"Response to Synergy Global Consulting and MMTC-PAMP"

On 10 July 2020, MMTC-PAMP (part of the MKS PAMP Group) published a response addressed to RAID by Synergy Global, the consultancy hired by the refiner to assess whether the Barrick-owned North Mara gold mine in Tanzania met responsible sourcing standards...For the reasons set out in RAID’s submission to the LBMA, there is a prima facie failure by MMTC-PAMP to comply with the RGG. Synergy’s response to RAID, which is analysed below, fails to clarify how the assessment met the standard of enhanced due diligence and, indeed, the extent to which it can be considered to underpin MMTC-PAMP’s compliance at all.

To coincide with its publication of the Executive Summary, MMTC-PAMP also issued its annual Compliance Report, a key part of which is based upon Synergy’s assessment. However, Synergy’s response to RAID makes clear that its remit was not to assess MMTC-PAMP’s due diligence and compliance, but rather to focus on risk management at the North Mara mine. This confusion creates serious concern as to how the LBMA’s responsible sourcing programme has been applied in this case. It also obfuscates the key question at the heart of the public reporting by Forbidden Stories and civil society groups: how could MMTC-PAMP have sourced gold from North Mara, a mine troubled by widely reported systematic and widespread human rights abuses for a decade, without raising red flags under the LBMA’s responsible gold certification scheme?