LBMA Annual Report 2024
Sustainability and Responsible Sourcing
A cornerstone of LBMA is its Responsible Sourcing Programme. It underpins the drive for continuous improvement and responsible business standards designed to protect the value of the gold we all treasure.
LBMA is taking a leading role by creating a coalition of willing partners across the global precious metals industry, with the ultimate mission of positioning precious metals as part of the solution to the sustainability challenges we face.
Responsible Sourcing on the Agenda
Over the last year, LBMA’s Responsible Sourcing agenda has focused on four areas:
1. ARTISANAL SMALL-SCALE MINED (ASM) GOLD AND RECYCLED GOLD
Invest resources to address the governance challenges and market exclusion associated with ASM gold, while also responding to concerns that current definitions of recycled gold support unsubstantiated product claims.
2. PROGRAMME REVIEW AND OVERSIGHT
Reinforce the integrity and credibility of LBMA’s Assurance Programme. This consists of the development of a suite of guidance documents that support Assurance Providers before, during and after their annual engagements with GDL Refiners.
3. CIVIL SOCIETY ENGAGEMENT
Strengthen engagement with civil society partners. The exchanges of views is critical to fostering mutual trust and understanding of each other’s perspectives and play an integral role in informing improvements to the Responsible Sourcing Programme (RSP).
4. VALUE CHAIN ENGAGEMENT
Increase communication with the full spectrum of LBMA stakeholders. LBMA launched the inaugural edition of the Sourcing Advisory to raise awareness of GDL Refiners and Assurance Providers (APs) to ad hoc sourcing threats and vulnerabilities brought to our attention. The Responsible Sourcing team also increased its dialogue with both entities, proactively providing constructive feedback on the quality and LBMA expectations of assurance reports received during in 2024.
Strategy
Our three-year Sustainability and Responsible Sourcing Strategy (2024-2026) seeks to adapt and define best practice by identifying what needs to change, determining how to effect that change and then guiding change in line with our overarching approach of ‘continuous improvement’.
Our key deliverables that we are committed to in year one are below:
Leadership: Meaningful Collaboration and Engagement
Key deliverable: Undertake a stakeholder mapping exercise to support with the key deliverables.
Integrity: Strengthening Oversight and Standards
Key deliverable: Strategy for Assurance Provider training.
Transparency: Promoting and Enhancing Publication of Data
Key deliverable: Annual Publication of aggregate on gold and silver origin by country.
LBMA can never be complacent to an evolving landscape and new threats; we must maintain our vigilance and continually strive toward better.
LBMA’s core values of leadership, integrity and transparency guide all focus areas of the Strategy. Rather than approaching one focus area at a time, we consider how these core values will both inform and propel action as we build on them each year.
Responsible Gold Guidance
LBMA has always sought to ensure that the Responsible Gold Guidance (RGG) – the 10th iteration of which will be launched in 2025 – remains at the forefront of all emerging challenges and debates related to the governance of the precious metals market.
LBMA can never be complacent to an evolving landscape and new threats; we must maintain our vigilance and continually strive to accomplish more in our efforts to do so. We often recall two foundational principles upon which both the RGG and OECD Guidance are premised: continuous improvement and progressive improvement. The former speaks to the need for industry schemes to never rest on their laurels. And so, with the conclusion of each new iteration of the RGG, we begin the process of identifying further areas of improvement. This commitment to continuous improvement is what keeps the Responsible Sourcing Programme fit for purpose.
ASM Initiative: A Pathway for Legal ASM
LBMA’s ASM Initiative is first and foremost an effort to address the governance challenges to the global legal gold sector posed by the unsupervised, marginalised and criminalised environment within which the industry actors in the ASM sector are unfortunately often forced to operate.
While there is much more to be done, we are confident that the first concrete steps have been taken to promote engagement by GDL Refiners and reverse the avoidance that has hobbled the full economic potential the sector represents for millions of miners and producer countries around the globe.
Intermediate Refiners
LBMA also engaged with several intermediate refiners and aggregators in Ghana, Peru and Tanzania, encouraging them to undergo an assessment process led by the Responsible Mineral Initiative (RMI). Securing RMI’s conformance builds the credibility of prospective intermediate refiners, while providing GDL Refiners with additional comfort that they are dealing with an established and credible supplier.
Country of Origin Data
LBMA’s Country of Origin (CoO) data sheds light on the global movement of gold and silver, offering insights into where and how these materials are sourced and processed. By detailing the geographical origins of gold and silver, the CoO data helps maintain the integrity of the supply chain and provides valuable insights into global trade patterns and sourcing practices among leading Refiners.
CoO data helps maintain the integrity of the supply chain and provides valuable insights into global trade patterns and sourcing practices among leading Refiners.
Recycled Material
This is the second year that data has been submitted against the five recycled categories and so, this year, we have been able to do a direct comparison year-on-year with more granular data on recycled materials. This provides a clearer and more detailed picture of the types of recycled material that GDL Refiners are sourcing.
Previously, recycled materials were grouped under a single category. Disaggregating the data into five categories better captures the nuances within the sector: Unprocessed Recyclable Metals; Melted Recyclable Material; Industrial By-products; Mixed Materials; and Grandfathered Stocks.
Toward Greater Transparency and Disclosure by Refiners
Refiners continue to improve their systems and controls - with a lower number of non-conformances reported. One of the most significant developments in 2024 was the mandatory disclosure by Refiners of their high-risk suppliers, including their identity and location.
This disclosure is an important step towards meeting elements of Footnote 59 in the OECD Due Diligence Guidance and responds to calls for greater transparency by civil society groups. The Footnote speaks of disclosing such information - subject to certain commercial sensitivities - to an “institutionalised mechanism” that is either regional or global in scope.
While LBMA remains committed to greater transparency and disclosure of information, in discussions with various stakeholders (including the OECD and civil society groups), greater clarity is needed as to what constitutes a universally accepted “institutionalised mechanism”. In an effort to advance discussion and forge consensus on this matter, the OECD - at LBMA’s behest - moderated the first discussion with affected industry audit schemes and civil society organisations in November.
Sakhila Mirza - Deputy CEO & General Counsel, LBMA
Sakhila is our lead on sustainability, most notably the Responsible Sourcing and ESG agenda. In addition, Sakhila works on LBMA’s market development projects, as well as government affairs.
Alan Martin - Head of Responsible Sourcing, LBMA
Alan manages LBMA’s Responsible Sourcing Programme for precious metals, which is mandatory for all Good Delivery List Refiners. Formerly director of research at IMPACT, Alan has an intimate understanding of the vulnerabilities and challenges of sourcing responsibly across the supply chain, which is crucial to the success of our Programme.