Incident Review Process
Our Physical Committee and Compliance Panel oversees the policy development and implementation of our Responsible Sourcing programme.
Incident Review Process
The Incident Review Process is invoked in response to a particular stimulus of a reputational nature. Information can come from a variety of sources (trade associations, law enforcement agencies, market intelligence, etc.) and the LBMA will seek corroboration wherever possible as part of the process. Due to the sensitivities involved, the LBMA may keep the process confidential until the issue has been resolved.Refiners and Members can raise concerns about the process directly with LBMA. Complaints must be made in writing and be accompanied by supporting evidence. The Compliance Officer will review the details of the complaint and the outcome will be formally communicated to all interested parties.
The process is designed to ensure a thorough and fair review of the Member’s activities. Given that the process involves numerous stakeholders to verify the information (including those within LBMA's Responsible Sourcing, Good Delivery, and Membership teams), it is difficult to conclude an average lifespan of each incident reviewed under the IRP. However, it must be understood as an iterative process, particularly in situations where new information is produced, or a situation escalates.
Any outcome of the IRP process will be subject to a quality control check, by a subgroup of the LBMA Board, who will also determine the final decision. This subgroup comprises the independent Non-Executive Directors, the Chief Executive and the Executive Directors of the LBMA Board. The decision by this group will be final.
The formal process involves 11 steps
Failure to meet the standards required has serious implications for GDL refiners. Sanctions could include suspension subject to resolution or being transferred to the Former List with immediate effect. To date, four refiners have been removed from the Good Delivery lists, and one auditor has had its approved auditor status revoked.
It is vital that refiners develop and publicise a mechanism allowing any employee or external stakeholder to anonymously voice concerns about the gold or silver supply chains, activities of a refinery or any newly identified risk.
Similarly, anyone else involved in the gold or silver supply chains is encouraged to contact LBMA with all legitimate concerns they may have.
All GDL refiners and new applicants must engage an independent third-party auditor on LBMA's Approved Auditors List to conduct annual Responsible Sourcing audits.