Regulatory Disclosure.

ElionMT operates as a commodity trading house based in Québec, Canada, with activities that span several regulatory frameworks. We approach compliance as an integral part of commercial judgment rather than a peripheral function.

Where we refer below to a named policy, the full text is available on request to info@elionmt.com. We welcome counterparty due-diligence enquiries and respond to them in the spirit of reciprocity that institutional markets depend upon.

ElionMT does not transact with designated persons, and does not knowingly facilitate activity prohibited by applicable sanctions regimes. Our sanctions programme is aligned with:

• Canadian regimes, including the Special Economic Measures Act (SEMA), the United Nations Act, the Justice for Victims of Corrupt Foreign Officials Act and the Freezing Assets of Corrupt Foreign Officials Act.
• United Nations Security Council consolidated lists.
• United States OFAC sanctions (including SDN and sectoral lists), United Kingdom OFSI consolidated lists, and European Union restrictive measures.

Our measures include systematic screening of counterparties and controlling interests at onboarding and on an ongoing basis, restrictions on jurisdictions subject to comprehensive sanctions, end-use and end-user diligence for dual-use goods, and escalation to senior management for any potential concern.

We apply a risk-based approach to anti-money-laundering (AML) and counter-terrorist financing (CTF). Our programme is aligned with the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the guidance issued by FINTRAC, as well as the Financial Action Task Force (FATF) Recommendations.

Measures include verification of counterparty identity and beneficial ownership above a 25 % threshold (or lower on a risk-sensitive basis), politically-exposed-person and adverse-media screening, source-of-funds and source-of-wealth enquiries for higher-risk situations, and ongoing transaction monitoring with escalation and reporting channels for suspicious activity.

We have zero tolerance for bribery and corruption, whether involving public officials or private parties. Our programme is aligned with the Canadian Corruption of Foreign Public Officials Act (CFPOA), the United States Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010 and the OECD Anti-Bribery Convention.

Our measures include a written anti-bribery policy, a register for gifts and hospitality above defined thresholds, due diligence on intermediaries and agents, restrictions on political contributions, and periodic training. We do not make or tolerate facilitation payments, and we cooperate fully with legitimate investigations.

We are committed to the integrity of the markets in which we operate. We prohibit insider dealing, the manipulation of prices, and the dissemination of false or misleading information. Where our activities bring us within the scope of a specific market-abuse regime — such as the Canadian securities framework administered by the Autorité des marchés financiers (AMF) and the Canadian Securities Administrators, the UK/EU Market Abuse Regulation (MAR) or the rules of the US Commodity Futures Trading Commission (CFTC) — we hold ourselves to the requirements of that regime.

Our internal controls include information-barrier principles, rules on personal account dealing, and surveillance of communications where lawful.

We commit to respect internationally recognised human rights as set out in the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. We apply due diligence to our supply chain to identify and mitigate risks of forced labour, child labour and human trafficking.

Where our organisation meets the applicable thresholds, we comply with the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) and publish the required annual report. We extend equivalent expectations to our counterparties and service providers.

For transactions involving tin, tantalum, tungsten, gold or cobalt, we apply the principles of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Where applicable, we also have regard to the EU Conflict Minerals Regulation 2017/821 and to section 1502 of the US Dodd-Frank Act.

For precious metals, we prioritise counterparties aligned with recognised industry standards such as those of the London Bullion Market Association (LBMA) and the Responsible Jewellery Council (RJC).

Our Code of Conduct sets out the ethical standards expected of our directors, employees and contractors, and the standards we expect of our counterparties. It covers compliance with law, integrity in commercial dealings, respect for people and communities, fair employment, and protection of the environment. The full Code is available on request.

We operate a confidential channel for reporting suspected misconduct, available to employees, counterparties, suppliers and third parties. Reports can be submitted to info@elionmt.com, anonymously where local law permits.

We prohibit retaliation against anyone who raises a concern in good faith. Reports are assessed by designated personnel independent of the activity being reported, and substantiated issues trigger corrective action.

Environmental responsibility and sustainable governance are core to the long-term viability of commodity markets. We are building our disclosure on recognised frameworks, including the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) and the sustainability standards of the International Sustainability Standards Board (ISSB / IFRS S1 and S2).

Work in progress includes the mapping of our Scope 1 and Scope 2 greenhouse-gas emissions, the methodology for estimating Scope 3 emissions embedded in the cargoes we intermediate, and the publication of an annual sustainability statement.

Our obligations under Québec's Law 25, Canada's PIPEDA and other applicable privacy regimes are set out in the Privacy Policy. Questions about data protection can be sent to info@elionmt.com.