Responsible sourcing
Acceptance decisions must be based on the source of material, the counterparty and the risks in the transaction.
01
Five-step structure
1. Establish management systems. 2. Identify and assess supply-chain risk. 3. Respond to identified risk. 4. Obtain independent third-party audit. 5. Report on due diligence. The Gold Supplement informs the application to gold.
02
Acceptance and red flags
Before material acceptance, identify the counterparty and beneficial owners, document origin and transit, and review sanctions exposure and transaction consistency. Escalate opaque ownership, unverifiable origin, inconsistent documents, unexplained intermediaries, conflict links or indications of serious abuse.
Do not accept material while a material risk remains unresolved. A designated compliance owner must record the assessment and proposed decision; senior management must approve any permitted risk-management plan. Refuse or suspend transactions where the risk cannot be acceptably addressed.
03
Counterparty questionnaire
Required fields: legal identity and registration; ownership and authorised signatories; source and type of gold; origin and transit countries; supplier chain; licences where applicable; assay and shipment records; payment route; sanctions and adverse-information findings; responsible-sourcing controls. Supporting documents must accompany the answers.
Download a blank questionnaire; do not submit sensitive documents through this website.
04
Escalation and reporting
Record the concern, relevant lot, evidence and decision owner. Restrict access to sensitive information. Route the case to compliance and then senior management; preserve the decision trail. A named officer and secure reporting channel must be appointed before this policy becomes operational.
Audit and public reporting follow implementation; they cannot be replaced by publishing this policy. No CSR projects, beneficiaries or community-impact results are claimed.