Spotlight on Brazil: ESG and Responsible Sourcing

Recently we have been keeping an eye on legislative developments in Brazil and their implications for responsible sourcing.

Brazil’s Lower House overwhelmingly passed a Bill on Wednesday, 12 May that withdraws environmental impact assessments and licensing for development projects, including mining in protected areas of the Amazon. The Bill — currently being debated by the Senate — is backed by President Jair Bolsonaro and the powerful agribusiness lobby who champion it as a way to slash red tape on environmental assessments and licensing.

Opponents are convinced the new legal framework will inevitably fast-track approval of high-risk projects, leading to greater deforestation of the Amazon and an escalation of violence against indigenous communities, like the Yanomami people. Already there has been a noticeable uptick in armed and violent altercations between miners and the Yanomami (see News Roundup below).

That the Amazon —the world’s lungs as environmentalists call it — is under threat is not new. But current developments raise several issues from a responsible sourcing perspective and could well serve as a test case for how LBMA refiners respond to the Environmental Social Governance (ESG) requirements gathering steam around them.


How valid is the legal right to exploit a resource in an environmentally endangered area, especially when it lacks social license from endangered indigenous communities? How do LBMA refiners mitigate — rather than run from — risks associated with gold sourced in the Amazon? And how does the gold industry respond to new forms of conflict beyond the well-worn parameters set by the civil war in the Democratic Republic of Congo, which, as discussed in the last issue, has defined much of the responsible sourcing debate of the last decade?

With the current revision of the Responsible Gold Guidance (RGG) and its added emphasis on ESG, questions like these are not moot. Rather they strike at the heart of how the ethical sourcing landscape is continually shifting and evolving; and the need for LBMA (and its members) to proactively keep pace.

One key change in the draft RGG calls on refiners to encourage gold supplying counterparties to commit to their own gold supply chain policy. This policy should not only be consistent with Annex II of the OECD’s Due Diligence Framework but govern common ESG risks such as sourcing from environmentally protected areas or instances where tensions exist with local communities and indigenous peoples

These changes are a necessary part of the continuous improvement that underpins the OECD Due Diligence framework, as well as LBMA’s commitment to responsible sourcing. Public consultations of the RGG revision will begin in June and we once again encourage you to reach out to us if you are interested in participating. Reach out to us at if you are interested in participating.

LBMA Webinars - ESG & Mining

Watch now, host Neil Harby (Chief Technical Officer, LBMA), Grant Beringer (Group Sustainability Executive, Barrick Gold Corporation) and Edward Bickham (Senior Advisor, World Gold Council) discuss what's currently going on in the world of ESG and Mining.

LBMA Responsible Sourcing Programme Update

LBMA has published a mid-year update to outline the progress made on its 'Five Key Strategic Focus Areas' as well as the latest on 2020 audits.

These five key areas – value chain accountability, advancing standards, transparency, audit programme, and Artisanal and Small-Scale Mining – underpin the priorities for the programme over the next three years and are key to building long-term trust and credibility in the industry globally.

Central to LBMA’s strategy is engaging with stakeholders, and this year will continue to see a focus on several initiatives which require close collaboration with various actors in the supply chain, as well as with other industry programmes.

Read the full update here.

Webinar on Illicit Gold Markets in Eastern and Southern Africa

For those of you who missed it, our last webinar featured Marcena Hunter, a senior analyst with the Global Initiative Against Transnational Organized Crime. She walked us through the key findings of their latest report on five illicit African gold markets.

Marcena spoke about the resiliency of illicit markets and how easily they adapt to market interference, like Covid. She also highlighted the need to differentiate between informal and illegal artisanal production — arguing that calling it the former masks governance challenges and the bureaucratic manipulation of the sector by political elites. The report also shines a light on the role the recycled market plays as the main conduit by which illegal material gets laundered into international markets. If you missed it live, the webinar can be accessed here.

Responsible Sourcing News


  • Brazil: After Gold Miners Shoot Yanomami People, Brazil Cuts Environmental Regulation Further. Mongabay
  • Brazil: Impunity Driving Uptick In Violence Against Yanomami In Brazil. Insight Crime
  • Brazil: Brazil Court Orders Illegal Miners Booted From Yanomami Indigenous Reserve. Mongabay
  • Brazil: Doubts linger Over Army Mission To Save Brazil’s Rainforest. FT
  • Peru: Pictures From Outer Space Reveal The Extent Of Illegal Gold Mining In Peru. The Conversation
  • Venezuela: The Unlikely Resistance Of A Lone Mining Gang In Venezuela. Insight Crime
  • South America: Why South America’s Armies Are Losing the War For The Amazon. Insight Crime


  • Democratic Republic Of Congo: Price Of Gold: DRC’s Rich Soil Bears Few Riches For Its Miners. The Guardian
  • Ghana: Government Committed To Compliance With Mining Laws- Upper East Regional Minister. Myjoyonline
  • Ghana: Involve Chiefs In Galamsey Fight – Otumfuo To Govt. Modern Ghana
  • Ghana: Government Will Spend Over US$3 Billion To Reclaim Lands Destroyed By 'Galamsey' - Small Scale Miners. Ghana Web
  • Ghana: Nineteen Alleged National Security Operatives Arrested For Illegal Mining In Atewa Forest. Myjoy Online
  • Guinea: Fifteen Killed In Landslide At Guinea Gold Mine. Reuters
  • Kenya: Police Link Fake Gold Fraudsters To Forged Currencies Cases. The Star
  • Malawi: Malawi President Eyes Mining As Key Money Maker. Voa News
  • South Africa: Mankele Locals Tackle Zama Zamas. Sunday World


ESG News:

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Webinars & Events

20 September: Virtual Precious Metals Conference, LBMA/LPPM

20 September: London Networking Reception, LBMA/LPPM

6-9 October: IPMI 45th Annual Conference, IPMI

4-8 October: ESG Week: Energy and Mining Forum, Natural Resources Forum

12 October: LME Annual Dinner, LME

19 - 20 October: Responsible Business & Responsible Minerals Conferences, RBA/RMI

1 December: LBMA/LPPM Annual Dinner, LBMA/LPPM