Responsible Sourcing Programme Third Party Assurance Guidance
About
About LBMA: The Independent Authority for Precious Metals
LBMA is the pre-eminent standard-setting body for the global wholesale market for precious metals.
Our mission is to ensure the highest levels of leadership, integrity and transparency for the global precious metals industry by setting standards and developing market services.
LBMA plays a key role on behalf of the global precious metals market to ensure business integrity, by advancing standards, acting as a voice and champion for the market, and developing market solutions.
Commitment to Responsible Sourcing
LBMA’s Responsible Sourcing Programme (the Programme) protects the integrity of the global supply chain for the wholesale precious metals markets. It was set up to consolidate, strengthen and formalise the existing standards of the LBMA Good Delivery List (GDL) Gold and Silver Refiners’ (Refiners) due diligence practices. LBMA was actively involved in drafting the OECD Due Diligence Guidance1 and its Gold Supplement, and continues to support the OECD’s work in supply chain due diligence and related projects.
Vital to the credibility of the LBMA Programme is its broad scope, which includes measures to combat money laundering, terrorist financing and human rights abuses globally. In addition, the Programme has also been developed to recognise the increasing importance of strong Environmental, Social and Governance (ESG) responsibilities.
Responsible Sourcing Programme Overview
All LBMA GDL Refiners are required to implement LBMA’s Responsible Sourcing Guidance (the Guidance), which comprises the Responsible Gold Guidance (RGG) and Responsible Silver Guidance (RSG), and obtain annual independent assurance on their publicly available compliance reporting. Failure to appropriately adhere to the Guidance may result in a Refiner being removed from the GDL, following LBMA’s robust Incident Review Process (IRP).
Three levels of control
Refiner implements Guidance
Assurance Provider evaluates conformance
LBMA monitors Refiner and Assurance Provider performance
In addition to the Guidance, LBMA regularly produces supporting toolkits and training materials for both Refiners and approved Assurance Providers to enhance the quality and consistency of the Programme application. Refiners should use the Refiners Toolkit to implement the requirements of this Guidance. Refiners will be asked to justify any deviations from the scope of the Toolkit (on a comply or explain basis).
The Responsible Sourcing Programme
| Refiners | Assurance Providers | LBMA |
|---|---|---|
| Responsible Sourcing Guidance: | ||
| - Responsible Gold Guidance | ||
| - Responsible Silver Guidance | Third-Party Assurance Guidance | Country of Origin Data Analysis |
| Mandatory Assurance Training | LBMA Assurance Review Process | |
| Management Implementation Guidance: | Assurance Providers Application and Approved Assurance Provider List | LBMA Incident Review Process |
| - Refiners Toolkit | Compliance Panel and Physical Committee | |
| - Disclosure Guidance Document | LBMA Annual Responsible Sourcing Report |
The Guidance, together with the Responsible Sourcing Third-Party Assurance Guidance (the Assurance Guidance), should be applied in good faith by Refiners and Assurance Providers, and in the spirit of responsible engagement across the Refiners’ supply chains. The notion of meaningful, measurable improvement should also underpin the Refiners’ practices.
Continuous Development
The Guidance should be interpreted as a minimum threshold upon which Refiners should build and continually improve their responsible sourcing practices for each of the applicable precious metals. The concept of continuous improvement is an integral component of the LBMA Programme and underpins the spirit of LBMA’s five-step framework and responsible business practices.
About this Document
This document is intended for use by Assurance Providers who have been engaged to perform independent assurance of the Refiners’ Compliance Report in accordance with Step 4 of the Guidance. It sets out guidance for the application of the International Standard on Assurance Engagements 3000 (Revised)2 (ISAE 3000) in the context of the LBMA Programme.
GDL and Non-GDL Precious Metals Refineries may also access the Assurance Guidance and may choose to apply any or all aspects to their operations.
Enquiries and Version History
Enquiries may be emailed to: Responsible.Sourcing@lbma.org.uk
LBMA reserves the right to revise the document based on emerging good practice and implementation experience.
1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, April 2016
2 International Standard on Assurance Engagements 3000 (Revised), Assurance Engagements Other than Audits of Reviews of
Historical Financial Information, December 2013