It is vital that Good Delivery List (GDL) refiners develop and publicise a mechanism allowing any employee or external stakeholder to anonymously voice concerns about the precious metals supply chain. LBMA encourages stakeholders, including GDL refiners and their employees, third-party service providers, members of civil society, affected communities and other interested parties (GDL stakeholders), to anonymously report information against an organisation in the GDL supply chain.

Whistleblowing Procedure

LBMA’s Whistleblowing Policy enables GDL stakeholders to report illegal activities, wrongdoing or malpractice occurring throughout the GDL supply chain.

However, where GDL stakeholders are directly affected by the matter in question, or where GDL stakeholders feel victimised for escalating the concern, the matter may be raised to LBMA confidentially under the whistleblowing process, anonymously.

Stakeholders also have the option of filing a case with the Mineral Grievance Process (MGP), an online cross-industry platform to screen and address grievances linked to smelters and refiners present in global supply chains. The MGP is a collaboration between LBMA, the Responsible Minerals Initiative (RMI) and the Responsible Jewelry Council (RJC).

The purpose of the platform is to create a connected and efficient grievance review system that benefits a wide range of stakeholders and builds on existing relationships and mechanisms. The platform aggregates grievances associated with in-scope supply chains, provides a forum for supply chain actors to address these grievances, and provides a log of grievances that have been received and addressed for transparency and stakeholder communication. For more information, or to submit a grievance, please visit the Mineral Grievance Platform.

Incident Review Process

The Incident Review Process (IRP) is invoked in response to serious and credible incidents of a reputational nature. Information can come from a variety of sources, including but not limited to trade associations, law enforcement or media agencies, non-governmental organisations and market intelligence.

An IRP comprises 11 steps for LBMA to take in response to any incidents