Ghana Gold Board

Licensing
Policies

Due Diligence

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The Ghana Gold Board (GoldBod) is the sole authority with exclusive rights to buy, sell, weigh, grade, assay, value and export gold and other precious minerals in Ghana.

The Goldbod is committed in the conduct of our business to the highest standard with the aim of ensuring that all precious metals come from legitimate and ethical sources and do not contribute to conflict, human rights abuses, bribery, non-compliance with taxes and royalties due to governments, terrorist financing practices, money laundering or material breaches of environmental or health and safety regulations. This Due Diligence Policy and practices for handling precious metals per our adopted operating standards are consistent with Ghanaian industry regulatory requirements, the OECD Due Diligence Guidance for Responsible Sourcing or Acquisition of Minerals from Mine and Gold Trading Areas, and the London Bullion Market Association Responsible Gold Guidance.

Due Diligence Commitments

This policy and the due diligence practices that support it, are implemented through a robust and comprehensive management system. In this regard, we commit to the following.

  1. While sourcing from mines or gold trading areas, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:
  • torture, cruel, in-human, and degrading treatment;
  • any forms of forced or compulsory labour;
  • other gross human rights violations and abuses such as widespread sexual violence;
  • war crimes or other serious violations of international humanitarian law, crimes against humanity or genocide; and/or
  • child labour
  1. We will not deal with upstream suppliers where we consider there is a reasonable risk that they are sourcing from, or linked to, any party committing any abuse of the above.
  1. We will not offer, promise, give, or demand bribes or kickbacks in any form to individuals including government officials, customers, contractors and suppliers or any other organisation.
  1. We will not disguise or fraudulently misrepresent the origin of precious metals which will contravene our product provenance value.
  1. We will not misrepresent or fail to comply with taxes, fees and royalties paid to governments for the purposes of trading, handling, transporting, and exporting of gold.
  1. We will support efforts and contribute to the elimination of money laundering and financing of terrorism where we identify a reasonable risk of money laundering or financing of terrorism resulting from, or connected to, the supply and distribution chain of gold.
  1. We will not support or otherwise further any activities which contribute to conflict.
  1. We will take into consideration, and make enquiries about the policies and practices of customers and upstream suppliers with respect to, the following environmental, social and governance (‘ESG’) factors:
    • Compliance with environmental, health, safety, and labour regulations in the territory of operation and/or company policy.
    • environmental management, including:
      • Air, water, land pollution and incident management plans.
      • Water stewardship, especially in water scarce and stressed areas; and.
      • Sourcing from World Heritage Sites and Protected Areas.
    • Storage handling and disposal of hazardous chemicals, including mercury and cyanide.
    • Management of labour issues, including remuneration, working hours, collective bargaining, discrimination, diversity, disputes and safeguarding of workers.
    • Community engagement and management programmes (land acquisition and community resettlement, cultural heritage sites and indigenous people, closure planning and safeguarding of vulnerable populations).

Our Due Diligence Framework

Establish an effective governance framework

  • We have adopted and committed to a policy for gold acquisition.
  • Established management structures to support gold acquisition.
  • Established a system for transparency, information sharing and control on gold acquisition.
  • Strengthened engagement with gold supply counterparties.
  • Established a confidential grievance mechanism.

Identify and assess gold acquisition risk

  • Our company conducts gold acquisition due diligence to identify potential risks.
  • Identify red flags / high risk indicators in the gold acquisition process.
    • Red flags include human rights abuses, bribery and gold provenance and financial impropriety.
    • Amber flags include health and safety issues, and toxic chemical usage which affects the environment such as Mercury and Cyanide
  • Undertake enhanced due diligence measures for high-risk supply areas.

Management of the acquisition risk

  • Goldbod has devised a risk management strategy for any identified risk.
  • We have a risk control plan in place.
  • We have a continuous monitoring system in place.
  • Senior management reporting.

Independent third-party audit of the due diligence measures

  • Our company has developed an effective audit plan.
  • Audit implementation steps have been well aligned.

Annual reporting on due diligence measures

  • Our company has an efficient management system in place.
  • Risk assessment and reporting done periodically.
  • Effective risk management process in place.

Due Diligence Application Process

This involves the onboarding of counterparties (aggregators, agent, suppliers and off takers)

Each new counterparty who expresses interest in working with us is required to go through the due diligence procedure (onboarding). The onboarding process seeks to ensure compliance with anti-money laundering rules, know-your-client assessment, and responsible sourcing. This means we shall onboard all suppliers who express interest to trade with us. All purchases will be done only when suppliers are duly onboarded. The thorough onboarding process that seeks to ensure compliance with anti-money laudering, KYC, responsible sourcing rules are as follows. A meeting with potential supplier to obtain information on the below.

  • Aggregator and company’s official name
  • Buyers or traders under the aggregator
  • Mines supplier obtains products from
  • Territories supplier obtains product from
  • Expected production and volume from the various mines’ product comes from.
  • Expected supply volume from licensed buyers and the list of those buyers.
  • Price terms for transactions
  • Currency terms for transactions
  • Location for trade
  • Timelines for trade to occur

There will be verification of all evidential documents backing the supplier corporate business which it had received from relevant agencies ie assembly, mineral commission etc.

All records to be kept of all registered suppliers for third party verification purposes and for the limitation act period.

The verification will include.

  • Police Checks
  • Security agencies checks.
  • Credit worthiness checks with credit reference bureau.
  • There will also be verification of AML and CFT through any professional verifiable body for clearance.
  • The verification at mine field done on suppliers will include.

The onboarding process is detail to ensure product prevalence and availability of required trading documents by the supplier among other requirements listed above.

Supply Chain Risk Assessment

Once the Compliance/Trade Officer determines the Due Diligence (onboarding form) contains sufficient information for a decision to be made, he assigns a risk profile rating (low, medium, high, or extreme) using the internal risk assessment matrix. For all counterparties deemed to be ‘high risk’ and ‘extreme risk, enhanced due diligence shall be performed. Enhanced due diligence includes the completion of a physical site visit by a representative and completion of a report.

Risks assessed include, but not limited to:

  • the location of the origin of gold
  • any sanctions
  • identification of the supplier or trader
  • ESG matters

Aggregator or Supplier Approval

Once a risk profile rating has been allocated, its guides in engagement for approval or disapproval. Each due diligence or onboarding form shall either be ‘approved’ or ‘rejected’ for business based on our risk-based approach to due diligence. No new supplier may be approved for business until they have been subjected to our due diligence process.

Responsibility

The trade officer and or compliance officer are responsible to oversee the due diligence process. Senior Management retains the ultimate control and responsibility for the acquisition process. Senior Management will carefully select and supervise the trade officer or compliance officer and give him/her the necessary means to perform his/her duty. Senior Management should approve each new supplier and should revisit the decision yearly whether to continue with these business relationships or not.

Gold Traceability

Once approved for business, each supplier is assigned with a unique identification number. Each lot or supply received is assigned with a sub-identification number before the gold is traded or exported.

On-going Supplier Due Diligence & Monitoring

Once the supplier has been approved, all employees who have had any contact with the supplier have a duty to report any known change in information contained in the Due Diligence Form, or any suspicious information, to the trade or compliance officer in accordance with our code of conduct on information provision to the business.

Update of information in Due Diligence

All information updates regarding the supplier including bank account, change of address and contact number, physical location etc shall be submitted to the trade or compliance officer. The modification request shall dully be approved by senior management.

Inactive Aggregators

In the case of counterparties who have been inactive for one (1) year, the Due Diligence Form must be updated, validated, and resubmitted for approval should they elect to recommence business.

Due Diligence Document Retention

All due diligence forms must be kept in a safe and secure manner and for a minimum of seven (7) years in accordance with the limitation Act on documents after business ceasation. This applies to both approved and rejected customers.

Training

Our company ensures the provision of training for employees, counterparties, and business partners to comply with our Policy and, wherever possible, will enforce it with appropriate measures, including termination of employment or contracts if need be.

Sustainability and Responsibility

Sustainability encompasses how we conducts our business through commitment to an ethical supply chain, a pursuit of workplace health and safety, minimizing impact on the environment and maintaining reputation as one of the leading precious metal companies in Ghana.

Conclusion

At Goldbod, we have taken effective steps by this policy to ensure we work to acquire gold which has been mined responsibly. By this policy we are able to as much as possible trace the territory source of product we acquire. As part of our corporate social responsibility especially within the gold mining and trading areas, we have committed to adhere fully to global due diligence standards in sourcing gold by the OECD, RJC and World Gold Council.