Responsible Sourcing Newsletter: March 2024

A Few Takeaways from the Sustainability & Responsible Sourcing Summit

Transparency. Authenticity. Collaboration. Risk. Mitigation.

These are some of the main takeaway themes for me from this month’s LBMA/WGC Sustainability & Responsible Sourcing Summit.

Let’s unpack some of the conversations around these themes, because in my view they are all interlinked.

Transparency as a basic business practice

Akshat Rathi, a keynote speaker and author of Climate Capitalism, made the point that business needs to be more transparent with the public - not just about what might be going right, like meeting a particular climate target, but also publicly reporting what didn’t go to plan. Doing so prevents allegations of greenwashing, but also sensitises the public to the real and genuine challenges of meeting climate targets or implementing structural change within established corporate orthodoxy.

LBMA often engages with stakeholders - mostly in the NGO sector - who want LBMA and Good Delivery List (GDL) Refiners to disclose more information about their business practices and operations. This is particularly the case with respect to the disclosure of high-risk suppliers or mitigation efforts that follow a sourcing breach.

A common criticism within the world of the OECD Forum on responsible mineral supply chains is that industry groups are reluctant to fully implement their Step 3 (mitigation) and Step 5 (public reporting) obligations. Part of this reservation may lie in a fear of how the information will be interpreted. If a Refiner discloses X, will that be weaponised by NGOs, or will it spook their banks or insurance companies into prejudicially re-evaluating their credit rating or risk profile?

In my experience it is not that Refiners don’t mitigate, or want to be transparent about what they do. Adverse incidents and mitigation efforts are disclosed to LBMA, and Refiners are mandated to cooperate and share information with LBMA during a potential sourcing issue. The same goes for disclosing the names and locations of high-risk suppliers in their annual assurances - a requirement introduced in Version 9 of the Responsible Gold Guidance. But growing Refiners’ comfort levels with full public disclosure of this kind of information is something we realise is an inescapable part of the continuous and incremental improvement arc. Charlie Betts, managing director of The Betts Group and co-founder of Single Mine Origin, had one of the best zingers of the Summit: “Transparency is a magnifier of ethics.” He is not wrong and we have our work cut out for ourselves as we work toward better public disclosure of information.

The opening line of Rathi’s book posits: “It’s now cheaper to save the world than destroy it.” The same line could be paraphrased to include the practice of appropriately assessing risk, undertaking proper mitigation and being transparent in what you do. In the long run, doing nothing almost invariably costs more, carries reputational jeopardy, and invites more unwanted scrutiny.

In making his case for more forward thinking by industry, Rathi referenced the example of Unilever, the consumer goods giant, that was an early adopter of mainstreaming sustainability into its core business model. Then CEO Paul Polman realised that the company was losing market share to competitors with a business plan that focussed too much on short term profits and targets they couldn’t deliver on.

Polman stepped back to assess what was needed. Realising that much of what the company produced came from countries impacted by climate change, Polman set out to show a more sustainable form of capitalism was possible, and that a demand for green products was there. His solution was to integrate a climate plan into the core business strategy, one of the first corporations to do so. The result, as the book points out, saw Unilever’s market capitalisation grow threefold during his tenure; revenues rose 30% and direct emissions were more than halved.

Being honest and authentic in what is said and done was an often-reinforced refrain across several panels. “Credibility of the industry is going to rest in being unimpeachable in what we are telling the public,” said Michelle Richardson, chief impact officer at the Royal Canadian Mint (RCM). Equally important, she added, is to influence change by having transparent conversations with all partners and suppliers, and share lessons learned as you go along. Later this year, the RCM plans to issue its first ESG Impact Report.

Zero risk doesn't exist: the case for engagement and mitigation

On the risk and mitigation side, I was left thinking about the experience of Rashid Ackah, a Ghanaian gold trader, who used to supply approximately 4 tonnes of ASM material to a GDL Refiner until rising standards and changing public perceptions led the Refiner to exit the ASM sector in 2016. This was not an isolated incident, as evidenced by the low amounts of ASM material GDLs currently receive - approximately 2% of combined throughput of our Refiners. It’s not a question of relitigating the circumstances that led to that decision, but a comment by Xavier Miserez of MKS PAMP that “Zero risk doesn’t exist” was bang on. Ditto illicit supply chain researcher David Soud’s point that risk is always changing. In retrospect adopting a more holistic risk assessment process and appropriate risk mitigation with suppliers could have averted the current isolation of the ASM material from the legal gold market. In the pursuit of “perfection”, a choice - conscious or otherwise - was in fact made for avoidance, neither of which did anything to support the governance of a sector replete with governance challenges.

At the beginning of a panel discussion on ASM that I moderated, delegates were asked whether or not ASM material should automatically be classified as high risk (as it is currently defined in the RGG). I was pleasantly surprised with the even split in the answers. While the 2016 disengagement was undoubtedly not unanimously embraced by all market participants, the result shows that there is a growing openness and recognition of the nuance within the ASM market. This bodes well as LBMA launched its ASM Toolkit to support the integration of Artisanal and Small-Scale Mining (ASM) production into the legitimate supply chain.

If the purpose of the Summit was to provoke and give us food for thought, it was undoubtedly a success. Thank you to my colleagues for their hard work, and to all the attendees who came. Next year, LBMA will begin drafting the 10th version of the RGG. We welcome collaboration from all quarters as we embark on that process, and work toward better.