Responsible Sourcing & Traceability Policy
Alley Pond Trading Corporation · Version 1.1 · September 2026 · Reviewed annually
1. Purpose
This policy sets out how Alley Pond sources raw Gum Acacia (Gum Arabic), Baobab and Hibiscus ingredients, what we record for every lot, and what we will and will not do to move material from a producing area to a customer’s dock.
It is written to be used. A customer’s quality, procurement or compliance team should be able to read it and know exactly what evidence exists, what we can produce on request, and where to raise a concern.
2. Scope
This policy applies to Alley Pond Trading Corporation and to every supplier, collector, agent, transporter, processor and service provider in our supply chain. Its requirements pass upstream through the Alley Pond Supplier Code of Conduct, which suppliers sign and are expected to cascade to their own suppliers and subcontractors.
3. Standards we work to
- UN Guiding Principles on Business and Human Rights
- ILO core conventions on child labour, forced labour, discrimination and freedom of association
- OECD Due Diligence Guidance for Responsible Business Conduct, including its guidance on conflict-affected and high-risk areas
- Applicable US law, the laws of every country in which our suppliers operate, and applicable trade and sanctions regimes
- The customer codes of conduct and ethical charters we have signed
Where standards differ, the higher applies.
The journeyPage 2 of 7
4. The journey, and what each stage produces
Gum acacia is wild-harvested by smallholder families and sold at collection markets in the producing regions. From there it is transported to a cleaning and packing facility, and then to Port Sudan for export.
Every stage of that journey generates its own documentation, at the time it happens and by a party other than the seller.
| Stage | What happens | What it produces |
|---|
| Purchase at market | Material is bought in small batches at a named collection market and weighed on an electronic scale | Weight certificate stating exact quantity and the location where the batch was received · purchase contract · identity of the counterparty · payment record |
| Movement to cleaning | The batch is transported to the cleaning and packing facility | Transport permit for that leg, covering Zakat, forestry tax and business profit tax · transport manifest · VAT receipt · official receipts for duties paid · checkpoint verification en route |
| Cleaning and packing | Material is cleaned, sorted, graded and packed | Facility location and dates · batch processing records reconciling input to output |
| Movement to port | The consignment is transported to Port Sudan | A separate transport permit for that leg, with its own tax clearances · manifest · receipts · checkpoint verification en route |
| Arrival at port | Duties and permits are verified before the consignment enters clearance | Export permit · verification of all preceding permits and clearances |
| Export | The consignment clears customs and ships | Bill of lading set · commercial invoice · packing list · certificate of origin · certificate of analysis |
Why the sequence matters. Export documentation records a departure. A permit chain records a route. Material of unrecorded origin can obtain paperwork at stage six; it cannot retrospectively produce a weight certificate from a named market at stage one, a permit for each leg between, and checkpoint verification along the way. The controls that matter sit upstream of export, and that is where ours are.
Two trailsPage 3 of 7
5. Two trails that must reconcile
The record above is not a folder of certificates. It is two independent trails that must tie out against each other at every stage.
The weight trail. Every batch is weighed on an electronic scale at the point of purchase, and the certificate records both the quantity and the place it was received. Processing records reconcile input weight to output weight through cleaning, sorting and grading. Manifests and packing lists carry those weights forward to the container.
The payment trail. Every batch has a contract, a counterparty and a payment. Payment is made by bank transfer as standard practice — to a named account, held by the identified seller. Cash is used only exceptionally and is recorded when it is. Duties, taxes and transport are likewise paid and receipted, each against the leg it belongs to.
Our suppliers maintain formal bookkeeping and accounting systems, and can produce the supporting evidence for each individual quantity purchased, processed or transported while in their custody. This is required by ordinary standards of business management as much as by this policy — but in this trade it does more than satisfy an accountant. A named bank payment reconciling against a weight certificate issued at a named market is evidence that cannot be constructed after the event. Material of unaccounted origin does not arrive with a bank trail.
Segregation — a technical control before it is a compliance one
Material is kept separate at two levels, physically, from purchase through to loading.
By species. Acacia senegal (Hashab) and Acacia seyal (Talha) are stored in entirely separate warehouses — not merely separate stacks or bays. The two species differ in their analytical profile, they command different prices, and they are specified separately by every buyer. Keeping them under different roofs removes the possibility of cross-contamination and, equally, removes any question of one species being present in a consignment of the other.
By producing area, within each species. Gum grown on mud soils differs in its chemical characteristics from gum grown on sand soils, and buyers specify accordingly. Batches from different markets or areas are therefore held separately — in different rooms where necessary — and are never mixed, as a standing quality-control rule. Where a single shipment carries material from more than one area, the containers are identified by area.
Batches are not combined, because the product does not permit it.
The consequence is that segregation is not a control imposed on the process from outside. It is inherent to how the material must be handled to be commercially usable at all, and it is enforced by warehouse architecture rather than by procedure alone. Every container can be traced back to the specific batches that went into it, and those batches to their markets of purchase.
A commitment can lapse and a procedure can be skipped. A wall cannot. That is why our traceability holds under pressure.
6. What we hold for every lot
Consolidating the above, for each lot we supply we record and can produce:
- The harvesting area
- The collection market, the date of purchase, and the weight certificate issued there
- The identity of the counterparty, the purchase contract, and the payment record
- The location and dates of cleaning, sorting, grading and packing, with processing records
- The transport permits for each leg, with manifests and VAT receipts
- Official receipts for Zakat, forestry tax, business profit tax and any other lawful duty
- The export permit and customs clearance
- Export documentation — bill of lading set, invoice, packing list, certificate of origin, certificate of analysis
- The specific batches comprising the lot, each traceable to its market of purchase, and the producing area of every container in a shipment
Records are retained for not less than five years and are available to customers on request.
Material of unknown, undocumented or misrepresented origin is never purchased, and is never commingled with material intended for our customers.
7. Route and origin integrity
We recognise that ordinary supplier verification is not by itself sufficient in the current environment, and that origin documentation obtained at the point of export can be vulnerable to misuse. Our controls therefore sit upstream of export rather than at it.
- We source only material moving through official domestic channels to Port Sudan, with the permit chain in section 4 intact for every leg.
- We do not purchase Sudanese-origin gum offered for export through third countries, regardless of price, availability or the documentation offered with it.
- We do not purchase material offered without a verifiable route history, including material offered at distressed prices or under altered grade classifications.
- We treat any sudden shift in a counterparty’s sourcing, route or export point as a risk indicator requiring investigation before further purchase.
- We reassess route conditions continuously and will suspend a route rather than accept a gap in the record.
We would rather decline a consignment than supply one we cannot account for.
8. Counterparty due diligence
Before we buy from any supplier, and periodically thereafter, we establish and document:
- Legal and beneficial ownership, including the individuals who ultimately own or control the business
- That the business is privately owned, with no state, para-state or politically affiliated ownership interest
- Screening against applicable sanctions regimes, including the US Treasury OFAC Specially Designated Nationals list and applicable EU and UK regimes, covering the entity, its owners and its principals
- Screening for politically exposed persons
- The nature and duration of our relationship with the business and its principals
Our suppliers are long-standing counterparties whose principals are known to us personally. Screening is repeated periodically and on any change of ownership, and a relationship is ended where screening cannot be satisfactorily completed.
9. Payment integrity
The only payments we or our suppliers make to move material are those that are required by law, charged at the official rate, and supported by an official receipt. For the movement of gum to port these are Zakat, forestry tax and business profit tax, levied per leg, together with lawful transport charges and customs duties — each verified at checkpoints en route and again at port before clearance.
We do not pay, and require that no supplier acting for us pays, any bribe, kickback, facilitation payment, protection payment or unofficial charge, to any person, for any purpose, including for the passage, release, escort, loading or clearance of goods.
Any such demand must be refused and reported to us. No supplier will be penalised by Alley Pond for a delay caused by refusing an improper demand. We would rather lose the consignment.
10. Human rights and labour
We require, and our Supplier Code of Conduct obliges, throughout our chain:
- No child labour, and no person under 18 in hazardous work, night work, or work that interferes with schooling. Light, supervised work by children alongside their families outside school hours is recognised as part of smallholder harvesting and is not prohibited; hazardous work, work that displaces education, and work performed for a third party are prohibited without exception.
- No forced, bonded or trafficked labour. No retention of identity or travel documents.
- Lawful wages, hours and rest. Freedom of association where law permits.
- Safe working conditions, with access to clean sanitation and potable water.
- Freedom from harassment, violence and discrimination.
11. Environment and the resource
We require lawful environmental practice, responsible waste handling, and — specific to our trade — tapping practices that do not compromise tree health, no felling or damage of productive acacia stands, and support for the natural regeneration of the belt. The resource is the business; a supply chain that exhausts it has ended itself.
12. What we issue to customers
With every shipment: bill of lading set, commercial invoice, packing list, certificate of origin, and certificate of analysis.
On request: a lot-level traceability statement identifying harvesting area, purchase and movement dates, cleaning and packing location, route to port, and confirmation that no payment was made outside the bounds of section 9 and that no illegal activity occurred along the chain described. Supporting records behind that statement — weight certificates, permits, receipts — are available on request.
We complete customer sustainability questionnaires and self-assessments, sign customer codes of conduct and ethical charters, and accommodate customer audits.
13. Raising a concern
Anyone — a worker, a collector, a supplier, a customer, a community member or any other affected party — may report a concern about conduct in our supply chain to:
speakup@alleypondglobal.com
How we handle it. We acknowledge every report within ten business days. We assess it, investigate where warranted, and may engage an independent third party to assist. We aim to propose a resolution within sixty business days, and where a matter is complex we will say so and keep the reporter updated. Corrective actions are documented and the matter formally closed with the reporter where contact details were given.
Confidentiality. Reports are handled discreetly and the reporter’s identity protected where requested. Reports may be made anonymously, though we can investigate more effectively when we can ask questions.
Non-retaliation. No person will be penalised by Alley Pond, and no supplier may penalise any person, for raising a concern in good faith or for refusing an improper payment. Retaliation is itself a breach of our Supplier Code.
We record and review all reports to identify patterns rather than treating each in isolation.
14. Monitoring, corrective action and consequences
We assess supplier compliance through the signed Supplier Code, self-assessment, documentary verification and visits. We may request documentation or appoint a third party to audit.
Where a shortfall is found, our first response is a corrective action plan with an agreed timeframe; we would rather raise a supplier’s standard than replace them. Where a supplier declines to engage, conceals information, retaliates against a person raising a concern, or where a breach is severe and cannot be remediated, we end the relationship.
15. Accountability and review
Responsibility for this policy sits with Taric Khalil, Founder & President, who owns it personally. It is reviewed at least annually and whenever conditions in our supply chain change materially.
