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

2. 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.

3. 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

4. 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.

5. 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

6. 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