Compliance

Compliance and Due Diligence

Last updated 27 September 2026

We work from mine to market: our Zimbabwe mining company is growing its own mining rights and works in joint venture with established mines, and our Singapore trading company buys, takes title and sells on its own account. That means we carry the risk of who we deal with and where the material comes from, so we check before we commit.

Know your counterparty

Before we enter into any contract, we identify and verify every counterparty, whether buyer or seller. We ask for:

• Certificate of incorporation and a current company registry extract.
• Directors, shareholders and ultimate beneficial owners.
• Identity documents for authorised signatories and evidence of their authority.
• Registered and operating addresses.
• Bank details on company letterhead, in the company's own name.

We review these checks again when ownership or circumstances change, and we do not proceed where we cannot establish who we are dealing with.

Sanctions

We screen counterparties, their beneficial owners, and the vessels and banks involved in a trade against the sanctions lists of the United Nations, Singapore, the United Kingdom, the European Union and the United States. We do not deal with sanctioned persons, or trade in breach of any sanctions regime that applies to us or our partners.

Anti-money laundering

• We do not accept or make cash payments.
• We pay and receive funds only through regulated banks, and only to or from an account held in the name of the contracted counterparty.
• We do not accept payments from, or make payments to, third parties.
• Trades are settled against shipping and inspection documents, presented through banks.
• Where we suspect money laundering or other criminal proceeds, we report it to Singapore's Suspicious Transaction Reporting Office.

Responsible sourcing

Our minerals come from our own mining rights and joint ventures in Zimbabwe, and from third-party producers across Southern Africa. We apply the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. In practice:

• We buy only from producers that hold valid mining and export licences, and we check those licences before we commit.
• We require documented origin and chain of custody for every cargo.
• We do not buy material connected to child labour, forced labour, armed groups or serious human rights abuses.
• Grade and weight are confirmed by independent inspection at loading.
• Where we cannot establish origin, we do not buy.

Joint ventures with mines

Before we enter a joint venture with a mine, we verify its mining rights, licences and ownership with the issuing authorities where possible, check its owners and directors against sanctions lists, and review its health, safety and environmental standing. Joint ventures are documented in writing, and we hold our partners to the sourcing standards on this page.

Trades between our sister companies

Forest Castle Group Pte. Ltd. (Singapore) and Forest Castle Mining (Private) Limited (Zimbabwe) are sister companies under common ownership. When one sells to the other:

• Prices are set against published indices - LME, Fastmarkets and CRU - on the same terms we would offer an independent party.
• Grade and weight are confirmed by independent inspection, as for any cargo.
• The supply is subject to the same sourcing and documentation checks as any third-party producer.
• We disclose the relationship to our banks and to counterparties who ask.

What we do not trade

We do not trade gold, other precious metals or precious stones.

Anti-bribery and corruption

We do not offer, pay, request or accept bribes, kickbacks or facilitation payments, directly or through anyone else, in any country. We comply with Singapore's Prevention of Corruption Act and the equivalent laws wherever we do business, and we expect the same of the parties we trade with.

Protect yourself from fraud

Commodity trading attracts impersonation and advance-fee fraud. People may use our name, logo or documents that look like ours. Our position is simple:

• We never ask for advance fees to release cargo, documents, samples, allocations or contracts.
• We only pay and receive funds through a bank account in the name Forest Castle Group Pte. Ltd. We will never ask you to pay an individual or another company.
• Genuine emails come only from @forestcastlegroup.com. Treat anything from a free email service or a lookalike domain as suspicious.
• We never change bank details by email alone. If you receive new payment instructions, confirm them with us through a contact you already know before sending any money.

Onboarding documents

Our own company documents, including our certificate of incorporation and company registry extract, are available to prospective counterparties on request. Write to info@forestcastlegroup.com.

Raising a concern

If you have a concern about our conduct or about a transaction involving us, write to info@forestcastlegroup.com. We treat every report seriously and in confidence.