying contract referenced.

Container terminal seen from above, stacked boxes and gantry cranes along the quay
Art. 03 — on file

Transport documentation

Transport and waste-transfer paperwork issued before the vehicle is loaded.

The lobby of a bank safe deposit vault, the vault door standing open
Art. 04 — on file

Bank settlement only

Payment by bank transfer against invoice. No cash, no third parties.

Bound registers and labelled document boxes on archive repository shelving
Art. 05 — on file

Sanctions and AML screening

Counterparties screened against applicable lists, under applicable anti-money-laundering practice.

An open handwritten account ledger, entries ruled and totalled by hand
Art. 06 — on file

Records and retention

Identification, origin, weights, transport documents and payment reference, held and retrievable.

Limits

Four things we do not do.

  1. 01

    We do not accept cash, in any amount.

  2. 02

    We do not accept payment from an account that does not belong to the counterparty on the contract.

  3. 03

    We do not sell to private individuals.

  4. 04

    We do not ship material without evidence of how it arose.

Container terminal seen from above, stacked boxes and gantry cranes along the quay
Cross-border movement runs on the transport file
A completed file

What it contains.

Counterparty

Company extract, VAT registration, beneficial owner, signatory identification, sanctions screening record.

Material

Grade specification, analysis record, photographs, origin evidence, alloy verification.

Movement

Transport document, waste-transfer paperwork, receiving facility confirmation, weighbridge ticket.

Commercial

Written offer, delivery terms, final invoice, bank transfer reference.

File complete
Discuss a transaction How we trade