1. Website Use & General Terms

1.1 Website Operator

This Website is owned and operated by Compass Bullion Pty Ltd (ABN 22 676 151 447) (“Compass Bullion”, “we”, “our” or “us”).

The Website provides information regarding precious metals, numismatic products, collectables and related products together with facilities enabling customers to purchase those products online.

1.2 Acceptance of these Terms

By:

• accessing this Website;
• creating an account;
• requesting a quotation;
• placing an order; or
• purchasing products,

You acknowledge that you have read and agree to be legally bound by these Terms together with our:

• Privacy Policy;
• Shipping, Delivery & Insurance Policy;
• Returns & Refund Policy; and
• any additional policies published on this Website.

1.3 Changes to these Terms

Compass Bullion may amend these Terms at any time.

Updated Terms become effective immediately upon publication on the Website.

Any order accepted prior to publication of revised Terms will remain governed by the Terms applicable at the time that order was accepted.

1.4 Website Availability

While every effort is made to maintain continuous availability of the Website, Compass Bullion does not warrant uninterrupted access.

We may suspend, restrict or discontinue any part of the Website without notice for:

• maintenance;
• upgrades;
• security;
• technical failures; or
• operational requirements.

Compass Bullion accepts no liability for temporary interruptions beyond our reasonable control.

1.5 Website Accuracy

Although reasonable care is taken, Compass Bullion does not warrant that:

• product descriptions;
• pricing;
• availability;
• images;
• specifications;
• release dates;
• mintages; or
• other Website content

will always be completely accurate or current.

Images are provided for illustration purposes only.

Actual products, packaging, certificates, presentation boxes and serial numbers may differ from those displayed.

Compass Bullion reserves the right to correct any errors or omissions without prior notice.

2. Eligibility to Purchase

By placing an order you warrant that:

• you are at least 18 years of age;
• you have legal capacity to enter into a binding contract;
• you are purchasing on your own behalf or have authority to act for another person or entity;
• all information supplied is accurate and complete.

Compass Bullion reserves the right to refuse any order where these requirements are not satisfied.

Compass Bullion may refuse to supply goods where required by law or where doing so would expose Compass Bullion to regulatory or commercial risk.

3. Customer Accounts

3.1 Registration

Customers may create an online account to facilitate future purchases.

Registration may require:

• full legal name;
• residential or business address;
• email address;
• telephone number;
• date of birth;
• identification documents where required.

3.2 Customer Responsibilities

Customers agree to:

• maintain accurate information;
• keep login credentials secure;
• immediately notify Compass Bullion of unauthorised access;
• not permit another person to use their account.

Customers remain responsible for all activity occurring through their account unless caused by Compass Bullion’s negligence.

3.3 Suspension or Closure

Compass Bullion reserves the right to suspend or permanently close an account where:

• fraudulent activity is suspected;
• these Terms are breached;
• payment defaults occur;
• identity cannot be verified;
• abusive or threatening behaviour occurs; or
• continued business is considered commercially unreasonable.

Compass Bullion may also refuse future transactions.

4. Live Bullion Pricing

4.1 Market Pricing

Precious metal prices displayed on this Website are derived from live international precious metal markets together with applicable premiums.

Prices may change at any time without notice.

Products placed in your shopping cart are not reserved and pricing is not locked until Compass Bullion accepts your order.

4.2 Pricing Updates

Compass Bullion reserves the right to update prices continuously in response to movements in:

• gold;
• silver;
• platinum;
• palladium;
• foreign exchange rates;
• refining costs;
• supplier pricing;
• freight;
• insurance;

4.3 Website Pricing Errors

Despite reasonable precautions, pricing errors may occur.

Compass Bullion reserves the right to:

• cancel an order;
• refund any payment received;
• correct pricing;
• refuse supply

where an obvious pricing error has occurred.

Compass Bullion will notify affected customers as soon as reasonably practicable.

5. Precious Metals Market Volatility

The customer acknowledges that precious metals markets are highly volatile.

Prices may change significantly within minutes due to:

• international bullion markets;
• currency fluctuations;
• geopolitical events;
• economic announcements;
• market liquidity.

Compass Bullion manages pricing risk by purchasing inventory and/or entering commercial arrangements immediately following acceptance of customer orders.

Accordingly:

• accepted orders are intended to be legally binding;
• cancellations may expose Compass Bullion to financial loss;
• customers may be liable for losses arising from default or cancellation in accordance with these Terms.

Customers should carefully consider their purchase before placing an order.

6. Order Acceptance

6.1 Invitation to Treat

All products displayed on the Website constitute an invitation to treat only.

Placing an order constitutes an offer by the customer to purchase.

No binding contract exists until Compass Bullion expressly accepts the order.

6.2 Acceptance

An order is accepted when Compass Bullion issues an Order Confirmation or otherwise communicates acceptance.

Compass Bullion reserves the right to decline any order for any lawful reason including:

• pricing errors;
• payment issues;
• stock shortages;
• suspected fraud;
• inability to verify identity;
• supplier allocation shortages;
• compliance requirements.

6.3 Order Limits

Compass Bullion may:

• restrict purchase quantities;
• limit sales of promotional products;
• refuse bulk purchases;
• allocate stock between customers.

6.4 Pre-Orders

Where products are sold on a pre-order basis:

• estimated release dates are supplied by manufacturers;
• release dates may change without notice;
• supplier allocations may be reduced;
• delays beyond Compass Bullion’s control do not constitute breach of contract.

7. Payment Terms

7.1 Accepted Payment Methods

Compass Bullion may accept payment by:

• Electronic Funds Transfer (EFT);
• Visa;
• Mastercard;
• PayPal;
• other approved payment methods.

Available payment methods may change without notice.

7.2 Payment Timeframes

Unless otherwise agreed in writing, payment must be received within 24 hours of order confirmation.

Failure to pay within this period may result in:

• cancellation;
• repricing;
• recovery of losses;
• refusal of future business.

7.3 Cleared Funds

Goods will not be dispatched until:

• payment has been received;
• funds have fully cleared;
• payment is irrevocable.

Bank transfer receipts do not constitute cleared funds.

7.4 Payment Processing Fees

Merchant fees incurred by Compass Bullion may be deducted from refunds where permitted by law.

Customers remain responsible for any fees charged by their financial institution.

7.5 Payment Default

Where a customer fails to complete payment, Compass Bullion reserves the right to recover all reasonable losses including:

• market losses;
• merchant fees;
• administration costs;
• storage charges;
• insurance costs;
• freight;
• debt recovery costs;
• legal costs on an indemnity basis where permitted by law.

8. Ownership & Title

Legal title to all goods remains with Compass Bullion until:

• full payment has been received;
• payment has cleared irrevocably; and
• all monies owing under the transaction have been paid.

Risk associated with delivery transfers in accordance with the Shipping, Delivery & Insurance Policy.

Nothing in this clause limits any rights available to customers under the Australian Consumer Law.

9. Identity Verification (AML/CTF Compliance)

9.1 Compliance

Compass Bullion is committed to conducting business in accordance with all applicable Australian laws, including legislation relating to anti-money laundering, counter-terrorism financing, fraud prevention and financial crime.

Compass Bullion reserves the right to implement customer identification and verification procedures at its discretion, whether or not legally required to do so.

9.2 Identity Verification

Compass Bullion may require customers to provide information or documentation including, but not limited to:

• Government-issued photo identification;
• Proof of residential address;
• Date of birth;
• Company registration details;
• Trust documentation;
• Proof of source of funds where appropriate; and
• Any other information reasonably required to verify identity.

Compass Bullion may verify this information through third-party verification services.

9.3 Delayed Orders

Compass Bullion may delay processing or dispatch of any order until all requested identification has been received and satisfactorily verified.

Any such delay shall not constitute a breach of contract by Compass Bullion.

9.4 Refusal of Transactions

Compass Bullion reserves the right to refuse, suspend or cancel any transaction where it reasonably believes:

• the customer cannot be adequately identified;
• false or misleading information has been provided;
• fraudulent activity is suspected;
• the transaction presents an unacceptable commercial or regulatory risk;
• compliance concerns exist; or
• completion of the transaction may breach any applicable law.

Compass Bullion is not obliged to disclose the reasons for refusing a transaction where doing so may prejudice fraud prevention, law enforcement activities or regulatory obligations.

9.5 Sanctions & Prohibited Transactions

Compass Bullion is committed to conducting business ethically, responsibly and in compliance with all applicable Australian laws, regulations and international sanctions regimes.

Compass Bullion reserves the right, at its sole discretion and without liability, to refuse, suspend, delay or cancel any order, account registration or transaction where it reasonably believes that completing the transaction may:

• breach any applicable Australian law or regulation;
• contravene any applicable sanctions, embargoes or trade restrictions;
• facilitate money laundering, terrorist financing or other financial crime;
• involve proceeds of crime or other unlawful activity;
• expose Compass Bullion to legal, regulatory or reputational risk; or
• otherwise be inconsistent with Compass Bullion’s internal compliance policies.

Compass Bullion may undertake such enquiries as it reasonably considers necessary to satisfy itself that a proposed transaction complies with all applicable legal and regulatory obligations.

These enquiries may include requesting additional information regarding:

• the identity of the purchaser;
• the identity of any beneficial owner;
• the intended recipient of the goods;
• the source of funds used to complete the transaction;
• the intended purpose of the purchase; or
• any other information reasonably required to assess compliance.

Where Compass Bullion is unable to satisfactorily verify the legitimacy of a transaction, Compass Bullion reserves the right to decline the transaction without providing detailed reasons where disclosure may prejudice fraud prevention, law enforcement activities or regulatory obligations.

Compass Bullion may also delay shipment or release of goods pending completion of any compliance enquiries.

Customers acknowledge that Compass Bullion may be legally prohibited from completing certain transactions or disclosing the reasons for refusing a transaction.

Nothing in these Terms obliges Compass Bullion to proceed with any transaction that it reasonably believes may expose Compass Bullion to legal, regulatory, financial or reputational risk.

10. Fraud Prevention

Compass Bullion maintains systems and procedures designed to protect both customers and the business against fraudulent activity.

Compass Bullion reserves the right to:

• verify payment methods;
• contact financial institutions;
• delay dispatch;
• request additional identification;
• require payment by bank transfer;
• refuse alternative payment methods;
• refuse transactions;
• cancel orders;
• report suspected fraud to law enforcement authorities.

Any losses incurred by Compass Bullion arising from fraudulent activity, attempted fraud or false representations may be recovered from the responsible party to the fullest extent permitted by law.

Compass Bullion also reserves the right to permanently refuse future business from customers involved in fraudulent or abusive conduct.

11. Pricing Errors

Compass Bullion makes every reasonable effort to ensure pricing displayed on the Website is accurate.

However, due to the nature of live bullion pricing, technical faults, supplier pricing changes, exchange rate movements or human error, incorrect pricing may occasionally occur.

Where an obvious pricing error exists, Compass Bullion reserves the right to:

• cancel the order;
• refuse supply;
• correct the pricing;
• issue a full refund of monies paid; or
• offer the customer the opportunity to proceed at the correct price.

Compass Bullion shall not be obliged to supply products at an incorrect price where the error would have been reasonably apparent.

Pricing corrections may occur before or after payment has been received but prior to dispatch.

12. Recovery of Market Losses

Customers acknowledge that precious metals are traded within rapidly fluctuating international markets.

Immediately upon acceptance of an order, Compass Bullion may:

• purchase inventory;
• allocate stock;
• secure supplier commitments;
• enter commercial arrangements;
• hedge market exposure.

Accordingly, customers acknowledge that cancellation or default may expose Compass Bullion to genuine financial loss.

Where a customer breaches these Terms, including by:

• failing to complete payment;
• refusing delivery;
• cancelling an accepted bullion order;
• initiating an unjustified payment reversal;

Compass Bullion reserves the right to recover all reasonable losses including:

• market losses;
• supplier cancellation charges;
• merchant processing fees;
• administration costs;
• freight;
• insurance;
• storage;
• debt recovery expenses;
• legal costs where recoverable by law.

Compass Bullion will take reasonable steps to mitigate its losses before seeking recovery.

13. Chargebacks

Customers agree not to initiate a chargeback or payment dispute unless:

• the transaction was genuinely unauthorised;
• required under applicable consumer protection legislation; or
• Compass Bullion has failed to resolve the issue within a reasonable period.

Fraudulent or unjustified chargebacks may constitute a breach of these Terms.

Compass Bullion reserves the right to:

• dispute any chargeback;
• recover merchant fees;
• recover associated losses;
• suspend customer accounts;
• refuse future transactions.

Nothing in this clause limits any statutory rights available to customers.

14. Risk Disclosure

Purchasing precious metals involves financial risk.

Customers acknowledge and accept that:

• precious metal prices fluctuate continuously;
• past performance is not indicative of future performance;
• Compass Bullion does not provide financial, investment or taxation advice;
• customers should obtain independent professional advice before making investment decisions.

Information published on the Website is provided for general information only and should not be relied upon as investment advice.

Compass Bullion accepts no responsibility for investment decisions made by customers based upon information contained on the Website.

Except where expressly stated, product descriptions, commentary and market information are provided in good faith and are believed to be accurate at the time of publication.

15. Limitation of Liability

Nothing contained within these Terms excludes, restricts or modifies any rights or remedies available under the Australian Consumer Law or any other legislation which cannot lawfully be excluded.

Subject to those statutory rights, Compass Bullion’s liability arising from the supply of products or services shall, to the maximum extent permitted by law, be limited to one or more of the following remedies, at Compass Bullion’s election:

• replacement of the goods;
• repair of the goods;
• resupply of equivalent goods;
• refund of the purchase price;
• payment of the reasonable cost of replacing or repairing the goods.

To the fullest extent permitted by law, Compass Bullion shall not be liable for:

• indirect loss;
• consequential loss;
• loss of profits;
• loss of business opportunities;
• loss of anticipated savings;
• loss arising from fluctuations in bullion markets;
• delays caused by third-party carriers;
• interruptions to Website availability;
• cyber attacks;
• unauthorised access to customer accounts not caused by Compass Bullion’s negligence.

Where liability cannot be excluded, it shall be limited to the maximum extent permitted by law.

16. Force Majeure

Compass Bullion shall not be liable for any failure or delay in performing its obligations where such failure or delay results from events beyond its reasonable control.

Such events include, but are not limited to:

• natural disasters;
• flood;
• fire;
• pandemic;
• epidemic;
• war;
• terrorism;
• civil unrest;
• industrial action;
• cyber attacks;
• ransomware incidents;
• internet outages;
• telecommunications failures;
• banking system failures;
• transport disruptions;
• supplier insolvency;
• refinery delays;
• mint production delays;
• customs delays;
• government action;
• import or export restrictions;
• changes in law;
• power failures;
• shortages of precious metals or packaging materials.

Where a Force Majeure Event continues for an extended period, Compass Bullion may:

• suspend performance;
• extend delivery timeframes;
• cancel affected orders;
• provide refunds where appropriate.

Compass Bullion will use reasonable endeavours to minimise the impact of any Force Majeure Event.

17. Intellectual Property

All content contained on the Compass Bullion Website, including but not limited to:

• text;
• product descriptions;
• photographs;
• graphics;
• logos;
• branding;
• artwork;
• icons;
• videos;
• software;
• databases;
• website design;
• source code; and
• downloadable material,

is owned by, licensed to, or used with permission by Compass Bullion and is protected by Australian and international intellectual property laws.

Customers are granted a limited, non-exclusive, revocable licence to access and use the Website solely for personal or legitimate commercial purchasing purposes.

Except as permitted by law, customers must not, without prior written consent:

• reproduce;
• copy;
• republish;
• distribute;
• sell;
• licence;
• modify;
• scrape;
• data mine;
• reverse engineer;
• frame;
• mirror; or
• commercially exploit any part of the Website or its content.

The Compass Bullion name, logo and associated branding remain the exclusive property of Compass Bullion. Unauthorised use of Compass Bullion’s intellectual property may result in legal proceedings.

18. Governing Law

These Terms & Conditions, together with any purchase made through the Compass Bullion Website, are governed by and shall be construed in accordance with the laws of the State of Victoria, Australia.

By accessing the Website or placing an order, you irrevocably submit to the non-exclusive jurisdiction of the courts of Victoria and any courts entitled to hear appeals from those courts.

Nothing contained in these Terms limits any rights you may have under applicable consumer protection legislation.

19. Dispute Resolution

Compass Bullion values its customers and aims to resolve disputes fairly, efficiently and in good faith.

19.1 Initial Resolution

If a dispute arises relating to these Terms, an order or the supply of goods or services, the customer agrees to first contact Compass Bullion in writing providing:

• full name;
• order number;
• description of the dispute;
• supporting documentation; and
• the outcome sought.

Compass Bullion will endeavour to acknowledge receipt within five (5) business days.

19.2 Good Faith Negotiation

Both parties agree to use reasonable endeavours to resolve any dispute through good faith negotiations before commencing legal proceedings.

Nothing in this clause prevents either party seeking urgent interlocutory or injunctive relief where necessary.

19.3 Mediation

Where a dispute cannot be resolved within twenty-one (21) days, either party may propose that the dispute be referred to mediation.

Unless otherwise agreed:

• mediation shall take place in Melbourne, Victoria;
• each party shall bear its own legal costs;
• mediation costs shall be shared equally.

Participation in mediation does not prevent either party commencing court proceedings if mediation is unsuccessful.

19.4 Australian Consumer Law

Nothing in this clause restricts any rights available under the Australian Consumer Law or prevents a customer from making a complaint to an appropriate government agency.

20. General Provisions

20.1 Entire Agreement

These Terms, together with Compass Bullion’s published policies, constitute the entire agreement between Compass Bullion and the customer relating to purchases made through the Website.

20.2 Severability

If any provision of these Terms is found to be unlawful, invalid or unenforceable, that provision shall be severed to the minimum extent necessary.

The remaining provisions shall remain in full force and effect.

20.3 Waiver

Failure by Compass Bullion to exercise any right under these Terms shall not constitute a waiver of that right.

Any waiver must be in writing.

20.4 Assignment

Customers may not assign or transfer any rights or obligations under these Terms without Compass Bullion’s prior written consent.

Compass Bullion may assign its rights or obligations where reasonably necessary.

20.5 Electronic Communications

Customers consent to receiving notices, invoices, order confirmations and other communications electronically.

Electronic communications satisfy any legal requirement that communications be in writing.

20.6 Survival

Any provisions which by their nature are intended to survive termination shall continue after termination, including:

• payment obligations;
• indemnities;
• limitation of liability;
• intellectual property;
• recovery of losses;
• dispute resolution;
• governing law.

20.7 No Partnership

Nothing contained in these Terms creates any partnership, agency, joint venture or employment relationship between Compass Bullion and any customer.

20.8 Compliance with Laws

Customers agree to comply with all applicable Australian laws when purchasing products through Compass Bullion.

Where products are exported, customers are responsible for complying with the laws of the destination country.

20.9 Sanctions & Prohibited Transactions

Compass Bullion reserves the right to refuse any transaction where it reasonably believes the transaction may contravene:

• Australian sanctions laws;
• anti-money laundering legislation;
• export restrictions;
• applicable international sanctions;
• other applicable legal or regulatory requirements.

Compass Bullion shall not be liable for refusing or delaying any transaction in order to comply with applicable law.

20.10 Updates to these Terms

Compass Bullion may amend these Terms from time to time.

The current version published on the Website will apply to future orders.

Orders already accepted shall continue to be governed by the Terms in force at the time of acceptance.

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Cancellation, Returns & Refund Policy

At Compass Bullion, we are committed to providing high-quality bullion and numismatic products together with excellent customer service. Due to the nature of precious metals markets, our cancellation and returns policy differs between investment bullion products and collectible numismatic items.

This Policy forms part of the Compass Bullion Terms & Conditions.

1. Australian Consumer Law

Nothing in this Policy excludes, restricts or modifies any rights or remedies you may have under the Australian Consumer Law (ACL) or any other applicable legislation that cannot lawfully be excluded.

Where a product is faulty, damaged, not of acceptable quality or not as described, you may be entitled to a repair, replacement or refund in accordance with your statutory rights.

2. Bullion Products

For the purposes of this Policy, bullion products include investment-grade precious metals whose value is primarily determined by the prevailing market price of gold, silver, platinum or other precious metals.

Examples include:

• Gold bullion bars
• Silver bullion bars
• Gold bullion coins
• Silver bullion coins
• Platinum bullion
• Palladium bullion
• Investment-grade minted and cast bars
• Other investment bullion products sold by Compass Bullion
• Because bullion prices fluctuate continuously and Compass Bullion immediately commits to purchasing inventory or managing market exposure once an order is accepted:
• all accepted bullion orders are final;
• change of mind cancellations are not accepted;
• change of mind returns are not accepted;
• exchanges due to market price movements are not accepted.

Customers are encouraged to carefully consider their purchase before placing an order.

3. Numismatic Products

Numismatic products include collectible coins, proof coins, graded coins, historical coins, medallions, collectible sets and other products whose value is influenced primarily by rarity, collectability or condition rather than precious metal content.

Subject to this Policy, Compass Bullion may, at its sole discretion, accept the return of eligible numismatic products.

To qualify:

• the return request must be made within seven (7) days of delivery;
• the item must remain unopened where sealed;
• the product must be unused;
• the product must remain in its original packaging;
• certificates of authenticity, presentation boxes and accessories must be included;
• the product must be received in resaleable condition.

Returns received without prior approval may be refused.

4. Restocking Fee

Where Compass Bullion agrees to accept the return or cancellation of an eligible numismatic product for reasons other than a fault or a customer’s statutory rights under the Australian Consumer Law, a minimum restocking fee of 30% of the original purchase price will apply.

This fee contributes towards the costs associated with:

• administration;
• order processing;
• product inspection;
• repackaging;
• inventory management;
• merchant transaction fees;
• price depreciation;
• and other reasonable costs incurred by Compass Bullion.

Where Compass Bullion’s actual losses exceed the minimum restocking fee, Compass Bullion reserves the right to recover its actual reasonable losses to the extent permitted by law.

Original shipping, insurance, payment processing fees and return freight are non-refundable.

5. Order Cancellations

Orders may only be cancelled with the prior written approval of Compass Bullion.

Compass Bullion is under no obligation to accept any cancellation request.

Where a cancellation is approved:

• applicable merchant fees;
• shipping costs;
• insurance costs;
• administration costs;
• supplier cancellation fees;
• market losses (where applicable); and
• any applicable restocking fee

may be deducted from any refund to the extent permitted by law.

6. Customer Default

If a customer fails to complete payment for an accepted order, Compass Bullion reserves the right to:

• cancel the order;
• resell the product;
• recover any actual losses arising from the customer’s default, including market losses on bullion products;
• recover merchant fees, administration costs, storage costs, legal costs (where recoverable by law), debt recovery costs, shipping and insurance expenses.

Compass Bullion will take reasonable steps to minimise any losses before seeking recovery.

7. Non-Returnable Products

Except where required by Australian Consumer Law, Compass Bullion does not accept returns or exchanges for:

• Bullion products;
• Special orders;
• Pre-order products;
• Products manufactured or ordered specifically for a customer;
• Products that have been opened, altered or tampered with;
• Products with damaged or missing packaging;
• Coin rolls where the original seal has been broken;
• Gift cards;
• Clearance or final sale items;
• Products showing signs of misuse or damage after delivery.

8. Return Process

Customers seeking to return an eligible product must first contact Compass Bullion to obtain return authorisation.

Unauthorised returns may be refused and returned to the sender at the customer’s expense.

Customers are responsible for ensuring returned items are securely packaged and adequately insured during transit.

Compass Bullion accepts no responsibility for returned goods lost or damaged before they are received.

9. Refunds

Once an approved return has been received and inspected, Compass Bullion will notify the customer whether the return has been accepted.

Where approved, refunds will generally be processed using the original payment method within a reasonable period.

Refunds may be reduced by any applicable:

• restocking fee;
• merchant processing fees;
• shipping costs;
• insurance charges;
• supplier fees;
• administration costs;
• other reasonable deductions permitted under these Terms and applicable law.

Processing times may vary depending upon the customer’s financial institution.

10. Incorrect, Damaged or Faulty Products

Customers should inspect all deliveries immediately upon receipt.

If a product:

• is damaged during transit;
• is faulty;
• is not the product ordered; or
• does not match its description,

the customer should notify Compass Bullion within 48 hours of delivery, providing photographs where appropriate.

Compass Bullion will work with the customer to provide an appropriate remedy in accordance with the Australian Consumer Law.

11. Contact Us

If you have any questions regarding cancellations, returns or refunds, please contact Compass Bullion through the contact details published on our Website before returning any goods.