April 25, 2024

Responsible Sourcing Newsletter: April 2024

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Don't Bite the Messenger: Navigating Civil Society Criticism

Last month, LBMA received a letter from a group of Civil Society Organisations (CSOs) that questioned the comprehensiveness of the Responsible Sourcing Programme (RSP) and set out a series of recommendations to improve the global precious metals market.

We dedicate significant thought and effort to keeping our responsible sourcing policies and practices current and fit for purpose. We understand that, whatever the latest improvements to the Responsible Gold and Silver Guidance, a commitment to continuous improvement means our job is never done. And while we may disagree with many of the allegations and conclusions of the signatories, taking their concerns personally or responding in a defensive and dismissive manner is counterproductive to everyone involved. We welcome constructive engagement such as this.

Engagement with Civil Society is a cornerstone of LBMA’s RSP. CSOs often bring to light legitimate concerns about the governance of global gold/silver supply chains. Sometimes their field presence or analysis can give us better appreciation or line of sight of certain issues. Their concerns can inform our understanding of emerging issues and changing public norms and guide the improvement of our sourcing standards and policies. In short, the world need not be a polarised and binary place, where industry and CSOs discount the other and only engage as hostiles.

So rather than smart from the sting of their criticism, LBMA welcomes the opportunity such letters afford to foster a constructive dialogue with CSOs about our ongoing efforts to address their concerns, as well as explore practical ways by which we can collaborate to improve the RSP.

LBMA’s response can be found via our website.

The response summarises the progress to date in addressing their concerns, responds to their recommendations, and highlights our plans for future development of the RSP.

During last month’s Sustainability & Responsible Sourcing Summit, LBMA leadership held a constructive discussion with a group of CSOs - some of which were signatories to the letter - to open up more avenues of dialogue and cooperation. A second meeting is planned for the OECD Responsible Minerals Forum at the end of May.

Ask Responsible Sourcing

Earlier this year we launched “Ask Responsible Sourcing”, where any interested party can ask questions related to LBMA’s sourcing policies and procedures.

Our intention is for this initiative to foster dialogue with a critically important demographic - GDL Refiners, Approved Service Providers, CSOs, and the broader public - and give LBMA an indication of issues that are important to these key stakeholders.

Question: “An LBMA assurance provider is undertaking an annual review for our refinery and required on-site due diligence report for every gold material supplier. If the materials are sourced from our inner group company's miners and all the documents required are prepared, does our refinery need to take on-site due diligence and provide the said report?” - A Refiner

Answer: While Refiners are able to rely upon company-wide compliance systems to demonstrate shared KYC information, such as ultimate beneficial ownership and details of legal registrations, all materials sourced from within a group or company must have appropriate due diligence performed on them. Even from within a group there can be differentiations of sourcing threats that can be very localised and not shared across affiliated entities. For this reason, Refiners are obligated to undertake a risk-based assessment of potential sourcing vulnerabilities specific to their different supply chains. The regularity of the site visits will depend on the risk level of the suppliers. For example, mine site location can offer a variation of security risks and proximity to Annex II risks, as can the routes by which the material takes to get to the Refiner. Material coming from a conflict-affected or high-risk area (CAHRA) will obviously need to be treated with more scrutiny than those mines that operate outside CAHRAs.

Have a question you have always wondered about but were afraid to ask? Send it to Ask Responsible Sourcing.

Questions can be submitted by using this form or scanning the QR code. Questions will be published (on an anonymised basis) with answers appearing in the next Newsletter.

Alan Martin
Head of Responsible Sourcing, LBMA