Custody & Storage Policy

Fine Gold Reserve

Last Updated: 1st January, 2026

1. Purpose

This Custody & Storage Policy explains how physical gold backing digital gold balances is safeguarded, managed, and protected by Fine Gold Reserve (“Company”, “we”, “our”, or “us”).

The purpose of this policy is to provide transparency regarding:

• Physical gold custody
• Storage arrangements
• Security procedures
• Ownership structure
• Client asset protection

2. Custody Model

Fine Gold Reserve operates a physical gold-backed custody framework.

Digital gold balances correspond to physical gold holdings stored in secure vault facilities.

The Company acts as:

• Custodial coordinator
• Asset record administrator
• Platform operator

Physical gold custody may be performed by approved third-party professional vault providers.

3. Types of Gold Storage

3.1 Allocated Storage

Allocated storage means:

• Specific quantities of gold are assigned to clients
• Gold holdings are recorded in internal allocation records
• Client ownership corresponds to measurable gold units

Allocated gold is not treated as a corporate operating asset of Fine Gold Reserve.

3.2 Segregated Holdings

Where operationally applicable:

• Client gold holdings may be segregated from company assets
• Custodial records distinguish client ownership from operational reserves

This structure enhances investor protection.

4. Approved Vault Facilities

Gold may be stored in secure vault facilities located in selected jurisdictions.

Vault providers are selected based on:

• International security standards
• Operational reliability
• Insurance arrangements
• Regulatory compliance
• Professional custody experience

Storage locations may change to optimize security and operational efficiency.

5. Security Standards

Physical gold stored under custody arrangements benefits from multiple layers of protection, including:

• High-security vault infrastructure
• 24/7 monitoring and surveillance
• Access control systems
• Armed or professional security services
• Transportation security procedures
• Controlled audit access

Security measures are periodically reviewed and enhanced.

6. Insurance Coverage

Where applicable, gold stored in custody facilities may be protected by insurance arrangements maintained by vault operators or logistics partners.

Insurance terms depend on custodial agreements and may include coverage against:

• Theft
• Damage
• Loss during transportation
• Security breaches

Insurance details may vary between jurisdictions and custodians.

7. Gold Procurement Standards

Fine Gold Reserve sources gold consistent with recognized industry standards.

Gold may meet accepted criteria such as:

• Recognized refinery sourcing
• Standardized purity levels
• Traceable supply chains
• Responsible sourcing practices

The Company aims to maintain transparent sourcing aligned with global precious metals practices.

8. Record Keeping & Reconciliation

Fine Gold Reserve maintains internal records documenting:

• Total gold holdings
• Client allocation balances
• Transaction history
• Custodial confirmations

Periodic reconciliation procedures are performed to ensure alignment between digital balances and physical reserves.

9. Audits and Verification

The Company may conduct or arrange:

• Internal asset reviews
• Custodial confirmations
• Operational audits
• Inventory verification procedures

Audit frequency may vary based on operational and regulatory requirements.

10. Transportation of Gold

When gold is moved between facilities or delivered to clients, secure logistics procedures are applied, which may include:

• Authorized transport partners
• Secure handling protocols
• Risk-managed transportation routes
• Compliance documentation

Transportation risks cannot be entirely eliminated.

11. Client Ownership Rights

Clients holding digital gold maintain beneficial ownership of allocated gold quantities recorded under their account.

Fine Gold Reserve:

• Does not treat client gold as company revenue assets
• Does not pledge client gold without authorization
• Maintains ownership records tied to client balances

Ownership rights remain subject to platform terms and applicable law.

12. Physical Delivery Requests

Where physical delivery is offered, clients may request withdrawal of gold subject to:

• Minimum withdrawal quantities
• Identity verification requirements
• Delivery and fabrication fees
• Compliance approval processes

Delivery availability may vary by jurisdiction.

13. Risk Disclosure

While extensive safeguards are implemented, custody risks may include:

• Operational failures
• Security incidents
• Transportation risks
• Force majeure events
• Regulatory or geopolitical disruptions

No custody system can eliminate all risk.

14. Business Continuity & Asset Protection

Fine Gold Reserve maintains operational safeguards designed to support asset continuity, including:

• Secure record backups
• Custodial coordination procedures
• Operational contingency planning
• Restricted access to asset records

These measures aim to protect client ownership records during operational disruptions.

15. Regulatory Compliance

Custody arrangements are structured to operate in accordance with applicable laws governing:

• Precious metals custody
• Financial compliance
• Asset safeguarding
• Anti-money laundering obligations

Storage jurisdictions may change as regulatory conditions evolve.

16. Policy Updates

Fine Gold Reserve may update this Custody & Storage Policy periodically to reflect operational improvements, regulatory developments, or enhanced security practices.

Updated versions will be published on this page.

17. Contact Information

For custody or storage inquiries:

Custody & Compliance Department
Fine Gold Reserve

Email: custody@finegoldreserve.com
Website: www.finegoldreserve.com