Sustainability and Responsible Sourcing Report 2025
Chapter 5: Refiners' Performance and Programme Enforcement in 2024
In reviewing Refiners' annual assurance reports, the Responsible Sourcing Team pays close attention to not only the numbers of non-conformances (NCs) but also where they occur with respect to compliance with LBMA’s Responsible Sourcing Programme (RSP).
This gives us critical data points on where Refiners need additional support or guidance from LBMA, and helps us to identify additional requirements into future iterations of the Responsible Sourcing Guidance (RGG and RSG).This information also plays a critical role in the mandatory annual training we require of Approved Assurance Providers (AAP), providing case studies that illustrate common challenges identified through the assurance process.
While non-conformances serve a critical role in LBMA’s internal continuous improvement plans, they also provide constructive feedback to Refiners by identifying where and how they can make their due diligence programmes more robust.
TRENDS AND OBSERVATIONS
Comparative to FY2023, and consistent with the assurance reports LBMA reviewed up to the time of writing this report, there was an increase in overall numbers of NCs in FY2024, rising from 85 to 110.
We attribute this increase to the implementation of new requirements introduced in RSGv2. Generally, a new iteration of our Guidance documents results in a spike in NCs as Refiners introduce changes to their management systems. 2024 was the first year where these requirements were active.
This is evidenced by increases in NCs related to Refiners’ supply chain policies (Step 1.1), where APs specifically referenced how policies were not yet fully aligned with the new silver Guidance.
For gold-only Refiners there was a decline in aggregate numbers due to the increased focus LBMA placed on Refiner support and training, particular providing clarity on expectations such as the disclosure of suppliers in high-risk locations.
Risk identification (Step 2.1) significantly overtook risk classification (Step 2.2) as the step with NCs most frequently identified, compared to 2024. These findings identify gaps in Refiner’s due diligence, largely for individual suppliers. The type of incomplete evidence varies, but full details of ultimate beneficial owners (UBOs), shipment/transit documentation, licenses, and KYC questionnaires are commonly mentioned.
While the majority of the NCs were low risk, it is nonetheless crucial that Refiners check not only that due diligence is completed, but that it is completed to a high standard. The regular review of due diligence documents underscores that the KYC process isn’t a tick-box exercise, and that appropriate scrutiny and completeness is critical in supporting Refiners to assess the risks of a particular business relationship.
The numbers of medium NCs remained slightly elevated at 36, while high NC’s requiring immediate remediation within one month rose to 14 from six in the previous year.
ROOM FOR IMPROVEMENT
Traceability, counterparty engagement, and grievance mechanisms are areas where Refiners are performing strongly, but there are always opportunities to improve. Refiners are encouraged to continuously review these elements and implement changes to support their due diligence programmes, as well as those of their suppliers. The example of Tokuriki Honten highlighted below (see Refiner Performance: Disclosure Showcase) is a good best practice exampleof Refiners training their counterparties to better understand GDL reporting requirements.
Another positive development has been in the quality of reporting on non-conformances. AAPs are including more detail compared to previous years, providing Refiners with a clearer understanding of the gaps identified and corrective measures required to address them.
In a similar vein, LBMA noted a greater use of recommendations by AAPs. Implementing their constructive feedback serves two important functions. Firstly, it demonstrates a Refiner’s proactive commitment to continuous improvement.
Second, it offers Refiners an opportunity to address potentially problematic issues before they grow into non-conformances requiring more significant time and resources to ameliorate.
LOOKING AHEAD
While there was a significant drop in NCs related to risk classification, LBMA’s own observations are that Refiners need to broaden how they conceptualise risk. Rather than relying entirely on the sources listed in the Guidance, consideration should be given to the bigger picture that includes factoring the likelihood of potential risks that could impact the integrity of their supply chains.
Refiners’ public facing compliance reports also reflected more references to ESG factors which GDLs will need to appropriately consider given where investor and market demands are headed.
The year 2025 was the first for which Refiners were required to submit their assurance deliverables via the Gold Bar Integrity platform, including the use of a prescribed non-conformance template. This delivery system now automates the data for LBMA, providing clearer insights and less manual analysis.
NCs, unless zero tolerance, should not be considered failure – continuous improvement a key message of LBMA, and this is the opportunity for Refiners to identify how they can make their due diligence programmes more robust.
The following case studies go beyond compliance. They show innovation and leadership in how Refiners are staying ahead of OECD and EU requirements.
C Hafner
C Hafner’s report is a stand-out example of continuous improvement for disclosure. The German Refiner has reflected on the areas for improvement, general market demands, and best practice that were highlighted during our Refiner’s drop-in session in Summer 2024. The result is a well-structured report that addresses the requirements from across LBMA Guidance in a way which is accessible for all users. C Hafner’s report benefits from them explaining their due diligence programme as a process, including descriptions of their overall approach to risk and amendments made to suit their supply chain and applicable risks.
Rand Refinery
The South African Refiner demonstrates excellent disclosure throughout their Compliance Report but is especially noteworthy for the information on their sourcing, putting them ahead of the curve for transparency requirements LBMA is making mandatory from January 2026. Their description of risk identification, assessment, and mitigation processes remains of the highest quality, providing confidence in the assurance work done is the result of the disclosures made under Step 4. Clear descriptions of the assurance engagement itself provide insight not typically available to the public. This is supplemented by the history of non-conformances and recommendations for improvement, providing all users with a complete picture.
Zijin Mining Group Smelting Company
Like all China-based GDLs, Zijin Mining Group Gold Smelting Co., Ltd. (Zijin Gold Smelting) is required to conduct an annual “Special Assurance” statement demonstrating no forced labour in both its operations and supply chain, in addition to its regular assurance deliverables. In 2025, Zijin Gold Smelting supplemented the special statement by completing a workplace composition survey of its employees and issued a statement outlining the sampling size and transactions.
Tokuriki Honten
The Japanese Refiner operates a conflict minerals information system which tracks all information related to their suppliers, including which metals can be purchased from them and their most current risk assessment status. No purchasing slip can be issued for a supplier before their risk assessment has been completed.
In 2024, Tokuriki Honten required all suppliers to submit a “Certificate of Non-Use of Conflict Minerals”, as evidence that they align with Tokuriki’s Supply Chain Policy. The refiner also held a training session for 14 suppliers to explain their conflict minerals management efforts and the importance of doing due diligence on their respective supply chains.
Argor Heraeus
The Swiss Refiner offers a comprehensive overview of the company’s management system. This section is particularly detailed, describing the specific accountabilities within the processes. What sets this section apart is the inclusion of a diagram and visual aids showing the company’s structure.
This visual representation clarifies the chain of command and enhances the reader’s understanding of accountability within the organisation. Such detailed disclosure helps stakeholders understand the company’s governance structure and due diligence processes.
INCIDENT REVIEW PROCESS AND REMOVAL FROM LIST OF APPROVED SERVICE PROVIDERS
Over the last year, LBMA engaged one Refiner and two Approved Assurance Providers to address either potentially serious sourcing issues or a failure to meet the standards set out in the Responsible Gold/Silver Guidance and the LBMA Rules for Members.
LBMA’s Incident Review Process and constant reviewing exemplifies our commitment to transparency and accountability. We voluntarily disclose outcomes and processes, reinforcing industry trust and demonstrating our proactive approach to maintaining the highest standards.
Umicore SA Business Unit Precious Metals Refining (Umicore)
The Incident Review Process was invoked against Belgium-based Umicore in April 2025 to review matters that were raised during
Umicore’s assurance process. This process involves consultation with a range of stakeholders, alongside a second assurance process that includes a peer review of events.
The IRP is ongoing at the time of writing and LBMA will provide further updates once the review process has concluded. The Refiner remains on the Good Delivery List and is cooperating fully with LBMA.
PwC Belgium
The assurance firm was removed from the AAP List in June 2025. This action has been taken while clarification of ongoing matters related to Umicore’s assurance remain underway.
Arkan and Ergin (Turkey)
The assurance firm was removed from the AAP List in February 2025. This action was taken as they no longer satisfy LBMA’s Service Provider requirements.
Bureau Veritas China
The Approved Assurance Provider was removed from the AAP List in October 2025. This action was taken as they no longer satisfy LBMA’s Service Provider requirements.
Istanbul Gold Refinery (IGR)
The Incident Review Process was invoked against IGR in October 2025 to review matters raised in connection with Istanbul Gold Refinery (IGR) regarding recent reports concerning an investigation by Turkish authorities. This process involves consultation with a range of stakeholders.
The IRP is ongoing at the time of writing and LBMA will provide further updates once the review process has concluded. The Refiner remains on the Good Delivery List and is cooperating fully with LBMA.