Responsible sourcing
Paperwork is what makes the metal saleable.
African gold can be priced against the world benchmark only if a refinery will take it, and a refinery will take it only if its origin can be shown. The due diligence is the business.
- Framework
- OECD Due Diligence Guidance, gold supplement
- Region
- ICGLR Regional Certification Mechanism
- Refinery
- LBMA Responsible Gold Guidance
- Screening
- UK, EU, US and UN sanctions lists
01Policy
What we commit to.
We buy gold and precious metals only from licensed producers, registered cooperatives, licensed dealers and accredited refiners. We follow the OECD Due Diligence Guidance and its gold supplement, the ICGLR regional mechanism where it applies, and the LBMA Responsible Gold Guidance at the refinery end of every chain.
We apply enhanced due diligence in every market designated conflict-affected or high-risk, and we suspend activity where legal or security conditions do not let us meet this standard.
How the framework fits together02The framework
The OECD five steps, as we run them.
- 01
Management systems
A board-approved policy, a compliance function that reports separately from trading, a record for every supplier and a way to raise a concern.
- 02
Risk identification
Counterparty and beneficial-ownership checks, sanctions and adverse-media screening, site identification and an Annex II assessment.
- 03
Risk response
Continue, mitigate, suspend or disengage, written down and reported upward. Where an Annex II risk is present we disengage.
- 04
Independent audit
Our records go to the LBMA-accredited refineries we ship to, whose annual assurance covers the metal we supply.
- 05
Reporting
An annual statement of our sourcing due diligence, available to counterparties, banks and regulators on request.
03Red lines
What we will not buy.
The OECD Annex II risks. Where any one is present, we disengage.
- 01
Metal from sites where armed groups or unlawful security forces are present or benefit
- 02
Metal produced with child labour, forced labour or serious abuses
- 03
Counterparties on UK, EU, US or UN sanctions lists, or owned by sanctioned persons
- 04
Misrepresented origin, or metal without a documented chain of custody
- 05
Bribery of officials, or evasion of royalties and taxes owed to the producing state
- 06
Money laundering or the financing of terrorism
04On the ground
Three things we insist on.
Ground
Partner sites move off mercury, manage water and tailings and rehabilitate worked ground. Conditions of our money, not aspirations.
People
Workers registered, basic safety in place, a way to raise a grievance. No metal from sites using child or forced labour.
Revenue
Royalties and taxes paid to the producing state on every lot, receipts kept in the file. Lawful export is the only export.
05Questions
Sourcing, asked.
compliance@miningaccord.com
01Do you buy in conflict-affected areas?
Yes, where we can do so within the OECD framework. Walking away from those areas altogether would hurt the legitimate producers who depend on responsible buyers. Buying there with enhanced due diligence is what the guidance recommends and what we do.
02How can a refinery or bank check your due diligence?
Ask for the file. For any consignment we provide the supplier's licences, KYC and ownership records, screening results, site information, the risk assessment and our decision, along with the assay, permits and certificates for the lot.
03How do I raise a concern?
Write to compliance@miningaccord.com. Concerns can be raised anonymously and are handled by compliance, which reports separately from the desk.
Get in touch
desk@miningaccord.com
08.30 to 18.00 GMT
Need the file?
Refineries, banks and regulators can request supplier and consignment records from compliance.