Responsible Sourcing Governance
The Physical Committee and LBMA’s Compliance Panel oversee the policy development and implementation of the Responsible Sourcing programme, for example the complaints mechanism and incident handling procedure.
LBMA’s Compliance Officer is responsible for the day to day running of the programme and participates on the Compliance Panel (CP). The CP reports to the Executive Committee (ExCom) on all matters relating to the management, governance and development of the Responsible Sourcing programme. Non-conformances are escalated by the Compliance Officer to the CP for review and action. The Physical Committee is notified of any action taken by the CP.
Incident Review Process
The Incident Review Process is invoked in response to a particular stimulus of a reputational nature. Information can come from a variety of sources (trade associations, law enforcement agencies, market intelligence, etc.) and the LBMA will seek corroboration wherever possible as part of the process. Due to the sensitivities involved, the LBMA may keep the process confidential until the issue has been resolved.
Refiners can raise concerns about the process directly with LBMA. Complaints must be made in writing and be accompanied by supporting evidence. The Compliance Officer will review the details of the complaint and the outcome will be formally communicated to all interested parties.
The formal process involves 11 steps:
Failure to meet the standards required has serious implications for GDL refiners. Sanctions could include suspension subject to resolution or being transferred to the Former List with immediate effect. To date, four refiners have been removed from the Good Delivery lists, and one auditor has had its approved auditor status revoked.
It is vital that refiners develop and publicise a mechanism allowing any employee or external stakeholder to anonymously voice concerns about the gold or silver supply chains, activities of a refinery or any newly identified risk.
Similarly, anyone else involved in the gold or silver supply chains is encouraged to contact LBMA with all legitimate concerns they may have.