2019 was the first year for all Good Delivery List (GDL) refiners to implement the changes that were introduced in version 8 of the Responsible Gold Guidance (RGG).

To summarise, version 8 of the RGG expanded the definition of due diligence by requiring refiners to not only assess risks identified in the OECD Due Diligence Annex II, regarding money laundering, but also to include an assessment of the Environment, Social and Governance (ESG) responsibilities.

Under step one, of the RGG, the refiner’s due diligence for its supply chain must include a policy that extends to ESG requirements. Under this step, refiners are asked to strengthen ESG engagement with gold-supplying counterparties and, where possible, assist gold-supply counterparties build due diligence capacities. This would also capture the use of mercury in Artisanal and Small-Scale Mining (ASM), with the expectation that GDL refiners assist in establishing processes to eliminate its use.

Under step two, refiners must assess the risk in the supply chain, which includes assessing the environmental policies and practices of the producers, both in relation to Artisanal and Small-Scale Mining (ASM) and Large-Scale Mining (LSM). The guidance also gives more detail on this assessment, depending on the nature of the material being sourced (ASM/LSM).

Under step three, once the risks have been identified, the refiner is required to make sure it has a management strategy to respond to identified ESG risks. GDL refiners are also required to provide evidence of their sustainability policy and its effect on any associated initiatives throughout their supply chain.

Audit reports reflecting implementation of these changes will be submitted in 2020 and discussed in more detail in the next Annual Report.


In 2019, no GDL refiner was moved to the Former List for failure to comply with the Responsible Sourcing Programme.

Whilst there were several escalations during the year, each one was addressed appropriately, with full co-operation from the GDL refiner in question. As highlighted earlier, LBMA relies on two important processes to help identify Responsible Sourcing issues. Firstly, the annual reports, and the information provided in these reports, will flag non-conformances. Also, market intelligence, media reports and credible NGO reports may provide information that will then instigate an Incident Review Process (IRP).

Gold – non-conformances
2019 saw an overall increase in medium-risk and highrisk non-conformances for responsible gold audits. The two high-risk non-conformances for gold related to one GDL refinery based in the Europe & Africa Country of Origin category (see case study one). All medium-risk non-conformances for gold related to two different GDL refineries based in the Americas and were escalated to the Compliance Panel. LBMA engaged with the auditors and both GDL refiners throughout the development of Corrective Action Plans to ensure appropriate timescales were agreed before issuing 2018 RGG certificates. No zero-tolerances were reported in 2019.

Silver – non-conformances
As 2018 was the implementation year for silver GDL refiners, the 2019 reports highlighted a high number of non-conformances for silver. This was expected, as several silver-only GDL refiners were implementing new controls and going through the audit for the first time. We expect to see these numbers trend down as silver GDL refiners fully embed systems in their operations and work towards continuous improvement. However, no zero-tolerance non-conformances were identified, which confirms the commitment that each GDL refiner has in trying to achieve full compliance with the international standards. As is expected for gold, all silver high-risk non-conformances were addressed within 90 days.


Below is a breakdown of the most common types of non-conformances raised against the five steps of the RGG and RSG.