LBMA Responsible Sourcing Programme — MSM/LSM Site Visit Report, V3, 27.09.2021 (cover "Updated Feb 2024"; inner pages "Updated April 2024")
Text as of 2026-09-28
Public law and official guidance, published as research. Not legal, tax or financial advice.
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- Kind
- form
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- V3
- Issued by
- London Bullion Market Association (LBMA) — Refiners' Toolkit
- Country
- International agreements
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<!-- page 1 --> Updated Feb 2024 LBMA RESPONSIBLE SOURCING PROGRAMME MSM/LSM SITE VISIT REPORT ### V3, 27.09.2021
<!-- page 2 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 1 Visited By (Name of Representative):……………………………………………………………………………………………………. Date of the visit:…………………………………………. This site-visit report supports the LBMA KYC Questionnaire. ## COMPANY INFORMATION Company Name Name of the mine Location of the mine Town Region Country How did you get to the mine site? Name of the mine site operator if not a wholly owned subsidiary
<!-- page 3 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 2 ## GOVERNANCE Has your Company been fined or prosecuted for a breach of the local regulations during the last two years? Does the company ensure provision of fair remuneration to all employees? How much is the minimum salary in comparison with the benchmark? ☐ Yes ☐ No If yes, please provide brief details. Has the company signed up to relevant industry codes of conduct (e.g., WGC, ICMM, EITI)? If yes how are these commitments verified? Have the local authorities performed an on-site visit in the past 12 months? ☐ Yes ☐ No If yes, please provide a copy or a link to the report. Is a visit by local authorities planned in the next 12 months? ☐ Yes ☐ No If yes, please provide brief details. Approximate total number of workers directly employed at the mine Employees / Contractor: Gender: Local / Expat: Are any workers employed by subcontractors? ☐ Yes ☐ No If yes. please provide brief details. Does the company prohibit any use of forced labour (e.g.: not permitting employees to change jobs) including bonded or involuntary prison labour? ☐ Yes ☐ No If yes, please provide brief details. Do miners live on the premises of the mine (e.g.: in a dormitory)? ☐ Yes ☐ No If yes, please provide brief details. How would you assess these facilities? ☐ Comfortable ☐ Basic
<!-- page 4 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 3 ☐ Unacceptable Are working hours, excluding overtime, limited to a maximum of 48 hours per week? ☐ Yes ☐ No If yes, please provide brief details. Has the company received any reports or complaints of pressure, threats, bad or degrading treatment, etc. from employees or third parties, including sexual violence? ☐ Yes ☐ No If yes, please provide brief details. Are the employees represented by a syndicate or equivalent body? ☐ Yes ☐ No If yes, please provide brief details. Have the employees been on strike during the past 12 months? ☐ Yes ☐ No If yes, please provide brief details. Has your Company carried out or plans to carry out a proportionate KYC on each of your business partners (e.g., intermediaries, transporters, exporters) forming part of the supply chain and under which we receive shipments for refining from you? Other comments: ## HEALTH AND SAFETY Did you see a visible health and safety policy and emergency plan? ☐ Yes ☐ No If yes, please attach a copy or a link to the policy. Does the company regularly report leading and lagging safety statistics (KPI on safety incidents)? ☐ Yes ☐ No If yes, please provide brief details.
<!-- page 5 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 4 Has the company implemented an ISO 45001 Occupational Health and Safety Management System, or nationally recognised equivalent? ☐ Yes ☐ No If yes, please provide brief details. Does the company offer regular health monitoring and screening to prevent workplace illnesses? ☐ Yes ☐ No If yes, please provide brief details. Does the company provide adequate first aid equipment and training? ☐ Yes ☐ No If yes, please provide brief details. Is the workplace environment secure? ☐ Yes ☐ No If yes, please provide brief details. Does the company enforce compliance to PPE requirements by all people on site? ☐ Yes ☐ No Please provide brief details. Does the mine provide safety training to visitors? ☐ Yes ☐ No Please provide brief details. Does the mine use the accident rate as key performance indicator? ☐ Yes ☐ No Please provide brief details. What is the mine safety track record for the past 24 months? Do you have medical facilities on site? ☐ Yes ☐ No If no, where are the closest medical facilities? How is the transportation to such organised? Other comments:
<!-- page 6 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 5 ## GOLD AND/OR SILVER EXTRACTION AND PROCESSING METHOD Describe the mining site (open pit, underground, etc.). Describe the extraction techniques (incl. blasting) What is the annual production in tonnes (ore)? What is the average gold and/or silver grade per tonne? Does the mine source ore or doré from mines outside its concession? ☐ Yes ☐ No Describe the processing techniques, including chemical products used. What type of material will be sent to our refinery for processing? Is the infrastructure and/or the equipment set up proportionate to the production figures? ☐ Yes ☐ No Comments: Is there any routine maintenance programme for mining equipment, and are maintenance records kept? ☐ Yes ☐ No If yes, please provide brief details.
<!-- page 7 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 6 Describe the method/process to avoid negative impact / gas emission reduction on the environment: • Air • Water • Noise • Vibration • Land rehabilitation • Biodiversity • Leakage of chemicals Does the company perform environmental impact assessments for new projects? ☐ Yes ☐ No If yes, please provide brief details. Does the company have an environmental incident plan (incl. tailings dam failure)? ☐ Yes ☐ No Please provide brief details. Other comments: ## USE OF MERCURY (IF APPLICABLE) How is mercury sourced? How is the mercury stored, handled, used, and recovered? What are the procedures in place to limit the negative impacts on environment due to the use of mercury? What are the procedures in place to limit the negative impact on health & safety issues due to the use of mercury?
<!-- page 8 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 7 What is the action plan to find alternative solution to mercury? What is the time frame to renounce to the use of mercury?
<!-- page 9 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 8 ## ARTISANAL MINING NEXT TO THE MINE SITE Did you identify any artisanal miners • On the mine site? • next to the mine site? ☐ Yes ☐ No If yes, please provide brief details. ☐ Yes ☐ No If yes, please provide brief details. If yes, estimate the number of ASM miners on the concession. Have you seen children working on site? ☐ Yes ☐ No If yes, please provide details. Can these ASM miners be considered legitimate ASM? ☐ Yes ☐ No Please provide brief details. How does the mine handle artisanal miners on or next to the mine site? Have there been any instances of conflict or tension? If yes, please describe. ☐ Yes ☐ No If yes, please provide brief details. Does the mine source from artisanal miners on or next to its concession? ☐ Yes ☐ No If yes, please provide brief details. Are the ASM part of the community? ☐ Yes ☐ No Other comments:
<!-- page 10 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 9 ## COMMUNITY Have you resettled communities? If possible, visit the resettled community ☐ Yes ☐ No If yes, provide details on consultation and compensation. Does the company engage with indigenous communities to obtain meaningful consent prior to commencing activities that adversely affect the community (e.g., cultural heritage)? ☐ Yes ☐ No If yes, please provide brief details. Does the company have regular meetings with local representatives? If yes is there a fair, accessible, effective, and timely grievance mechanism? ☐ Yes ☐ No Please provide brief details. ☐ Yes ☐ No ☐ N/A Please provide brief details. Is the mine positively affecting the surrounding communities, for example? • Number of direct employees at the site • Number of indirect jobs supporting the mine site • Infrastructure (e.g., school, community centre, etc.) ☐ Yes ☐ No Is the community facing issues that would impact our refinery’s reputation (e.g., organized crime, prostitution, alcoholism, abuse of fragile community members, children schooling)? ☐ Yes ☐ No If yes, please provide brief details. Does the company have a policy to “act as a good neighbour” minimizing dust, noise, road access, vibration, water access and light pollution from its operations? ☐ Yes ☐ No If yes, please provide brief details. Have there been demonstrations or social unrest in relation with the mine? If so, how was it handled by the mine and the authorities? ☐ Yes ☐ No If yes, please provide brief details.
<!-- page 11 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 10 ## CONFLICT AREA AND SECURITY Is the mine located in a conflict area? ☐ Yes ☐ No If yes, please provide brief details. Are there any armed groups stationed on/near the mine site? ☐ Yes ☐ No If yes, please provide brief details. If yes: Is it state armed groups? ☐ Yes ☐ No Is it non-state armed groups? ☐ Yes ☐ No Is it public or private security forces? ☐ Yes ☐ No Describe the general site security infrastructure (CCTV, perimeter fence, controlled access etc.) Describe the precious metal storage security infrastructure and processes. Does the company have procedures for storing, handling, using, and disposing of hazardous chemicals? Does the mine comply or plan to comply with the International Cyanide Management Code? How do you assess the security infrastructure? ☐ Adequate ☐ Inadequate Comments: Have you identified any indication of illegal ☐ Yes ☐ No
<!-- page 12 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 11 taxation or extortion of money across the whole supply chain? If yes, please provide brief details. Are there appropriate procedures to screen security personnel during the hiring process? ☐ Yes ☐ No Comments: Is the screening of security personnel in line with the UN Voluntary Principles on Security and Human Rights? Are there appropriate procedures to train security personnel ☐ Yes ☐ No If yes, please provide brief details. Is site security managed in-house or outsourced to a third party? Comments: Have you determined any risks of incident of human right violations (as defined in the declaration of human rights)? ☐ Yes ☐ No If yes, please provide details.
<!-- page 13 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 12 ## TRANSPORTATION Summaries transportation methods from mine site to export location (routed through CAHRA). Is the material stored by a third party prior to export ☐ Yes ☐ No If yes, please provide brief details. Other comments:
<!-- page 14 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 13 ## CORRECTIVE ACTIONS RASIED DURING VISIT Corrective Action Mine Comment Completion Date
<!-- page 15 --> Updated April 2024 MSM/LSM SITE VISIT REPORT RESPONSIBLE SOURCING PROGRAMME 14 ## REFINER MANAGEMENT REVIEW General comments: What is the mine biggest risk? Risk rating Low Medium High Next Visit Due