Statement pursuant to §.54 of the Modern Slavery Act 2015 (UK) and §.14 of the Modern Slavery Act 2018 (Cth) (Aust).
This statement is made and published by HIGH TABLE LLC (a company incorporated under the laws of the State of Florida under document number L21000107197 with principal place of business at 936 SW 1st Avenue, Suite 414, Miami, FL 33130) and our GoldChain Platform (GoldChain, we, us, our).
1. Overview
GoldChain is a blockchain-based B2B marketplace for ethical gold trading, connecting licensed gold professionals from mine to market with complete supply chain transparency.
We wholeheartedly support the Modern Slavery Act 2015 (UK) and the Modern Slavery Act 2018 (Cth) (Aust) whose provisions assist to eradicate modern slavery, wherever it may occur, and raise public awareness of the problem. As a platform dedicated to ethical gold trading, we recognize that the artisanal and small-scale gold mining sector faces significant risks of forced labor and child labor. We are committed to using our technology and marketplace to combat these abuses throughout the gold supply chain.
2. Our Approach
We are committed to achieving the highest standards of ethical behavior in the conduct of our business and activities worldwide. We support and respect the protection of internationally proclaimed human rights and endeavor to make sure that GoldChain is not complicit in human rights abuses. To this end, we will not tolerate slavery or human trafficking or abusive or unfair treatment in any part of our own business, our supply chains, or the gold trading activities conducted through our marketplace.
3. Our Operations & Supply Chain
3.1 Our Direct Operations: Our direct operational supply chains consist primarily of low-risk professional services including real estate, technology (IT hardware, software, cloud services), business services (office supplies, furniture), and professional services (consultants, legal support). These are assessed as low risk for modern slavery.
3.2 Gold Marketplace Supply Chain: As an operator of a gold trading marketplace, we recognize heightened risks in the gold supply chains we facilitate. The artisanal and small-scale gold mining sector has been identified by the ILO, OECD, and UN as high-risk for child labor, forced labor, exploitative working conditions, and human trafficking.
Our marketplace connects:
- Producers: Artisanal miners, cooperatives, aggregators, and mine owners
- Traders: Exporters, importers, and dealers
- Retailers: Refineries, manufacturers, and jewelers
4. The Clean Gold Initiative
All marketplace participants must comply with The Clean Gold Initiative, which requires:
- Zero tolerance for child labor and forced labor
- Safe working conditions and fair compensation
- Freedom of association and environmental responsibility
GoldChain empowers artisanal miners through direct market access, fair pricing, secure escrow payments, and support for formalization. Our blockchain technology creates immutable records of gold’s journey from mine to market, enabling complete traceability and transparency.
5. Policies & Procedures
We have a zero-tolerance approach to modern slavery. Our key policies include:
5.1 Code of Conduct prohibiting slavery, human trafficking, child labor, and forced labor
5.2 Participant Terms & Conditions requiring Clean Gold Initiative compliance
5.3 KYC and Due Diligence procedures including identity verification, license validation, and sanctions screening
5.4 Procurement Policy assessing social, environmental, and ethical impacts
5.5 Third-Party Risk Management requiring due diligence on vendors
5.6 Anti-Money Laundering Policy addressing proceeds of crime including modern slavery
5.7 Whistleblowing Protection Policy allowing confidential reporting of concerns
6. Due Diligence & Risk Assessment
We conduct regular risk assessments and enhanced due diligence for participants operating in conflict-affected and high-risk areas, including site visits, third-party verification, and review of certifications. Our approach aligns with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals.
When potential modern slavery is identified, we investigate immediately, suspend accounts pending investigation, cooperate with authorities, and require remediation. Confirmed violations result in immediate termination and reporting to appropriate authorities.
7. Training & Monitoring
All employees receive training on modern slavery risks in the gold sector, identification of red flags, and reporting procedures. We provide educational resources to marketplace participants on Clean Gold Initiative requirements and best practices for ethical mining.
We continuously monitor marketplace activity and maintain grievance mechanisms for participants, workers, and community members to report concerns.
8. Recruitment & Welfare of Our People
We only use reputable recruitment firms and comply with all relevant laws and regulations. All employees are paid fair wages and have access to a 24/7 employee assistance program supporting mental, physical, social, and financial wellbeing.
9. Measuring Effectiveness
We assess effectiveness through KPIs including verified Clean Gold compliant participants, transactions with complete chain of custody documentation, incidents reported and investigated, and training completion rates. We conduct annual reviews and continuously improve our procedures.
10. Communication
Copies of this Modern Slavery Statement are published on our website at www.goldchainblock.io. We commit to publishing this statement annually with updates on our progress.
For questions or to report suspected modern slavery, contact: compliance@goldchainblock.io
11. Consultation & Approval
This statement was prepared in consultation with GoldChain leadership, legal and compliance advisors, and stakeholder representatives. It has been reviewed and approved by the Board of Directors of HIGH TABLE LLC.
Updated: November 27, 2025