Page 31 - Bullion World Issue 7 November 2021

Bullion World | Issue 07 | November 2021

high-level information to LBMA on the identity of the refiner and of the gold market and gold supply
a phased-in basis. Starting in 2022, local exporter located in red chains, as well as focusing on
refiners will disclose to LBMA the flag locations. auditor expectation under the
number and location of high-risk • Acknowledge the complexity audit programme. Detailed case
suppliers. In 2023, refiners will of risks: Welcome and publicly studies were examined, and a test
complete all relevant contractual acknowledge any (new) source was carried out to confirm auditor
changes with suppliers to allow for of material information with understanding at the end of the
greater disclosure, while continuing regards to possible risks in the three-day course.
to provide information to LBMA. company supply chain and
Thereafter, refiners will provide provide external stakeholders 5. ASM – Engaging Responsibly
LBMA with the full list of suppliers with an understanding of In addition to amendments to the
operating in high-risk locations. the challenges related to the RGG, LBMA is seeking to improve
Future versions of the RGG will management of these risks. and increase market access of
focus on fuller public disclosure of • Ongoing communication: ASM gold to GDL refiners. For
this information. Demonstrate the company’s this to happen a paradigm shift
efforts in raising awareness will be required that sees ASM
The best time to buy a Other guidance documents about the complexity of the in a separate light than industrial
In addition to the revised RGG issues. production. In addition to LBMA’s
CombiBarTM was 10 years ago.
version 9, LBMA updated the third- • Accountability: Assure support for standards such as
The second best time is now. party audit guidance, the refiner’s external stakeholders of the the CRAFT Code, LBMA will also
toolkit, and formalised standard company’s responsibility in look to support initiatives that
operating procedures for the managing the potential risks in focus on supporting progressive
Country of Origin data analysis and its supply chain. improvement, traceability and due
the Incident Review Process. • Predictability: Regularly diligence in the ASM sector.
communicate to external
3. Transparency: Mandatory stakeholders on the identified Conclusion
Disclosure Guidance issues and on the due diligence LBMA is committed to ensuring
The December 2020 disclosure steps to be implemented, as continuous improvement of
guidance mentioned above further per the company due diligence Responsible Sourcing business
outlines the disclosure expectation and risk management strategy. practices and support supply
that refiners must adopt as part chains that are free from threat
of their supply-chain disclosure 4. Audit Programme – Auditor financing.
practices. Refiners are encouraged Training
to opt for proactive disclosure, LBMA recognises that any audit is With the current three-year strategy
rather than reactive communication only as good as the auditor. The coming to a close in 2022, we
with regards to potential risks in ongoing review and enforcement of anticipate a year of reflection
the supply chain. The guidance LBMA’s Approved Service Provider and discussion as we define the
includes a template, which list (list of approved auditors) priorities that will shape our future
highlights what level of disclosure is are important elements for the direction. Without prejudicing the
expected from refiners. credibility of the Programme. LBMA outcome of those consultations, we
engages with auditors through expect that any new priority areas
The following recommendations training sessions, webinars and will build on and support existing
and principles are provided to bilateral discussions. programmatic efforts.
guide refiners on enhancing their
due diligence disclosure: During November – December
• Transparency: Mention the 2020, LBMA partnered with
nature of the risks that are Synergy Global Consulting
being dealt with and give to launch a comprehensive
information as to the context training programme for auditors.
in which they might occur. For Participation in this course was
instance, provide the location mandatory for all LBMA-approved
in the supply chain and broader auditors. The training focused on
geographical area, as well as improving auditor understanding

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