Grievances and Complaints Committee

The Committee formed the Department to deal with Grievances, concerns and complaints submitted by the employees, clients, customers, and other affected end user and stakeholders.

A written objection to the business operation resolution issued concerning the employees, clients, customers, and other affected end-user and stakeholders. Which is submitted by him/her to remove the injustice or wrongdoing he/she claims to have been witnessed or inflicted.

The Objectives of the Grievances:

1. Ensures that materials acquired, and services provided are obtained with adherence to human rights, labor, environmental and highest business ethics.
2. Ensures to achieve justice, employment satisfaction and the stability of the legal status of the employees.
3. Ensures that business activities meet the international market ethics and standard.
4. Ensures that business operates in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and its Supplement on Gold, DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain and Responsible Jewellery Council.
5. Maintain the business status in providing the highest standard in operating in the gold and silver industry.

Grounds for the Grievance and Procedure for submission: 

1. Human rights violations; force and child labor, torture, serious abuses, etc.
2. Contravention of the law, regulations or by-laws
3. Accounts and financial Manipulation
4. Fraud, bribery, corruption and solicitation
5. Falsification of documents
6. Tolerates law and regulation violators and supporter of non-state armed group and all forms of criminal activities.
7. Employee misconduct and labor practices.
8. Health and safety; working conditions.

 We encourage all to submit reports along with solid proof of documents and provide as much information as possible for the investigation. Reports may submit to the following email address: compliance.officer@sampreciousmetals.com

Confidentiality: 

Committee will guarantee with the outmost capability of SAM Precious Metals to keep the identity of the concern person confidential with respect to all events. Documents and files, they view and all information that comes from their knowledge will solely be used for the purpose of investigating illegal activities or non-compliance allegations to SAM Precious Metals policies.

 Escalation Procedure and Timeline for Grievances and Whistleblowing

1.     Submission of Grievance

• Responsible Party: Complainant (employee, client, customer, stakeholder, or end-user)
• Method: Submission via email to compliance.officer@sampreciousmetals.com
• Content Required:
  
  • Full details of the grievance or complaint
  • Supporting documentation and evidence (if available)
  • Name and contact information (optional for anonymous reporting)
• Timeline: At any time
• Confidentiality: Full confidentiality guaranteed by SAM Precious Metals

2.     Acknowledgement of Receipt

• Responsible Party: Compliance Officer
• Action: Issue written acknowledgment of grievance receipt
• Timeline: Within 3 working days of submission

3.     Preliminary Review and Risk Assessment 

• Responsible Party: Grievances and Complaints Committee
• Actions:
  
  • Assess completeness of submission
  • Evaluate urgency and severity
  • Determine if the issue falls under Committee jurisdiction
• Timeline: Within 7 working days from acknowledgment 

4.     Initiation of Investigation 

• Responsible Party: Assigned Investigators (from Compliance or Legal Dept.)
• Action:
  
  • Conduct internal investigation
  • Request clarifications or additional documents (if needed)
  • Interview relevant parties (when applicable) 

• Timeline: Investigation must be initiated within 10 working days from the preliminary review
• Duration: Completed within 20 working days, unless extended due to complexity 

5.     Escalation (if necessary) 

If the issue cannot be resolved internally or requires higher authority or external reporting:

• Escalation to:
  
  • Senior Management
  • Board Compliance Sub-Committee
  • External Auditor (if legally required or high-risk breach)
• Timeline for escalation decision: Within 5 working days of investigation conclusion

6.     Issuing Final Decision and Corrective Actions 

• Responsible Party: Grievances and Complaints Committee
• Action:
  
  • Issue a reasoned written decision
  • Recommend corrective or disciplinary actions
  • Notify the complainant (unless anonymous)
  • Update internal risk management systems
• Timeline: Within 10 working days from conclusion of investigation 

7.     Follow-Up and Monitoring 

• Responsible Party: Compliance Officer
• Action:
  
  • Ensure implementation of corrective measures
  • Monitor resolution progress
  • Re-assess for recurrence risk
• Timeline: Periodic check-ins at 30, 60, and 90 days after decision 

8.     Recordkeeping and Reporting 

• Responsible Party: Compliance Department
• Action:
  
  • Securely store grievance records
  • Report summary of grievances and actions to senior management quarterly
  • Include anonymized data in annual compliance reports

The Issuing of Decisions:

The Committee shall issue its reasoned resolutions base on the Grievance and Whistleblowing mechanism and appropriate corrective actions shall made if necessary.