Page 9 - Bullion World Issue 1 May 2021
P. 9

Bullion World | Issue 01 | May 2021
           ABOUT                             WIDER




           LBMA                              ECOSYSTEM




                                              Global effort, amongst all the value
           LBMA is uniquely positioned to collab-  chain actors, national authorities as
           orate with IBCs.  This is partially due to   well as law enforcement agencies,
           the LBMA Good Delivery List (GDL).   is required to help address the
           LBMA sets the requirements to which re-  threats. Industry Programmes, whilst
           finers must adhere in order to qualify as   necessary, have limitations in their
           a GDL refiner and sell gold to the Loco   legal authority, scope, applicability
           London market – the largest financial   and enforcement resources. That is
           marketplace for precious metals.   why it is important to collaborate with
                                              the various actors in the IBCs that
           The GDL is also relied upon by most   make up the Responsible Sourcing
           major international markets, licensed and   eco-system.
           recognised by exchanges, central banks
           and traders worldwide. LBMA is also the   Industry Due Diligence Programmes:
           vice chair of the OECD Multi-Stakehold-  These Programmes seek to raise
           er Group, focused on the development   standards throughout the supply chain
           of the OECD Due Diligence Guidance   (mining, refining or retailing level)
           and the supporting Gold Annex. All of   and can be enforced if any non-
           this means that LBMA is well placed to   conformances are identified.
           collaborate and engage with IBCs, to
           advance standards that ultimately aim   National Authorities: Through
           to address the integrity of the precious   regulatory change and law
           metals market.                     enforcement, national authorities   5: COLLABORATION
                                              provide the ultimate sanctions across   It is fundamental that the wider eco-
           LBMA Responsible Sourcing          the supply chain.                 system operates as one. This will help
           Programme                                                            to mitigate threats to the industry while
           A fundamental aspect of the GDL is that   Downstream Actors: Banks,   implementing standards consistently
           Good Delivery bullion can be trusted to   electronics and jewellery companies   throughout global supply chains. It will
           be responsibly sourced. This chain of   can continue to collaborate with their   also mitigate the risk of re-routing
           integrity is vital across the bullion market   suppliers to ensure that material is   supply to IBCs that might have differ-
           and has been the foundation for the con-  sourced and processed responsibly   ent requirements.
           tinuous development of the Responsible   from beginning to end.
           Sourcing Programme (RSP). LBMA’s                                     A global effort is required to continue
           RSP was set up in 2012 to consolidate,   Other Stakeholders: By identifying   addressing the outstanding challeng-
           strengthen, and formalise existing   and escalating unique issues    es and risks. LBMA is committed to
           standards of refiners’ due diligence. The   through investigative research, other   working with all legitimate stakeholders
           Programme is based on the OECD Guid-  stakeholders provide important   but needs full engagement and co-op-
           ance, that provides detailed recommen-  support and feedback throughout the   eration as its own standards can only
           dations to help companies define their   supply chain.               reach so far.
           sourcing standards, as well as sets the
           five-step due diligence framework.
                                              For more information on the LBMA Responsible Sourcing Programme, please see
           LBMA makes these OECD requirements   report, RS Report  or visit our website at lbma.org.uk .
           mandatory for all GDL refiners who must
           be audited annually against the OECD
           Guidance by approved independent
           auditors. The refiners are then required   Ms Sakhila Mirza, Executive Board Director and General Counsel
           to report the audit findings publicly.
           Unlike any other industry programmes,   In her role as General Counsel of LBMA and also as Executive Director of the LBMA
           the RSP is a commercial necessity for   Board, Sakhila Mirza works closely with the CEO on the strategic direction of the LBMA.
           any major refiner and LBMA can ulti-  Her role involves addressing all  the legal  and regulatory matters, the Responsible
           mately remove a refiner from the GDL if   Sourcing Programme, market development initiatives, and lobbying efforts on behalf
           the standards are not met. Compliance   of members.
           with the stringent RSP standards is
           therefore essential.               Sakhila read law at the London School of Economics and went onto qualify as a solicitor.


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