Page 29 - Bullion World Volume 4 Issue 5 May 2024

Bullion World | Volume 4 | Issue 5 | May 2024

commercial considerations. Following the World Gold GDL Refiners to report the origin of gold extracted from
Council's decision for member Refiners to disclose host material, even if from countries without operational
refining partners, GDL Refiners will reciprocally disclose mines. LBMA ensures thorough scrutiny of reported data
with mining partners. LBMA seeks clarity from the OECD and seeks input on additional data points for RGG 10.
on implementing Footnote 59 of the Gold Supplement to
the OECD Guidance, proposing a moderated session at Governance and Awareness Raising:
the upcoming OECD Forum to address interpretations. LBMA launched the ASM Initiative two years ago to
Collaboration in advancing this discussion at the forum is address governance challenges in the artisanal and
welcomed. small-scale mining (ASM) sector, aiming to bring
responsibly produced ASM material into legitimate
Assurance Programme markets. The ASM Toolkit, released at a recent summit,
A robust and independent assurance program is pivotal supports due diligence assessments for GDL Refiners
to the credibility of the Responsible Sourcing Program and ASM suppliers, aligning with OECD guidance
(RSP). LBMA introduced Responsible Gold Guidance and allowing for progressive improvement over time.
version 9 (RGG v.9) in 2021, accompanied by additional LBMA acknowledges the need for continued progress
policies to bolster the assurance process. RGG v.9 and invites support from industry stakeholders and
brought significant changes, such as eliminating cash local authorities. Recognizing the attraction of gold
transactions except for Artisanal and Small-scale Mining to criminal networks, LBMA consistently enhances
(ASM), clarifying material origin, and enhancing due governance measures, evidenced by the RGG's
diligence processes. It also mandated conformance with continual evolution with approximately 40 additional
Disclosure Guidance and introduced a 10-year rotation pages of requirements in RGG9. The Sourcing Advisory,
for assurance providers. issued in January 2024, highlights sourcing risks and
encourages Refiners to remain vigilant. LBMA remains
LBMA is committed to continuous improvement, with committed to addressing sourcing vulnerabilities and
RGG v.10 under development, including a review of seeks to add ASM capabilities while welcoming input
supporting tools and consideration of feedback on from civil society organizations. Adverse reports are
community and worker engagement disclosure. The thoroughly investigated, with significant incidents publicly
training program for Assurance Providers (APs) has announced and addressed through LBMA's Compliance
been strengthened, with LBMA bringing training in-house Panel.
and increasing the pass threshold to 80%. Assurance
provider rotation every 10 years promotes independence Looking forward
and audit quality, aligning with global best practices and We greatly value your input and assure you that your
EU regulations. While LBMA acknowledges the need for recommendations will be carefully considered during
more assurance providers to support a shorter rotation the review and drafting of RGG10 next year, particularly
period, it remains open to addressing capacity issues in in the context of the Good Delivery Brand. Some
collaboration with other audit programs. of your suggestions, such as disclosing payments
to governments under the Extractive Industries
Origin of Gold: Transparency Initiative (EITI), are already integrated into
RGG9 introduced stricter due diligence measures for the existing RGG. We fully endorse the idea of improved
recycled gold, requiring GDL Refiners to ensure their engagement between Refiners and civil society to gain
high-risk suppliers undergo OECD-aligned assurance. a deeper understanding of the local contexts from
LBMA plans to refine these requirements based on future which they source. We welcome further opportunities to
experiences and align its definition of recycled gold with collaborate on areas of shared interest or concern and
the ongoing ISO 21261 Working Group discussions to explore constructive and pragmatic ways to enhance
on product claims. Clarifying definitions remains a the RGG. Thank you once again for your letter to LBMA,
priority for RGG 10 development, especially regarding and we eagerly await your response on how we can work
the distinction between secondary material for due together to advance more responsible business conduct
diligence and recycled material for product claims. LBMA in the global precious metals market.
emphasizes the criticality of due diligence on recycled
gold, equivalent to that on ASM supplies, and requires

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