EU regulation 2017/821
As part of its activities, GFI GOLD must comply with the European regulation (EU 2017/821) setting out supply chain due diligence obligations for gold importers to ensure the traceability of traded gold.
GFI GOLD has established an internal procedures manual relating to the traceability of gold. This manual has been in effect since March 2, 2023 and was approved by the GFI Board of Directors on the same day. It provides for the implementation of policies and practices to meet our duty of care with respect to the supply chain in order to provide the transparency necessary to build public trust and meet our legal obligations.
Recognizing that risks of serious negative impacts may be associated with the extraction, trade, processing and export of minerals from conflict or high-risk areas, and that we have a responsibility to respect human rights and not contribute to conflict, we commit to adopting and incorporating into contracts and/or agreements with suppliers a policy that is consistent with responsible gold sourcing regulations. We undertake to refrain from any act that may contribute to the financing of conflict and to comply with the applicable legal framework.
Supply chain due diligence is an ongoing, proactive and reactive mechanism by which we commit to monitor and manage our purchases and sales to ensure that they do not contribute to conflict or its adverse effects.
In addition, GFI currently sources exclusively from Metalor Technologies SA ("Metalor"), which is a Swiss smelter certified by the London Bullion Market Association ("LBMA") as being on the London Good Delivery List of Acceptable Refiners. An independent third party audit report on Metalor's supply chain due diligence has also been approved by the LBMA. GFI considers the methodology and criteria used to certify these mechanisms to be equivalent to the requirements of the Regulations. Smelters are an important link in international mineral supply chains, as they are generally the last link with a real opportunity to exercise due diligence by collecting, communicating and verifying information on the origin of minerals and the chain of custody.