Preparation for an audit under the Responsible Gold Guidance (RGG) of the London Bullion Market Association (LBMA) involves a structured process to ensure compliance with rigorous RGG requirements regarding due diligence in the gold supply chain. Ecosysmis supports you by:
Understanding RGG requirements
Study the RGG framework: Review the five due diligence steps of the RGG based on the OECD Guidelines.
dentify specific obligations: Analyze the requirements related to traceability, respect for human rights, anti-money laundering, and counter-terrorism financing.
Stay informed about updates: Regularly check for revisions to the RGG and its associated guidelines.
- Evaluate and Formalize Internal Processes
- Collect and Organise Evidence
- Stakeholder Training
Implement a Responsible Sourcing Policy: Develop a written policy aligned with the RGG and communicate it to all stakeholders.
Map the Supply Chain: Identify all entities involved in the gold supply chain, from extraction to delivery.
Conduct Risk Analysis: Perform a risk assessment based on RGG criteria (geographic origin, supplier practices, etc.).
Formalize Processes: Document internal practices and procedures to ensure traceability and compliance.
Supply Chain Data: Collect documentation proving the origin of the gold, traceability, financial flows, and controls performed.
Contracts and Agreements: Ensure that supplier contracts include compliance clauses aligned with the RGG.
Audit Reports: Prepare internal and external reports demonstrating process compliance.
Training Records: Provide evidence of training sessions delivered to employees and suppliers regarding the RGG.
Prepare Internal and External Reports: Compile documentation that demonstrates process compliance with the RGG.
Training Records: Provide evidence of training sessions delivered to employees and suppliers regarding the RGG.
Stakeholder Awareness and Training
Internal team training
Raise employees’ awareness of RGG requirements, particularly those in procurement, compliance, and legal departments.
Supplier engagement
Explain to suppliers the specific expectations related to the RGG and support them in their preparation.
Collaboration with external parties
Work with partners to ensure compliance throughout the supply chain.
Conduct a preliminary internal audit
- Evaluate and Formalize Internal Processes : Conduct a self-assessment to identify gaps in current practices against RGG requirements.
- Implement a Responsible Sourcing Policy: Develop a written policy aligned with the RGG and communicate it to all stakeholders.
- Correct non-conformities: Implement corrective measures to resolve discrepancies identified prior to the official audit.
Select an accredited auditor
Choose a qualified auditor
Select an entity accredited by the LBMA to conduct the independent audit.
Coordinate with the auditor
Plan the audit, agreeing on scope, schedule, and expectations.
Prepare employee teams
Inform staff about potential questions and the auditor’s expectations.
- Prepare the site for the audit
- Conduct the audit
- Manage Results and Recommendations
Document organisation: Arrange documentary evidence so that it is easily accessible during the audit.
Prepare on-site visits: Ensure that facilities meet standards and that processes are operational.
Plan interviews: Identify key personnel who will interact with the auditor and prepare them for potential questions.
Coordination with the auditor: Support the auditor in collecting necessary evidence and during inspections.
Answer questions: Provide clear and detailed responses to all inquiries related to practices and processes.
Document the audit: Keep copies of documents and observations shared during the audit.
Coordination with the auditor: Assist the auditor in collecting the necessary evidence and during inspections.
Answer questions: Provide clear and detailed responses to all inquiries related to practices and processes.
Document the audit: Retain copies of documents and observations shared during the audit.
Ensure Continuous Improvement
- Maintain ongoing oversight of processes to ensure compliance with the RGG.
- Adjust policies and procedures based on audit feedback and regulatory developments.
- Collaborate to improve supplier practices and ensure long-term compliance.
