"Response to RAID article “LBMA Should Suspend Gold Refiner MMTC-PAMP”

We note RAID’s article of 9 July 2020 “LBMA Should Suspend Gold Refiner MMTC-PAMP” https://www.raid-uk.org/blog/lbma-should-suspend-gold-refiner-mmtc-pamp and the related references, including the “Submission under the LBMA’s Incident Review of PAMP/MMTC-PAMP” https://www.raiduk.org/sites/default/files/raid_analysis_of_synergy_assessment_north_mara_gold_mine_update.pdf, which raise concerns relating to MMTC-PAMP’s assessment of North Mara Gold Mine (NMGM) which was conducted by Synergy Global Consulting (Synergy). This submission is an initial response to the points raised.

...Synergy also recommended to MMTC-PAMP that it continues trading with NMGM while engaging with Barrick and reviews progress on the above-mentioned risk areas and related improvement plan by the end of 2020 and to reassess NMGM’s alignment to the principles outlined in the OECD Due Diligence Guidance and the LBMA Responsible Gold Guidance. Progress on these items should be regularly monitored and reviewed by MMTC-PAMP during 2020, along with the implementation and progress on the risk-specific recommendations identified in this report. Any decisions relating to suspension or continuation of trade rest with MMTC-PAMP, although this may be informed by assessments such as this.

It should be noted that in accordance with the OECD Due Diligence Guidance (page 21, third edition), immediate suspension of trade with upstream suppliers (including largescale mines) should occur where there is a reasonable risk that sourcing is from, or linked to, any party committing serious human rights abuses. The assessment did not identify the occurrence of any of these serious human rights abuses. The assessment did however identify several areas which require improved risk management and raised recommendations accordingly (including relating to security forces management, historical and future resettlement, and the site grievance mechanism). Finally, we recognise this issue has potentially wider implications for responsible mineral supply chain due diligence, and we hope that it will result in ongoing awareness of existing guidance and improvements in good practices more widely.