Disclosure Guidance Version 3

Introduction

Purpose

This Disclosure Guidance (DG3) has been updated to support LBMA GDL Refiners (Refiners) in the implementation of the Responsible Sourcing Programme (RSP) reporting and disclosure requirements. DG3 provides greater alignment with the OECD Due Diligence Guidance1 Footnote 59 reporting requirements and, in instances, goes beyond this to encourage more transparent and meaningful communication by Refiners.

DG3 should be interpreted as a minimum threshold upon which Refiners should build and continually improve reporting and disclosure practices. It forms part of the Refiners Toolkit and, as such, Refiners are expected to implement it on a comply or explain basis.

Supplier information is provided by Refiners as part of their due diligence and independent assurance obligations. LBMA reviews assurance outcomes in accordance with its oversight role but does not undertake primary verification of supplier data. Refiners are responsible for the accuracy of their disclosures and for ensuring alignment with LBMA Guidance and OECD requirements.

1 Footnote 59 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas states: Business confidentiality and other competitive or security concerns means, without prejudice to subsequent evolving interpretation: price information; supplier identities and relationships (however the identity of the refiner and the local exporter located in red flag locations should always be disclosed except in cases of disengagement); transportation routes; and the identity of information sources and whistle-blowers located in conflict-affected and high-risk areas, where revealing the identity of such sources would threaten their safety. All information will be disclosed to any institutionalised mechanism, regional or global, once in place with the mandate to collect and process information on minerals from conflict-affected and high-risk areas.

Scope

The Disclosure Framework (see figure 1) sets out the components that Refiners should implement to meet the RSP’s expectations for Step 5 annual reporting and ongoing disclosure.

Figure 1: Disclosure Framework

Compliance Report

The Compliance Report is the subject of the annual third-party assurance as stipulated in the Responsible Sourcing Guidance (the Guidance), which comprises the Responsible Gold Guidance (RGG) and the Responsible Silver Guidance (RSG). Section 2 of DG3 sets out the disclosure requirements to be included for Refiners to conform with the Guidance.

In addition, Section 2 outlines requirements of the ‘Refiner Transparency Roadmap’2 , as committed to by Refiners, to support broader stakeholder needs for increased transparency on gold supply chain risks. Required disclosures are to be reported as a public-facing Annex to the Compliance Report and include:

  • All World Gold Council (WGC) miners and mines from which Refiners receive gold-bearing material (WGC Mines).
  • All locations (countries) from which mined material is received (Mined Material Locations).
  • The identity of the Refiner and local exporter in ‘red flag’ locations as per OECD DGG Footnote 59 of the Gold Supplement (OECD FN59).

Country of Origin Report

The Country of Origin (COO) Report is also subject to the annual third-party assurance as stipulated in the Guidance documents. This document is, however, only sent to LBMA and is not required to be made publicly available. Section 3 provides an example of the template for Refiners to complete their COO disclosures.

Ongoing Disclosure

Refiners are expected to adopt disclosure practices that enable them to reflect the ongoing nature of due diligence, beyond annual reporting. This also includes responding to responsible sourcing-related allegations that may be connected to a Refiner. Section 4 outlines recommendations and principles for ongoing disclosure.

Proportional Application

Each Refiner must apply DG3 proportionally to its own business activities and to those directly involved in its precious metals supply chains. Proportionate application does not mean different standards for different institutions – it is a recognition of the differing levels of size, complexity, nature of engagement and sophistication of precious metals producers and refiners worldwide. DG3 is therefore fit to be flexible enough to adapt to the operational context and supply chain of the Refiner.

DG3 effective date

DG3 supplements LBMA’s Responsible Gold Guidance version 9 (RGG9) and Responsible Silver Guidance version 2 (RSG2). This reporting requirement is expected to be implemented for Compliance Reports due in the 2026 calendar year for FY2025 data and onwards.

Audience

The primary target audience of DG3 is the LBMA GDL Refiner, but it can also be considered as a reference point for other refiners seeking to be aligned with LBMA’s RSP. LBMA Approved Assurance Providers are also required to use DG3 to complete their assurance procedures on required minimum disclosures.

2‘Refiner Transparency Roadmap’ is a commitment initially set out to meet the OECD DDG Footnote 59 (FN59) requirement of disclosing “the identity of the refiner and local exporter in [OECD] red flag locations”. LBMA is committed to transparency beyond FN59.

Please refer to press release.