The OECD five steps, and what they look like on the ground

Buying gold in a conflict-affected or high-risk area is not prohibited. Buying it without knowing where it came from, who profited and whether anyone was harmed is what the international framework exists to prevent. Three documents define that framework.

The OECD guidance

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas is the foundation. Its gold supplement sets out five steps.

1. Build the management system. A policy, a responsible person, a record system and a way for people to raise concerns.
2. Identify and assess risk. Know the counterparty, know the mine, and check for the Annex II risks of armed groups, serious abuses, bribery, money laundering and misrepresented origin.
3. Respond to the risk. Continue, mitigate, suspend or disengage, and record the decision.
4. Have the due diligence audited by an independent third party at the refinery.
5. Report on it every year.

ICGLR certification

The International Conference on the Great Lakes Region runs a regional certification mechanism for tin, tantalum, tungsten and gold. In member states such as the DRC, Uganda, Kenya and South Sudan, an ICGLR certificate travels with the export and attests that the metal came from a validated site through a documented chain. A buyer in the region should expect to see it.

The LBMA's refinery rules

At the far end of the chain, LBMA-accredited refineries must follow the Responsible Gold Guidance, which applies the OECD steps at the refinery and requires annual independent assurance. Because that is where our metal ends up, the refinery's requirements flow backwards into ours. It will ask us for the same records we ask our suppliers for.

What this is in practice

A file. For every supplier it holds licences, identity and beneficial-ownership checks, sanctions screening, site information, an Annex II risk assessment and the decision taken. For every consignment it holds the purchase record, assay, permits and certificates. It is kept up to date, reviewed when things change and shown to auditors and refineries on request. A buyer who cannot produce that file will eventually find that no accredited refinery will take their metal.