Refiner Compliance Report

The Refiner should:

• Outline the scope of the reporting with respect to the group/company structure including relevant facilities and business units.*
• Confirm that a Responsible Sourcing Policy has been documented and that the Policy includes:
  • All threat financing risks, including OECD Annex II risks, per Step 1.1 of the Responsible Gold/Silver Guidance.
  • Environmental, social and governance (ESG) factors considered in its gold primary supply chains, per Step 1.1 of the Responsible Gold Guidance.
• Make clear that the supply chain policy is:
  • Approved at a senior level.
  • Reviewed annually and updated as and when circumstances require.
  • Publicly available on the website, in English (link to policy), and communicated to all relevant staff.

The Refiner should provide:

• A description of the organisational structure and clarify that:
  • Authority and accountability for supply chain due diligence are assigned to the Board, or a committee appointed by the Board.
  • The Board has sufficient skills and experience, and training is provided for the Board to carry out its oversight of responsible sourcing activities effectively.
  • A suitably experienced Compliance Officer has been appointed to take responsibility for the implementation of the supply chain due diligence processes.
  • There is sufficient availability of the necessary resources and skills to support and monitor due diligence processes.

The Refiner should report on the:

• Percentage and/or number of relevant employees trained on supply chain due diligence matters during the reporting period.
• Related training topics, contextualised and proportionate to the company due diligence structure and supply chain.
• Where relevant, the number of material violations of the internal due diligence process that have been escalated and whether internal sanctions (e.g. warnings, penalties, etc.) have been taken, or could be taken, with regards to (failures in) due diligence implementation.

Refiners should also include a description of their cash payment policy and record-keeping policies with reasoned justifications for deviations from the requirements of Step 1.2 of the RGG.

The Refiner should describe:

• The methods for identifying all counterparties down to the precious metal’s origin, as defined in the RGG for various sources of precious metals.
• The traceability system used, including the information recorded (such as counterparties, origin, type of materials, date of arrival and finalisation, weight, etc.) and documents collected and stored (such as airwaybills, packing list, pro forma invoices, export forms).
• Any instances of incidents relating to counterparties’ identification, origin and traceability of precious metals, and the measures or procedures followed by the Compliance Officer to address these.

The Refiner should describe:

• How it shares information and expectations about due diligence with counterparties (e.g. contractual clauses, training on specific due diligence issues, company internet campaign).
• The types of expectations communicated to counterparties.
• The due diligence issues on which suppliers/counterparties were specifically engaged during reporting period, if any.
• The Refiner should also, if and where relevant, convey its support to the implementation of the EITI Principles (as provided for under Step 1, subsection 4 of the RGG) and indicate whether the Refiner buys Mined Gold from a State-Owned Enterprise operating in an EITI country.**
• The Refiner is encouraged to disclose all first trades payments made to State-Owned Enterprises for the purchase of mineral resources during the reporting period. (Note: This is a recent EITI requirement for buyers, see key insight 5).

The Refiner should describe:

• The grievance mechanism in place, including:
  • Whether it is accessible to internal and external parties.
  • How it can be accessed (e.g. via email, mailbox, hotline).
  • Whether it can be used anonymously by employees or external parties.
  • How grievances are managed and resolutions are communicated to stakeholders.

The Refiner should disclose:

• The number and nature of relevant grievances that were received through the relevant platforms or the Refiner’s own grievances channel and that were closed during the reporting period.
• The steps taken to resolve grievances and refer, where relevant and appropriate, to the nature of corrective and preventative actions taken in response to grievances. For instance, Refiners can report that external investigations, assessments, inquiries with suppliers, checks about internal procedures, etc. are ongoing, with due respect for confidentiality.
• The plan and expectations for closing out remaining grievances.

The Refiner should describe:

• The systems and controls in place to identify risks related to the supply chain, including:
  • The procedures and tools for undertaking Know Your Counterparty (KYC) assessments.
  • The resources, skills and experience of the team conducting the risk assessments and continuous monitoring, and how applicable systems and personnel communicate their assessments and checks to inform others.
  • The review and sign-off procedures for the risk assessments.

The Refiner should describe:

• The processes in place and the definitions/criteria (e.g. context, Politically Exposed Persons, beneficialowners, sanctions) used to determine when precious metals or counterparties are from a CAHRA or are considered high-risk (including the ESG criteria used for the gold primary supply chain).

The Refiner should disclose:

• The number and/or percentage of zero-tolerance and high-risk suppliers identified.
• The nature of the zero tolerance and high risks.
• The steps taken to mitigate these risks, including any communication with the regulators or LBMA, and the Enhanced Due Diligence procedures followed. It is understood that these cases may be sensitive and confidential. Disclosures are not expected to breach any legal requirements.

The Refiner should describe:

• The EDD procedure and tools used for the different types of precious metals-bearing material.
• The on-site visits procedures undertaken, including:
  • An understanding of the resources, skills and experience of those undertaking the on-site visits (e.g. external specialist agencies, joint assessment teams, in-house personnel).
  • The timing and frequency of the on-site visits.
  • The procedures implemented in instances where it is not possible to conduct mandatory on-site visits.

• The EDD procedures implemented for high-risk Recycled Gold from intermediate refiners with high-risk supply chains.

The Refiner should disclose:

• The number of all on-site visits to (high-risk) counterparties/areas for risk assessment purposes and the percentage that were conducted by external assessors, while keeping due regard to business confidentiality and other competitive concerns.
• The nature of the specific underlying issues, if any, that led to on-site visits being carried out and the nature of high risks identified during on-site visits – split by topic such as conflict, environment, social, governance, etc.
• The number of intermediate refineries with high-risk supply chains that supplied independent assurance reports and the plan for obtaining the remainder.
• The frequency for conducting risk assessments.

The Refiner should describe:

• The company’s risk management strategy according to the risk’s nature, including the reasons to continue, suspend and/or disengage with a counterparty.
• The company’s internal risk classification.

The Refiner should disclose:

• The number of counterparties, and the context and nature of related risks for which mitigation measures have been applied.
• The efforts made by the company to monitor and track performance for risk mitigation.
• The steps taken to strengthen chain of custody or traceability systems for supply chains under risk mitigation instances and the results of the follow-up of improvement plans after six months to evaluate significant and measurable improvement.
• The number of instances where the company has decided to disengage with counterparties, without disclosing the identity of those suppliers, except where the company deems it acceptable to do so in accordance with applicable laws.***
• The cases of cooperation with national or local government authorities (having regard for confidentiality and the potential harmful effects for stakeholders, and in accordance with applicable laws).
• The reporting mechanism to the Board of Directors/Board Committee on high-risk supply chains, counterparty under risk mitigation strategies and status of risk mitigation strategies, and the progress and effectiveness of improvement plans.

The Refiner should describe:

• The Assurance Provider selection process.
• How the Board has fulfilled its responsibility to ensure Assurance Provider independence.

The Refiner should disclose:

• High/medium-risk non-conformances identified during the current audit cycle and how these have been/are planned to be resolved (regardless of whether these have been closed by the time of Compliance Report publication).
• Progress on high/medium-risk non-conformances identified in the previous audit cycle that remain to be mitigated.
• Reasons for overall compliance with the Guidance when high/medium-risk non-compliances have been raised.
• Where the assurance report will be available to the public.

This section is only applicable to Refiners on the Good Delivery List – Gold, applying RGG9. These disclosures are not subject to independent assurance in the first year of reporting, i.e. for 2025 data. Refiners are nevertheless expected to comply as fully as practically possible, or explain deviations from requirements, in the FY2025 Compliance Reports to prepare for full external assurance from FY2026.

The Refiner should disclose:

1. World Gold Council (WGC) Mines: the following details for all WGC member mines from which
   gold-bearing material is received (regardless of risk classification):
   1. Name of mine.
   2. Location of mine (city or state, and country).
   3. Name of mining company.
2. Mined Material Locations: names of countries from which other mined material is received, where:
   1. Mined material includes all categories of gold-bearing mined material.
3. OECD FN59: the identity of the refiner and local exporter in OECD red flag locations, where:
   1. Scope includes gold-bearing material that:
      1. originates from or has been transported through a red flag location defined below.
      2. is claimed to originate from recyclable/scrap or mixed sources refined in or known or reasonably suspected to transit through a red flag location defined below.
   2. Recyclable/scrap or mixed sources means unprocessed, melted, Industrial By-products and Mixed Materials per OECD DGG (i.e. it includes investment gold).
   3. Refiner means intermediate refiner per RGG9.
   4. Local exporter includes producer, aggregator, international trader transporter or any other entity involved in the commercial export of the material.
   5. Determination of OECD red flag locations must be made using the following sources for consistent reporting:
      1. U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1502 Covered Countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.
      2. European Union Regulation (EU) 2017/821 Conflict Affected and High Risk Areas List (EU CAHRAs List).
      3. Current Financial Action Task Force (FATF) grey list and FATF grey list for preceding three years (FATF+3).****

Refiners should take note that the sources listed above for the determination of OECD red flag locations for due diligence purposes are non-exhaustive lists. Further, RGG9 still requires high risk determination and due diligence through the integrated location, supplier and type of material assessment, and that the output of this integrated risk assessment framework is expected to be broader than the public disclosures required under the Refiners Transparency Roadmap. Refiners should continue to conduct risk assessments and due diligence based on the RGG9 integrated risk assessment and continue to report to LBMA the official names and locations, and confirmation of enhanced due diligence, of all RGG9 high-risk suppliers through the Gold High-Risk Suppliers Form. This Gold High-Risk Suppliers Form is subject to the independent assurance engagement.

Exemption

LBMA recognises multi-metal procurement can differ from that of single-metal gold and that this can create distinct commercial sensitivities for multi-metal Refiners. To address this, LBMA has introduced a limited exemption for the above requirements to balance operational factors relevant to particular Refiners with LBMA’s transparency objectives.

What may be exempted

The identity of the Refiner and local exporter in OECD red flag locations for sourcing of:

• Industrial By-products, typically multi-metallic materials consisting of gold together with base metals, or gold together with other precious metals and other elements and impurities.
• Low-grade unprocessed recyclables or low-grade melted recyclables, typically with a gold content of 2% or below and where gold is not the main or only recoverable metal.

A non-exhaustive list of such material is included in the application form. LBMA will consider any other materials through the formal application process.

For Mining By-products, per the definition of origin of mining by-product in the OECD DD Guidance and RGGv9, the location to determine red flag risks will be at the point of separation of the precious metal. Mining By-products with a gold content of 2% or below may also lead to an exemption of disclosing requirements.

How to apply for the exemption

In order to be considered for this exemption, Refiners must make an application to LBMA’s Good Delivery Department at least 3 months in advance of the Compliance Report submission deadline, or as soon as practically feasible. An exemption application must be submitted for all material types, including for the material types already stated in the application form. LBMA’s Responsible Sourcing Compliance Panel will determine whether the exemption is valid.

What happens when an exemption is agreed

Where the Good Delivery Team approves an exemption request, the Refiner will be required to publicly disclose in the Refiner’s Compliance Report:

• The number of refiners and local exporters in red flag locations by continent.
• Statements that the information on the identities and high-risk location of suppliers of the exempted material:
  • has been disclosed privately to LBMA.
  • may be shared with interested parties on a bilaterial basis, subject to the interested party meeting the eligibility criteria specified in the application form.
  • has been subject to the risk-based third-party assurance, as has the exemption.