Page 17 - Bullion World Issue 01 Volume 06 January_2026

Bullion World | Volume 6 | Issue 01 | January 2026

Facilitate co-operation, including information sharing, In particular, companies should ensure that their
among law enforcement agencies of origin, transit, systems of control and transparency of the supply
and destination countries. Illicit flows of ores and chain, including traceability systems as relevant, are
concentrates are invariably a transnational problem, capable of detecting discrepancies, vulnerabilities, and
and need to be addressed through international indicators warranting enhanced due diligence specific
co-operation and co-ordination, both using available to gold concentrates. Where appropriate, they should
mechanisms such as joint customs operations and carry out on-the-ground assessments, plausibility
establishing new avenues of communication and checks and controls of due diligence systems of mines,
collaboration. beneficiation plants, exporters, smelters and refiners.
Verification initiatives like due diligence audit schemes
What can the private sector do? should review and, where necessary, update the scope
Given the persistent blind spots and potential of their assurance processes to capture vulnerabilities
vulnerabilities in gold concentrate supply chains, linked to concentrates. This includes initiatives in both
companies should treat the presence of such materials gold and copper supply chains.
as a high-risk indicator. Where a company identifies
gold concentrates in its supply chain, it is encouraged The shipping industry should contribute to oversight
to prioritise due diligence measures to identify, of ore and concentrate shipments. Through the major
address, and account for potential and actual risks of trade associations – including BIMCO, INTERCARGO,
adverse impacts. ICS and WSC – shippers should explore the possibility
of a code of conduct to help identify and prevent use
All entities in the gold and copper supply chains, of commercial vessels to transport illicit gold and other
particularly processing plants, traders, smelters and precious metals.
their customers, should conduct due diligence in line
with the OECD Guidance. As part of their due diligence Companies sourcing copper and other base metal
process, they should make sure their management concentrates containing gold are encouraged to
systems are equipped to identify actual and potential refer to the OECD Transfer Pricing Guidelines for
risks of adverse impacts linked to gold concentrates, Multinational Enterprises and Tax Administrations
continuously monitor, put in place mitigation measures to accurately establish a price for mineral sales (OECD,
where relevant, and report publicly – particularly on 2022[22]). In addition, further guidance on payable
risk identification and mitigation. metal rates and thresholds are set out in the OECD/
IGF Transfer Pricing Framework for Copper Toolkit
(OECD/IGF, Forthcoming[23]).

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