Page 9 - Bullion World Issue 1 May 2021
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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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