LBMA’s approach to CSR Sakhila Mirza Executive Board Director and General Counsel

Worlds Authority for Precious Metals Corporate Social Responsibility Good Delivery List Responsible Sourcing Guidance Global Precious Metals Code LBMA Vision & Mission To add value to the global precious metals industry by setting standards, developing market services and thereby ensuring the highest levels of integrity, transparency and quality.

People Profit Planet Responsible Sourcing KYC and due Human rights diligence Human rights Anti-money laundering Combatting terrorist financing Corporate governance People Resource management For LBMA, our commitment to sustainability is shown through our Responsible Sourcing Programme. Representing the optimum between People, Planet and Profit, we have designed this Programme to encourage corporate social responsibility amongst LBMA industry members. Through the development of best practices and processes, LBMA promotes sustainability at each step of the precious metals supply chain. Everyone is responsible in working together to prevent human rights abuses. All we do is provide a minimum standard, which can be used to further develop on. Social responsibility is becoming a higher priority for industry members, at upstream and downstream levels. LBMA recognises this through our Programme and aims to support members in their endeavours to source precious metals responsibly. Three key pillars of the Responsible Sourcing Programme, which I will be discussing today, include the Good Delivery List, the Responsible Sourcing Guidance, and the Precious Metals Code. Integrity Environmental legislation Responsible Sourcing Supply chain commitment Use of permits Profit Planet Transparency Chemicals regulation

Responsible sourcing programme Minimum standards Key Features Risks should be identified and assessed throughout the supply chain, including human rights abuses and terrorism financing. Refiners should publicly report on their precious metals supply chain due diligence policies and practices. Refiners should have a follow a Corrective Action Plan where a non-compliance has been identified. LBMA can move a refiner to the Former List from the Good Delivery List if it no longer complies with the Programme. 5-Step Framework Establish strong company management systems; Identify and assess risk in the supply chain; Design and implement a management strategy to respond to identified risks; Arrange for an independent third-party audit of the supply chain due diligence; and Report on supply chain due diligence.

GLOBAL PRECIOUS METALS CODE Market Conduct and Best Practice Chapter Principles 1 Ethics High ethical and professional standards; manage conflicts of interest 2 Governance, Compliance, Risk Management: Appropriate oversight; compliance and risk management frameworks; escalation’ independent reviews/assessments 3 Information sharing Handling confidential information; provide for clear, accurate communication 4 Business conduct Pre-trade and execution; due diligence; handling orders fairly; guidance on Mark-ups; benchmark auctions 5 Post-trade (confirmation process, netting, settlement, shipping) Annex Illustrative examples: definitions, conventions Global Application Market Commitment to High Standards Mandatory for LBMA Members

WHEN SOMETHING GOES WRONG Engagement | Communication | Remediation Process in place: e.g. Things can go wrong, despite best efforts Work collectively to address the issues Reporting and remediation plan important Share lessons learnt UN Guiding Principles on Business and Human Rights OECD Due Diligence Guidance for Responsible Supply Chains 1. Receipt/Logging of Complaint/Issue 2. Media and Market Review 3. RGG Audit (or equivalent) Review 4. Auditor Review and Interaction 5. Legal Review 6. Refiner Contact 7. Physical Committee Reporting and Escalation and/or Legal Consultation 8. Action/Sanction 9. Public Disclosure 10. Lessons Learnt 11. LBMA Communication

SAKHILA.MIRZA@lbma.org.uk www.lbma.org.uk