Commitment two
Responsible sourcing
Licensed sites only, screened against OECD guidance, with site inspection before a supply line opens.
The rule
No licence, no purchase
It is a short rule and we apply it without exception. A site must hold a current mining licence and a valid export permit before we buy a gram from it, and both must be verifiable against the issuing authority — not merely produced on paper.
Beyond the licence, we inspect. We visit the site before a supply line opens, and return during the life of the relationship. Photographs, permit copies and inspection notes go into the file that the buyer eventually receives.
What disqualifies a supply line
- Absent, expired or unverifiable mining licence or export permit
- Any indication of forced labour, child labour or armed-group involvement
- Refusal of physical site inspection or of independent assay
- Material discrepancy between declared origin and the chain-of-custody record
- Sanctioned parties anywhere in the ownership or transport chain
Framework
The OECD five-step model
Management system
A written sourcing policy, a named responsible officer, and records kept for five years.
Identify risk
Site-level assessment of the supply chain against the OECD red flags.
Manage risk
A mitigation plan agreed with the supplier, with defined review points.
Independent audit
Third-party audit of the due-diligence practice, not just the paperwork.
Report
Annual reporting to counterparties on supply-chain due diligence.
The file
Every kilogram carries its paperwork
No lot leaves origin without a documented chain of custody. Buyers receive the full file before funds move.
- Mining licence and export permit copies
- Independent fire assay and XRF report
- OECD due-diligence questionnaire on file
- Site inspection notes and dated photographs
- Insurance certificate and airway bill