November 17, 2023

Responsible Sourcing Programme - Document Updates

LBMA has introduced some new documents, for both Good Delivery List (GDL) Refiners and Assurance Providers, that have been designed to support LBMA’s Responsible Sourcing Programme. This includes measures to streamline Refiners’ data submission requirements through a new Refiner Data Collection Form, as well as updating how Assurance Providers report on non-conformances. LBMA has also devised a new Toolkit for Assurance Providers to use during the assurance process. Further details on these are set out below.

Guide to Completing Refiner Data

GDL Refiners are required to submit three data sets (Throughput, Tangible Net Worth, and Country of Origin data) to LBMA on an annual basis. We have produced a single reporting template for Refiners to provide this information. This template, called the Refiner Data Collection Form, includes the Country of Origin Annex. For assurance engagements taking place from 1 January 2024 onwards, Refiners are required to submit all three data sets in this template. LBMA has also prepared a Guide to Completing Refiner Data.

Assurance Provider Toolkit

The Assurance Providers Toolkit is intended for Assurance Providers to use when performing their independent assurance of a GDL Refiners’ Compliance Report in accordance with LBMA’s Responsible Sourcing Guidance. It has been developed to promote quality and consistency in the conduct of an assurance engagement across the LBMA Responsible Sourcing Programme. It consists of a minimum set of questions that all Assurance Providers would be expected to ask during the assurance process, as well as a list of documents that they are expected to review.

Non-Conformances Template

GDL Refiners should submit a Corrective Action Plan (CAP) if a high-risk or medium-risk non-conformance has been identified during the assurance and/or if the Refiner fails to satisfy one or more requirements set out in Steps 1-5 of the Responsible Gold Guidance (RGG) or Responsible Silver Guidance (RSG). To enhance efficiencies, LBMA has introduced a non-conformances reporting template for Assurance Providers to complete and return to LBMA.