Sustainability and Responsible Sourcing

Advancing Transparency, Assurance and Engagement

In 2025, the Sustainability and Responsible Sourcing team has focused on execution – increasing transparency, streamlining internal standards and strengthening assurance oversight – while embedding a set of interlocking “Building Blocks”.

This work underpins the forthcoming Responsible Gold Guidance v10 (RGG10), scheduled for publication in 2026.

Transparency Roadmap

LBMA has committed to accelerating key transparency enhancements for Refiners. Originally slated for 2027, these measures are expected to be incorporated into Refiners’ compliance reports beginning January 2026.

LBMA’s Refiner Transparency Roadmap adopts disclosure requirements aligned with Footnote 59 of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance). LBMA will become the first industry scheme to require Refiners to publicly disclose:

• The identity of the Refiner and local exporter in “red flag” locations as per OECD Guidance.
• All World Gold Council (WGC) miners and mines from which Refiners receive material.
• All locations (countries) from which mined material is sourced.

Following a public consultation, LBMA will publish Disclosure Guidance v3 (DG3) in December 2025 to help Refiners implement these requirements. The roadmap also envisions future disclosures covering supplier identities, sourcing volumes and all suppliers in high-risk locations as defined under RGG10.

Building Blocks

The four building blocks below aim to make the Responsible Sourcing Programme more transparent, accountable and resilient.

1: EU Alignment Re-application

LBMA, through increased alignment scores across all assessment categories, has made progress towards full recognition under the EU Conflict Minerals Regulation. The European Commission (EC) found LBMA “fully aligned” with Section B (alignment with the five-step framework) and Section C (specific responsibilities of schemes), and 89% of Section A (overarching due diligence principles). The remaining 11% of Section A was deemed “partially aligned”. No sections were deemed “not aligned”.

LBMA plans to reapply to become a recognised industry scheme under the EU Conflict Minerals Regulation in 2026.

2: Enhancing Approved Assurance Provider Performance

In 2025, two independent expert reviews of LBMA’s certification process were undertaken. These reviews identified opportunities to streamline processes and strengthen internal controls, resulting in the launch of a revised Approved Assurance Provider Toolkit (AAP Toolkit), updated AAP application and capability monitoring requirements, and a tailored AAP training programme.

3: Strengthening Value Chain Engagement

Cross-Industry Collaboration

Partnership remains central to LBMA’s approach. In 2025, LBMA and the WGC, together with the World Bank and Intergovernmental Forum on Mining (IGF), helped launch the Global Coalition for Action on Artisanal and Small-scale Gold Mining (ASGM). This initiative supports producer governments in creating incentives for responsible ASM practices.

LBMA also worked with the WGC to promote the London Principles among central banks sourcing ASM gold, emphasising that all material should be processed by a Good Delivery List (GDL) Refiner.

Civil Society Engagement

The responsible sourcing eco-system is as diverse as the risks it seeks to address. LBMA has long recognised that progress depends on coordination with peer initiatives and associations that share a commitment to transparency, consistency and good governance.

4: Strengthened Outreach and Communications

LBMA’s dialogue with civil society organisations (CSOs) continues to support the evolution of the Responsible Sourcing Programme. A significant outcome of this outreach is the announcement of a Public Private Partnership by the UK Foreign Commonwealth and Development Office (FCDO) to drive multistakeholder engagement.