Every mineral Corvex Logistics trades is DGSM-licensed, ITSCI chain-of-custody certified, and OECD due diligence compliant. Our documentation packages satisfy Dodd-Frank Section 1502, ICGLR Regional Certification, and KYC/AML requirements at the first request.
Since 2021, Corvex Logistics has built its business on the principle that transparent, traceable, and certified mineral supply chains are the only commercially sustainable model for trading from the Great Lakes region.
International buyers "” electronics manufacturers, refineries, financial institutions "” face increasing regulatory pressure to prove that the minerals in their supply chains did not finance armed conflict or violate human rights. Corvex Logistics exists to make that proof straightforward. We structure every transaction so that the documentation a buyer needs for OECD, Dodd-Frank, or RMAP audit purposes is complete before the consignment leaves Uganda.
Our compliance programme is not managed by a single department "” it is embedded in every step of our operations, from the moment we assess a mining site to the moment a consignment is delivered at port.
Every Corvex Logistics consignment is structured to satisfy all six of these frameworks simultaneously "” so buyers never have to choose between compliance standards.
Aligned to the OECD five-step framework "” from management systems to client reporting. This is applied to every mining site we source from and every buyer we supply to.
We maintain a written supply chain due diligence policy, a dedicated compliance register, and a named compliance officer. Our policy is communicated to all suppliers (mine operators and ASM cooperatives) and all buyers as a condition of engagement. Suppliers who cannot meet our minimum traceability standards are not onboarded.
Before sourcing from any mining site, we conduct a site-level risk assessment covering: DGSM registration status, mine-site location relative to conflict zones and protected areas, known presence of non-state armed groups, environmental and child labour indicators, and ITSCI tag availability. Sites that fail assessment are immediately suspended from our supply base.
For any risk identified, we design a specific mitigation measure "” whether that is requiring additional documentation, conducting an unannounced site audit, restricting purchases to direct cooperative sales only, or suspending the site pending investigation. Risk responses are documented and reviewed quarterly.
Our supply chain is subject to periodic independent third-party audit covering both our internal management systems and a sample of mining sites in our supply base. Audit findings are disclosed to clients on request. We welcome buyer-initiated audits of our documentation and will provide access to our compliance records under a standard non-disclosure agreement.
We provide a due diligence documentation package with every consignment, and an annual supply chain due diligence report to clients who request it. Documentation includes: DGSM export certificate, ITSCI chain-of-custody certificate, mine-site risk assessment summary, third-party assay certificate, Certificate of Origin, and the CMRT (Conflict Minerals Reporting Template) if required for Dodd-Frank reporting.
Corvex Logistics applies FATF-aligned KYC and AML controls to both the buyers we supply and the mining operators we source from. This protects the integrity of every transaction in our supply chain.
All new buyers complete a full KYC verification before their first transaction. Required documents: certificate of incorporation, beneficial ownership register (UBO), proof of identity for all authorised signatories, end-use declaration for the minerals being purchased, and copies of any relevant import licences or permits in the destination country.
Buyers are screened against the OFAC SDN list, UN Security Council Consolidated Sanctions List, EU Consolidated Sanctions List, and UK HM Treasury sanctions list at onboarding and on an ongoing periodic basis. Any match triggers an immediate transaction freeze and compliance review.
Required before first transactionMining operators and ASM cooperatives who supply minerals to Corvex Logistics are subject to a parallel KYC and due diligence process. We verify: DGSM mine operating licence, registration of the cooperative or company, beneficial ownership, absence from conflict-mineral sanction lists, and physical site assessment to confirm that the mine is operating at the declared GPS coordinates.
Suppliers are re-assessed annually or whenever a material change occurs in their operating environment "” including changes in land tenure, management, or proximity to conflict.
Annual supplier re-assessmentAll transactions are monitored for indicators of money laundering, including: payment from unrelated third parties, unusual payment structures, requests for cash settlement above threshold, and discrepancies between declared mineral values and market prices. Suspicious transaction reports are filed with Uganda's Financial Intelligence Authority (FIA) as required under the Anti-Money Laundering Act 2013.
We do not accept cash payments for mineral purchases above USD 1,000. All transactions above USD 10,000 are conducted by verified bank transfer with full beneficiary disclosure.
FATF-aligned monitoringAll KYC documents, due diligence reports, and transaction records are held securely and are accessible only to authorised Corvex Logistics compliance staff. Client data is not shared with third parties except where required by Ugandan law, DGSM reporting obligations, or with the client's explicit written consent.
Compliance records are retained for a minimum of seven years in accordance with Uganda's Anti-Money Laundering Act and OECD guidance retention requirements. Clients may request access to their own compliance file at any time.
7-year document retentionUS-listed companies and their supply chain partners are required under SEC Rule 13p-1 (Dodd-Frank Section 1502) to determine whether any tin, tantalum, tungsten, or gold (3TG) in their products originated from the Democratic Republic of Congo or adjoining countries "” including Uganda "” and whether those minerals directly or indirectly financed armed conflict.
Corvex Logistics has structured its supply chain documentation so that buyers can answer this question unambiguously and affirmatively: our minerals are sourced from DGSM-licensed Ugandan mine sites, tagged with ITSCI chain-of-custody certificates, and have not passed through any zone under the control of a non-state armed group.
We provide the following Dodd-Frank documentation package on request:
Compliance with regulatory frameworks is the minimum standard. Our approach goes further by building fair, transparent relationships with the artisanal and small-scale mining communities we source from.
Corvex Logistics buys directly from DGSM-registered ASM cooperatives at prices referenced to the London Metal Exchange (LME) or LBMA spot fix. This eliminates the local middleman margin "” which historically cost miners 20"“30% below market price "” and puts more income directly into mining communities.
All mining sites in our supply base are assessed for child and forced labour indicators as part of our OECD due diligence site assessment. Sites that cannot confirm compliance with ILO conventions on child labour and forced labour are excluded from our supply base without exception. This is a condition, not an aspiration.
We conduct visual environmental assessments at all supplier mine sites, looking for indicators of uncontrolled water discharge, deforestation, and proximity to protected areas or water catchments. Sites operating in protected areas or without the required NEMA (National Environment Management Authority) environmental impact permits are excluded.
Every miner or cooperative we purchase from receives a copy of the weigh-bill, assay result, and price calculation for their consignment. We do not use undisclosed deductions for processing or transport. The price a miner is told is the price that is paid, in full, within seven days of delivery and assay confirmation.
Our compliance team responds within one business day. We provide CMRT, ITSCI certificates, DGSM permits, assay reports, and OECD audit-ready documentation for every consignment.