Sustainability and Responsible Sourcing Report 2024
Evolving Regulatory Landscapes
by Emmy Richardson, Senior Compliance Associate
Intensifying our Support to Members and Refiners
In response to the evolving regulatory landscape concerning supply chain due diligence and sustainability, LBMA is intensifying its support for Members and Refiners.
Although the gold supply chain has had a head start with the implementation of the EU Conflict Minerals Regulation and LBMA’s own Responsible Sourcing Programme, the broader sustainability agenda remains a pressing concern.
The Global Push for Sustainability
The global stage is abuzz with sustainability initiatives.
Europe is accelerating its regulatory efforts, with the EU introducing ambitious proposals such as the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD).
These directives mandate large companies to integrate comprehensive due diligence measures throughout their global value chains and ensure transparent reporting of sustainability data,
respectively.
In April 2024, the European Parliament approved a regulation targeting forced labour within the EU market. This regulation, effective from mid-2027, requires comprehensive human rights due diligence across all stages of all product supply chains, applying universally to products regardless of origin or sector. This regulatory push is complemented by global efforts, such
as Canada’s modern slavery legislation and China’s development of Corporate Sustainability Disclosure Standards (CSDS).
Additionally, the UK House of Lords is currently progressing a bill that mandates commercial organisations and public authorities to prevent human rights and environmental harms.
The bill includes obligations to conduct and publish human rights and environmental due diligence assessments on their own operations, subsidiaries, and value chains. The bill would introduce provisions for civil liability, penalties, and criminal offences for non-compliance.
Strategic Outreach by the Compliance Team
Our Responsible Sourcing Programme has been instrumental in promoting ethical business practices and supply chain transparency.
LBMA has proactively aligned with these global standards to ensure that our Members and Refiners are well equipped to navigate these regulatory changes.
But in response to feedback and the evolving regulatory landscape, this year, the LBMA Compliance team has implemented a comprehensive outreach strategy aimed at:
- Enhancing Regulatory and Compliance Awareness
We aim to provide valuable regulatory updates and training. - Inclusivity
We strive to ensure accessibility for all Members and Refiners, and create forums for Compliance Officers to collectively discuss and explore current compliance challenges. - Insightful Engagement
We engage one-on-one with Members and Refiners to understand their unique needs better, allowing us to enhance our support effectively.
This strategic approach has been fruitful so far.
Our next step is to bring Members and Refiners together at a virtual roundtable event in October to discuss and strategise on common issues faced by Compliance Officers and professionals
in this space.
Developing Targeted Training Programmes
To further support our Members and Refiners, the Compliance team has been developing specialised training programmes.
- Compliance Officer Training:
Targeted at nonregulated organisations within the precious metals supply chain, this training will be launched at the end of the year to enhance compliance capabilities across the sector. - Gold-Specific Anti-Money Laundering (AML) Training
Set to launch in October, this training will be mandatory for LBMA Approved Assurance Providers during their annual review. However, it will also be open to all interested parties, promoting widespread adherence to AML standards within the gold industry.
Future Steps
Looking ahead, we remain committed to supporting our Members and Refiners through continuous engagement and the provision of resources necessary to comply with evolving regulations.
Our virtual roundtable event in October will be a pivotal platform for discussing strategies to tackle common compliance challenges. As regulatory frameworks continue to evolve, LBMA is dedicated to helping Members and Refiners integrate sustainability into their core strategies.
By embracing these challenges, businesses can ensure compliance and position themselves as leaders in promoting positive societal and environmental change. Our collective action, innovation and adherence to global sustainability standards will pave the way for a sustainable future in the precious metals supply chain.