KMG’s commercial purpose depends on supply chains that counterparties can trust. We seek to identify origin, understand material risks, maintain appropriate custody and certification evidence, and respond responsibly when a concern is identified.
Responsible sourcing is part of trade execution.
Kitivo Mercantile Group sources, purchases and moves physical commodities across agricultural and mineral supply chains. KMG is committed to conducting this activity lawfully, ethically and with respect for people, communities and the environment.
Our approach is risk-based and proportionate to the commodity, origin, supplier, route, delivery term and intended market. It is designed to support informed commercial decisions, not simply to collect documents.
Who and what this statement covers.
This statement applies to KMG’s directors, personnel and authorised representatives when selecting, approving or managing producers, aggregators, suppliers, transporters, warehouses, processors, inspectors and other operating partners.
KMG expects business partners involved in its supply chains to:
- Comply with applicable law, permits, licences, taxes, duties and export requirements.
- Provide accurate information concerning identity, ownership, origin, quantity, specification and custody.
- Respect internationally recognised human and labour rights.
- Maintain records appropriate to the commodity and transaction.
- Cooperate with reasonable due-diligence, inspection, traceability and remediation requests.
- Escalate material incidents, ownership changes, regulatory issues or sourcing concerns promptly.
KMG may incorporate relevant requirements into mandates, supplier communications, contracts, operating instructions or transaction controls.
A risk-based process from origin onward.
Depending on risk and commercial relevance, KMG’s sourcing review may include:
- Identifying the counterparty, beneficial owners, authorised representatives and commercial purpose.
- Understanding the commodity, origin, production or aggregation point, route and intended destination.
- Reviewing licences, permits, certification status, quality records, chain-of-custody information and other supporting evidence where applicable.
- Assessing geographic, human-rights, labour, environmental, integrity, sanctions, security and financial-crime risks.
- Applying proportionate controls, which may include site visits, loading oversight, independent inspection, enhanced documentation or approval conditions.
- Monitoring relevant changes and documenting the decision to proceed, mitigate, suspend or disengage.
Third-party certificates, audits or industry programmes can support due diligence, but they do not automatically replace KMG’s responsibility to consider the risks relevant to its own transaction.
Human rights and labour standards.
KMG expects its supply-chain partners to respect internationally recognised human rights and the fundamental principles and rights at work. This includes:
- No forced, bonded, trafficked or compulsory labour.
- No child labour and no hazardous work by anyone below the lawful age.
- No discrimination, harassment, violence or degrading treatment.
- Respect for lawful freedom of association and collective bargaining.
- Safe and healthy working conditions appropriate to the activity.
- Lawful wages, working time and employment practices.
- Respect for legitimate land, access, cultural and community rights.
Where risk is elevated, KMG may seek additional evidence, commission specialist support or require a time-bound corrective action before continuing.
Responsible agricultural supply.
For agricultural commodities, KMG considers risks that may arise at producer, cooperative, aggregation, processing and export stages. These can include labour conditions, child labour, land and community impacts, illegal deforestation, chemical use, food safety, product integrity, certification status and deliberate substitution or misrepresentation.
KMG seeks sourcing pathways that provide sufficient origin and quality information for the mandate. Where the buyer requires organic or another recognised certification, KMG structures the trade to preserve the applicable chain-of-custody requirements and documentary evidence through the agreed delivery point.
Seasonality, product condition and post-harvest handling are treated as commercial and responsible-sourcing considerations. Where appropriate, KMG may use inspection, condition monitoring and custody controls to protect product integrity in transit.
Responsible mineral supply.
KMG’s mined-resources activity is centred on non-ferrous metals. Mineral sourcing can present elevated risks relating to origin, licensing, beneficial ownership, conflict, security arrangements, bribery, fraud, money laundering, tax and royalty payments, human rights, child labour and environmental harm.
For minerals originating in or transiting conflict-affected and high-risk areas, KMG’s approach is informed by the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
KMG will not knowingly tolerate, profit from, assist or facilitate:
- Torture, cruel or degrading treatment, forced labour, the worst forms of child labour, sexual violence, war crimes, crimes against humanity or other serious human-rights abuse.
- Direct or indirect support to non-state armed groups.
- Illegal control, taxation or extortion by public or private security forces at mines, transport routes or trading points.
- Bribery, fraudulent misrepresentation of mineral origin or the concealment of taxes, fees and royalties.
- Money laundering, sanctions evasion or deliberately opaque ownership, payment or routing structures.
ASM participation is not treated as inherently unacceptable. Where relevant, KMG favours lawful formalisation, traceability, safer working practices and measurable risk improvement over indiscriminate exclusion, provided serious risks can be responsibly controlled.
Traceability, custody and certification.
The evidence required for a trade depends on the commodity and mandate. It may include supplier declarations, origin records, licences, permits, inspection or assay reports, weight and quality documentation, loading records, transport documents, seals, photographs, sensor records and handover evidence.
KMG does not present a product, producer or supply chain as certified unless the relevant certification is valid and the contractual pathway supports the claim. Where certification is required, KMG seeks to maintain the applicable chain of custody between recognised certified parties and preserve the evidence required by the buyer.
Traceability information is handled proportionately and may remain commercially confidential. KMG will make relevant evidence available to authorised counterparties, advisers, auditors or authorities where contractually or legally appropriate.
Environment and community value.
KMG expects producers and operating partners to comply with applicable environmental and social requirements. Depending on the activity, relevant issues may include land disturbance, water use, waste, pollution, biodiversity, deforestation, rehabilitation, community health and safety, and lawful consultation or access rights.
KMG supports local value creation through responsible commercial participation, including local procurement, logistics, capability development, formalisation and beneficiation where these activities are technically, legally and commercially sound.
Mitigation, escalation and disengagement.
When a concern is identified, KMG considers the severity, likelihood, connection to the transaction, ability to influence the responsible party and prospects for measurable improvement.
Depending on the risk, KMG may:
- Seek clarification or additional evidence.
- Require corrective action within an agreed period.
- Increase monitoring, inspection or approval controls.
- Temporarily suspend sourcing or movement.
- Decline or discontinue the relationship where risk is severe, unlawful, concealed or not capable of responsible mitigation.
- Report matters to an appropriate authority where legally required.
Concerns regarding KMG’s sourcing activity may be submitted through the institutional enquiry form by selecting “Privacy or governance request”. Reports should be made in good faith and may be handled confidentially to the extent reasonably possible.
Reference frameworks include the OECD-FAO guidance for responsible agricultural supply chains, the OECD guidance for responsible mineral supply chains, the UN Guiding Principles on Business and Human Rights and the ILO Fundamental Principles and Rights at Work.