Last updated: August 2026
SVRGN Capital Group (“SCG”) seeks to support legitimate, transparent and responsibly sourced physical commodity transactions.
Commercial opportunity does not override legal, sanctions, anti-money-laundering, anti-bribery, human-rights, environmental, customs, origin or other applicable compliance considerations.
SCG applies a risk-based and transaction-specific approach to preliminary qualification and commercial due diligence. The nature and extent of checks may vary according to the parties involved, commodity, origin, destination, jurisdictions, payment structure, logistics route and other relevant risk factors.
Counterparty and authority checks
Before progressing an opportunity, SCG may request information or documentation concerning:
- company identity and registration;
- directors and authorised representatives;
- beneficial ownership or controlling interests;
- mandate status;
- authority to buy, sell or offer the relevant commodity;
- mining, trading, export or other relevant commercial authority;
- corporate address and operating location;
- transaction history or commercial readiness where relevant;
- and other information reasonably required to understand the proposed transaction.
Submission of information does not guarantee successful qualification.
KYC, KYB and sanctions considerations
SCG may require or coordinate appropriate Know Your Customer (KYC) and Know Your Business (KYB) checks before sensitive commercial information is exchanged or a transaction progresses.
Depending on the transaction, this may include identity verification, company-document review, beneficial-ownership checks and screening against relevant sanctions or restricted-party information.
SCG may request additional information where:
- identities or ownership structures are unclear;
- corporate information cannot reasonably be verified;
- mandate or authority is uncertain;
- a transaction presents unusual payment or routing arrangements;
- sanctions or jurisdictional concerns arise;
- or other material compliance concerns are identified.
Product origin and authority to offer
Suppliers, producers, traders and intermediaries may be required to demonstrate reasonable evidence of:
- commodity origin;
- lawful authority to offer or trade the product;
- product specifications;
- available or expected quantity;
- loading location;
- applicable permits or export documentation where required;
- and the relationship between the party presenting the opportunity and the underlying product.
SCG does not treat photographs, assay reports, warehouse documents or statements of availability alone as conclusive proof of ownership, control, title or authority to sell.
Responsible-sourcing expectations
SCG seeks to avoid knowingly facilitating commodities associated with:
- unlawful extraction or trade;
- falsified product origin or documentation;
- sanctions evasion;
- bribery or corruption;
- money laundering or fraud;
- financing of unlawful organisations or activities;
- forced labour or child labour;
- serious human-rights abuses;
- unlawful environmental practices;
- theft or misappropriation;
- or other prohibited conduct.
International responsible-mineral guidance recognises that mineral supply chains can present risks involving human rights, conflict, corruption and financial crime, and encourages companies across the supply chain to identify, prevent and mitigate those risks.
SCG does not represent that adoption of this statement constitutes certification under the OECD Guidance or any other external responsible-sourcing standard.
Inspection, assay and verification
Where appropriate, product quality, quantity, weight, origin or other transaction requirements may be independently verified.
Independent parties may include:
- inspection companies;
- laboratories and assay providers;
- weighbridges;
- warehouses;
- logistics providers;
- customs specialists;
- financial institutions;
- legal advisers;
- and other appropriately qualified service providers.
Such parties remain responsible for their own professional services and contractual obligations.
SCG does not guarantee the accuracy of third-party reports merely because they are submitted in connection with an opportunity.
Environmental and social considerations
Where relevant to a transaction, SCG may consider reasonable indicators of environmental legality, responsible extraction, labour practices and related supply-chain risks.
Environmental considerations are increasingly recognised as part of responsible mineral-supply-chain due diligence. The OECD has published specific guidance on incorporating environmental risks into mineral supply-chain due diligence.
SCG does not represent that it conducts environmental audits of mines or production facilities unless expressly agreed and performed by suitably qualified parties.
Independent service providers
Legal, financial, banking, escrow, insurance, inspection, assay, transportation, warehousing, customs, regulatory and other specialist services may be performed by qualified independent third parties.
Their involvement does not imply that SCG owns, controls or operates their businesses or infrastructure.
Unless specifically confirmed and authorised for publication, SCG does not claim ownership of:
mines, mineral inventory, stockpiles, warehouses, laboratories, rail infrastructure, transport fleets, ports or production facilities.
Confidentiality
Commercial and due-diligence information should be disclosed only where reasonably necessary and through appropriate channels.
SCG seeks to protect confidential information in accordance with applicable agreements and internal access controls.
Website submission alone does not create an NDA, NCNDA, exclusivity or non-circumvention obligation. Where such protections are required, they should be documented separately between the relevant parties.
Right to request further information
SCG may request additional documentation or clarification at any stage where information is incomplete, inconsistent or requires further verification.
The absence of a request for a particular document should not be interpreted as confirmation that all compliance requirements have been satisfied.
Right to pause, decline or discontinue
SCG may pause, decline or discontinue consideration of an opportunity where information appears:
- materially inconsistent;
- unverifiable;
- misleading;
- commercially unrealistic;
- unlawful;
- associated with unacceptable compliance concerns;
- or outside SCG’s commercial or risk tolerance.
SCG is not obliged to disclose confidential internal assessment criteria or third-party compliance information when declining an opportunity.
No certification or regulatory claim
This statement describes SCG’s intended commercial and due-diligence approach.
It does not represent that SVRGN Capital Group is licensed, regulated, accredited, certified or approved for a particular regulated activity unless a specific current licence, registration or certification has been independently verified and expressly authorised for publication.
Updates
SCG may update this statement as its business processes, commodities, jurisdictions, counterparties, regulatory requirements or responsible-sourcing practices develop.
Important commercial disclaimer
Information published on this website is provided for general commercial information only. Product availability, specifications, pricing, quantities, delivery schedules and transaction terms are subject to verification, due diligence, regulatory compliance and execution of definitive agreements. Nothing on this website constitutes a binding offer, financial advice, investment advice or a guarantee of performance.