Know Your Customer

Effective KYC GUIDELINES - MARCH 1, 2010

Recent amendments to the by-laws of the Law Society of Upper Canada, (http://www.lsuc.on.ca/latest-news/a/hottopics/new-client-identification-...) known as the "Know Your Client" provisions, set out certain procedures that all Goldmembers must follow whenever we act for our clients on any new matter whether buying or selling precious metals. The purpose of the Know Your Client provisions is to guard against our unwittingly participating in money laundering or terrorist financing activities. The Know Your Client provisions have two aspects, client identification and client verification.

Client Identification

We will be required to complete client identification procedures each time we act for a new clients. For our existing clients, we will have most or all of the required information on file, but there may be occasions on which we ask you to provide certain information.

For clients who are corporations or other types of organizations, we must record the client's name, business address and telephone number, incorporation or identification number, and the name, title and contact information of the person who will be instructing us on behalf of the client. For clients who are individuals, we must record the client's name, home and business address and telephone number, and occupation.

Client Verification

Client verification procedures are only required in certain circumstances. Client verification is required when we engage in or give instructions in respect of the receiving, paying or transferring of funds. There are, however, several exemptions to the verification requirement. The main exemptions are payments from our clients to us for professional fees or disbursements, funds received from a lawyer or estate's trust account, funds paid or received in settlement of a legal proceeding, and funds paid or received by electronic funds (wire) transfer as this assumes the transmitting bank has all your information. Finally, client verification is not required if our client is a reporting issuer, public body or financial institution.

In certain circumstances, though, it will be necessary for us to verify the identity of our client. If so, the verification procedures for organizational clients will, generally speaking, consist of us reviewing and keeping a copy of a certificate of status, annual filing or other similar document of our client, recording the name, address and occupation of any person who owns 25% or more of the shares of our client, and recording the names and occupations of all of the directors of our client. In addition, it will be necessary for us to verify the identity of the specific individual who is providing instructions to us on behalf of the corporation or organization, by viewing and keeping a copy of that person's driver's license, passport or birth certificate. Similarly, for individual clients, we must verify identity by viewing and keeping a copy of the client's driver's license, passport or birth certificate.

Know Your Client regulations have also come into force across Canada. While we will comply fully with the new regulations, we will seek to do so in a manner which is as efficient and discrete as possible for our clients. No information is shared with any third party for a Goldmembers transaction.