March 12, 2021

LBMA Responds to NGO Open Letter on Responsible Sourcing

The LBMA Responsible Sourcing Programme plays a fundamental role in providing trust and confidence in the global precious metals market. However, the LBMA also recognises the challenges that all audit programmes face, and whilst no programme is perfect, we remain committed to continuous improvement, and ongoing engagement with stakeholders in addressing the supply chain risks. In addition, we are focused on enhancing transparency and welcome feedback from all stakeholders to help us achieve fuller and better transparency over our process, policies, including how we manage conflicts of interest.

Looking to the year ahead, we are in the process of revising our Responsible Gold Guidance (RGGv9), as well as the Third-Party Audit Guidance. The updates will reflect the feedback we have received from stakeholders and further strengthen the disclosure requirements. We will of course, as we have done since the first version in 2011, undergo a public consultation, however constructive feedback is welcomed at any time.

Over the course of the last 12 months, we published our first Responsible Sourcing report, launched the new Refiner’s Disclosure Guidance, and issued the International Bullion Centres Recommendations. The Refiner’s Disclosure Guidance (which we shared with Global Witness previously) is being implemented on a voluntary basis this year, with mandatory compliance from 2022, as part of RGGv9. The disclosure requirement is aimed at improving transparency and further strengthens the implementation with the OECD Guidance.

I would also encourage you to review our International Bullion Centres initiative which looks to engage national authorities particularly on the issues of recycled gold, cash transactions and support for artisanal miners. This work is focused on twelve gold centres, which trade significant volumes of recycled gold, and we are keen to work with the centres to reduce the illegitimate sector in size and bring in the ASM sector. The national authorities play a critical role in the overall Responsible Sourcing Ecosystem. A global effort amongst all the value chain actors, as well as national authorities, and law and enforcement agencies is required to continue addressing the outstanding challenges and risks.

Finally, and as highlighted above, the LBMA programme leads the way for the gold market and approving the programme will further strengthen our position in being able to continuously raise the bar and improve the global standards. This will help to put pressure on the illegitimate sector, and the LBMA can help lead the work, with support from other stakeholders.

Thank you for your recommendations and look forward to engaging with you during the next chapter of Responsible Sourcing.

Ruth Crowell
LBMA Chief Executive