LBMA is pleased to release updated versions of the Third-Party Assurance Guidance (TPAG) and Disclosure Guidance, the two documents that support independent Assurance Providers and GDL Refiners, respectively, meet the reporting and disclosure requirements expected under the Responsible Sourcing Programme (RSP).
The TPAG and Disclosure Guidance are fully aligned with the Responsible Gold Guidance (RGG) version 9, introduced in January 2022, and against which 2023 assurances will be measured. The TPAG provides a lot more detail and clarity to assurance providers as they perform independent assurances of GDL Refiners. It sets out guidance on the application of the assurance concepts and requirements specific to these types of engagements as well as practical steps to address potential issues that may arise. The Disclosure Guidance provides greater alignment with the OECD Due Diligence Guidance Step 5 reporting requirements and, in instances, goes beyond this to encourage more transparent and meaningful communication by Assurance Providers and Refiners
Taken together, the changes outlined in both Guidance documents represent a significant strengthening of LBMA’s commitment to transparency and disclosure of information regarding the operations and supply chains of GDL refiners.
Third-Party Assurance Guidance (TPAG) (For use by Assurance Providers)
For a broad overview of some of the key material changes, please consult a Summary of Changes to the Disclosure Guidance, issued in August 2022.
Refiners are also encouraged to confirm their preferred choice of Assurance Provider is on the Approved List of Service Providers, prior to proceeding with any assurance engagement.
Guidance effective date
The effective implementation date is as follows:
Third-Party Assurance Guidance: Reporting periods commencing on or after 1 January 2023 and cover activities over the previous 12 months.
Disclosure Guidance: As Refiners have until 31 December 2022 to fully implement the new requirements of RGG version 9, this Disclosure Guidance should be implemented for reporting for the year ending 31 December 2022.
It is noted, however, that Refiners may not have certain systems and processes in place to produce quantitative data and/or qualitative data that is outlined in the Disclosure Guidance (but may not be covered in RGG version 9). As such, Refiners have until 31 December 2023 to address this aspect of the Guidance.
For the avoidance of doubt, Step 5 of RGG version 9 (page 38), states: “The Country of Origin Annex should, as a minimum, meet the requirements outlined in the Disclosure Guidance documents in the Refiners Toolkit. Minimum information includes:
a. List of gold sources by country and by type of material sourced, and related information.
b. Total gold sourced by type of material (LSM, ASM, Recycled Gold, Grandfathered Stocks) in the reporting period.
c. The identity of the Refiner and the local exporter, if located in high-risk locations, should always be disclosed except in cases of disengagement.
This minimum information is required as part of the RGG version 9 implementation. Refiners will have until 31 December 2023 to meet the additional Country of Origin requirements highlighted in the Disclosure Guidance.”
LBMA would like to thank members of the Refiners Committee and select Assurance Providers that participated in the consultation process. Their contributions improved the final Guidance documents and reflect our shared commitment to the continuous improvement of the Responsible Sourcing Programme.
Refiners or Assurance Providers requiring clarification or additional information regarding either the Third-Party Assurance Guidance or the Disclosure Guidance are welcome to contact the Responsible Sourcing team at firstname.lastname@example.org.