Compliance — AYCAS Commodities

Corporate framework

Zimbabwean incorporated.

Company registration: Registered private limited company under the Zimbabwe Companies and Other Business Entities Act [Chapter 24:31]. Entity number 56514A0282025. Incorporated 27 August 2025. Registered office at Rosedale 208–209 Sam Nujoma Street, Harare.
Tax compliance: Registered with ZIMRA (Zimbabwe Revenue Authority). VAT registration and tax clearance certificate available on request.
Exchange control: All forex flows managed under Reserve Bank of Zimbabwe (RBZ) procedures — CD1 forms on export proceeds; import forex authorisations and bank-remittance compliance on imports.
Labour compliance: Operating under Zimbabwean labour law, NSSA-registered, statutory contributions current.

Mineral exports

MMCZ-licensed, per shipment.

MMCZ licensing: All mineral shipments cleared through the Minerals Marketing Corporation of Zimbabwe. Export permits obtained per shipment; assay and tonnage declared to MMCZ before loading; sales contracts registered.
Customs & certificates of origin: Export declarations lodged with ZIMRA customs. Certificates of origin issued by ZIMRA or recognised chambers (ZNCC, CZI) per destination market.
Sanctions-compliant routing: End-buyer KYC and sanctions screening cleared before loading. Routing chosen to avoid sanctioned ports and flags.

Agricultural imports

ZIMRA-cleared, phytosanitary-certified.

ZIMRA customs: All import shipments declared at port of entry (Beitbridge, Chirundu, Plumtree or Kazungula), duty and VAT paid in line with applicable Zimbabwean tariff schedules.
Phytosanitary: Phytosanitary certificates issued at origin — DAFF (South Africa), ZARI (Zambia), or the Department of Agricultural Research Services (Malawi) — and verified at the Zimbabwean border by the Department of Plant Quarantine Services.
Import permits & forex: Import permits obtained from the Ministry of Industry and Commerce where required. Forex authorisations arranged through RBZ-authorised dealers in line with prevailing exchange-control directives.
GMB / AMA alignment: Grain imports coordinated with the Grain Marketing Board and Agricultural Marketing Authority per product and period.

Internal governance

Separated duties. No self-approval.

AYCAS runs a separated-duties operating model. The person who originates the order is never the person who approves it; the person who selects a supplier is never the sole signatory on payment.

Order origination & approval: Business Development originates. Credit Control validates credit terms. Executive sign-off required before any order is confirmed. No self-validation by originating parties.
Cash orders: 50% pre-payment into escrow at order confirmation. No loading without cleared funds.
Supplier & logistics vetting: Suppliers and transporters vetted and approved by two executives against pricing, credibility and operational criteria. Once payment is made, executives step back and operations teams run the trade.
SA & Zim operations: Loading, weighing and border clearance handled by a dedicated South African operations team on imports. Handover to the Zimbabwean operations team at the border; in-country logistics and final delivery run from Harare.
Finance & Credit Control: Invoicing runs from signed weighbridge slips and delivery notes. Credit Control monitors debtor ageing and manages collections.
Reporting: Daily operational reports to executives. No interference with running trades unless requested.

Counterparty screening

KYC, sanctions, ongoing monitoring.

AYCAS performs counterparty clearance on both sides of every trade before contracting. Monitoring continues across the life of the relationship.

KYC file: Incorporation documents · UBO declaration · signatory authorisation · bank references.
Sanctions screening: OFAC (US) · HM Treasury (UK) · EU consolidated list · UN Security Council. Cleared before loading.
PEP & adverse-media: Screened via commercial provider. Escalation to board-level review on any amber flag.
Ongoing monitoring: Periodic re-screening across the life of the trading relationship. Contract terminable on sanction designation or material adverse finding.

Contractual & insurance

Familiar paper, covered cargo.

Grains & oilseeds: GAFTA (Grain and Feed Trade Association) contracts for grains; FOSFA contracts for oils and oilseed-derived products.
Sugar: ICUMSA-referenced terms for brown-sugar trade.
Minerals: Standard MMCZ-framed terms. Independent inspection (SGS, Bureau Veritas, Intertek). CIF, FOB, CFR — Incoterms 2020.
Dispute resolution: GAFTA, FOSFA or LME arbitration as applicable; substantive law as agreed in contract.
Insurance: Marine cargo insurance placed per shipment (Institute Cargo Clauses A where available). Credit insurance for open-account trades where warranted. War, strikes, riots and civil commotion cover where routing warrants. Inland transit cover on regional road and rail movements.

Regulated, licensed, documented.