Refining

Code of Conduct Self-Assessment Guide

Supported by
Supported by

Abhiyaan Abhiyaan
An industry initiative
An industry initiative
Inspired by the Retail Gold Investment Principles
Inspired by the Retail Gold Investment Principles
 Welcome to the
in-depth guide for Refining.

The first part - the Code of Conduct, will help you

understand and adapt to the best practices laid
out as per the Retail Gold Investment Principles.

The second part - The Self -AssessmentGuide will

help you identify areas of improvement through
a comprehensive questionnaire

We hope that with this guide by your side, you can embark on a glorious
journey and set a new benchmark in the gold industry.

1 2
 Contents

Introduction and structure of the Code of Conduct ... 06

Scope and Objectives ... 07

India Gold Market Code of Conduct - Refining ... 08

Linkage to Retail Gold Investment Principles ... 12

Implementation guidance ... 14

• Sourcing dore ... 15

• Recycling / Purchasing of old gold ... 17

• Refining ... 19

• Transportation and storage ... 21

• Customer and complaints management

• Payments ... 23

• Risk management

• Audit and compliance ... 25

Dissemination and application of Code of Conduct ... 26

Disclaimer

Annexure A: Self-assessment guide ... 27

• Introduction to Self-assessment guide ... 28

• Detailed assessment guidance ... 29

• Assessment Summary ... 46

Annexure B: Version control ... 47

Notes ... 48

3 4
 Introduction and structure
of the Code of Conduct document

This Code of Conduct document

is aimed at providing high-level
guidance for refining. The Code
of Conduct includes sound
practices, additional best practices
and implementation guidance
for refining.

Sound practices capture healthy practices which

should be followed by any provider (across all sizes,
complexity, etc.)

Additional best practices are aimed at larger/mature

providers who wish to adhere to even higher
standards of practice

Implementation guidance offers broad steps to

deploy sound practices/additional best practices at
an organization. The guidance is directional in nature
and is not exhaustive. Practical application of these
practices will require a detailed guidance that is
specific to the organization

5 6
 Global Retail Gold
Scope and Objectives Investment Principles

Fairness Transparency Protection of Responsible

and integrity client assets gold sourcing

Regulatory Commercial Operational

compliance prudence professionalism

Gold is an important asset class in India with an annual demand of ~800–900 tonnes1,
making it India the world’s second largest consumer of gold. Gold holds a unique place
in India, being culturally and socially significant2, and is an important savings asset3
with its consumption driven largely in the form of jewellery4, investment bars and coins.
1
Source: Viability of a Gold Exchange in India, 2016 by India Gold Policy Centre
2~
87% of estimated gold stock in India is with women
3~
20% of household wealth stored is in the form of gold
4~
80% of gold demand in India is in the form of jewellery compared to ~ 35% globally

While Indians have a strong affinity for investment in gold, individuals seeking to invest in
gold face several challenges in doing so, particularly around price transparency and quality
assurance. As the market is fragmented and there is no overarching supervisory body, an
World Gold Council launched Global Retail Gold Investment Principles industry-defined Code of Conduct is deemed to be an effective mechanism for protecting
(RGIPs) in August 2020. The principles are designed to raise the bar the interest of retail investors.
for product providers across the market and encourage retail investors
to place their trust in gold. Greater trust should benefit customers Effective dissemination and implementation of the Code of Conduct should enhance trust
and product providers alike, creating value and driving demand of consumers in gold products. This should, in turn, drive demand for both established
across the industry. and new gold products, benefitting consumers and the industry. This document is a step
in that direction, and it lays out the Code of Conduct specific to refining. There are similar
existing Code of Conduct documents for other activities across gold value chain including
bullion trading, manufacturing, assaying and retailing. We may develop further Code of
Conduct for activities such as vaulting, lending, etc. in future, as required.

7 8
 Gold jewellery India Gold Market
value chain Code of Conduct - Refining

Mining Refining Assaying & Bullion Trading Manufacturing Retailing Digital Investment
Hallmarking Gold Retailing

The process of developing the Code of Conduct has included

interaction with a number of industry experts, providers and
other stakeholders. We envision that the Code of Conduct
guidelines will continue to evolve over time in step with global
best practices and changing consumer preferences and
improved awareness of consumers in India.

9 10
 Activity Sound Practices

Sourcing dore 1. I promise to conduct “Know Your Provider” checks and record all the relevant
information about my suppliers before onboarding new suppliers
Linkage to
2. I promise to only procure dore which adheres to industry accepted standards, Retail Gold Investment Principles
conduct independent tests to ascertain the characteristics and document
details for each transaction

3. I promise to adhere to global responsible sourcing guidelines as well as

consider ESG credentials (Environment, Social and Governance) of suppliers
(Additional best practices)

Recycling / 4. I promise to design, convey and practice a fair policy for old gold purchase
Purchasing of and collect KYC details of sellers of old gold
old gold
5. I promise to buy / service recycled gold only upon conducting independent
tests to ascertain the characteristics of gold and documenting details
of the scrap gold

Refining 6. I promise to ensure that the refined products meet the dimension, weight,
finish, homogeneity and purity standards as characterized by markings
and commitment to the customers

7. I promise to be compliant with labour laws and provide requisite infrastructure,

safety equipment, benefits and training to my employees

8. I promise to have mandatory industrial licenses/approvals as per

applicable regulations

9. I promise to maintain traceability of gold items throughout the refining

process from the point of supply to delivery to my customers

Transportation 10. I promise to have adequate operational protocols to safely store and transport
and storage valuables (dore, recycled gold, refined gold products, cash, precious metals)

Customer and 11. I promise to adhere to appropriate KYC requirements while on-boarding
complaints new customers and update this information periodically
management
12. I promise to implement adequate systems and mechanisms to receive,
record and redress customer queries and complaints

13. I promise to educate customers about testing procedures, refinery markings

or point them to credible sources of information

Payments 14. I promise to clearly communicate and adhere to terms, conditions and timelines
of payments with every customer and supplier, consistently and impartially

Risk 15. I promise to proactively identify major financial and non-financial risks to
management my business and take appropriate steps to mitigate / manage the risks Sound practices and additional best practices for refining cover all the
16. I promise to have a dedicated and trained risk management team without seven Global Retail Gold Investment Principles and are mapped
linkage to any business incentive (Additional best practices) predominantly as below

Audit and 17. I promise to abide by the law of land and disclose required information
compliance to designated statutory bodies in time

11 12
 professionalism
No. Sound practices/Additional best practices

gold sourcing
Transparency

Protection of
Fairness and

client assets

Responsible

Commercial

Operational
compliance
Regulatory

prudence
integrity
1. I promise to conduct “Know Your Provider” checks and
record all the relevant information about my suppliers Implementation guidance
before onboarding new suppliers

2. I promise to only procure dore which adheres to industry

accepted standards, conduct independent tests to ascertain
the characteristics and document details for each transaction

3. I promise to adhere to global responsible sourcing guidelines

as well as consider ESG credentials (Environment, Social and
Governance) of suppliers

4. I promise to design, convey and practice a fair policy for old

gold purchase and collect KYC details of sellers of old gold

5. I promise to buy / service recycled gold only upon conducting

independent tests to ascertain the characteristics of gold
and documenting details of the scrap gold
6. I promise to ensure that the refined products meet the
dimension, weight, finish, homogeneity and purity
standards as characterized by markings and commitment
to the customers
7. I promise to be compliant to labour laws and provide requisite
infrastructure, safety equipment, benefits and training
to my employees

8. I promise to have mandatory industrial licenses/approvals

as per applicable regulations
9. I promise to maintain traceability of gold items throughout
the refining process from the point of supply to delivery
to my customers

10 I promise to have adequate operational protocols to safely

store and transport valuables (dore, recycled gold, refined
gold products, cash, precious metals)

11. I promise to adhere to appropriate KYC requirements while

on-boarding new customers and update this information
periodically

12. I promise to implement adequate systems and mechanisms

to receive, record and redress customer queries and
complaints

13. I promise to educate customers about testing procedures,

refinery markings or point them to credible sources
of information

14. I promise to clearly communicate and adhere to terms,

conditions and timelines of payments with every customer
and supplier, consistently and impartially

15. I promise to proactively identify major financial and

non-financial risks to my business and take appropriate
steps to mitigate / manage the risks

16. I promise to have a dedicated and trained risk management

team without linkage to any business incentive

17. I promise to abide by the law of land and disclose required

information to designated statutory bodies in time
13 14
 Sourcing dore

1
I promise to conduct “Know Your
Provider” checks and record all relevant
– Past supply background to India and
any available customs records
Sample Scenario:
information about my suppliers before – Information on supplier’s practices from
onboarding new suppliers market intelligence and referee, if any
I am a gold refiner and I have been procuring dore from a supplier
(licensed bullion trader / merchant exporter / miner) for last 3 generations.
• Conduct due diligence and record relevant • Record relevant information even for reputed Our business is completely trust based and I don’t have “Know Your Provider”
information about suppliers such as below institutional suppliers including banks
details of the merchant. I believe that the merchant is procuring the dore
before initiating any business transaction
• Update information recorded for onboarded from legitimate sources, however, I never had a word with the merchant
with a new supplier
suppliers annually or intermittently (in case about this. What should I do?
– Business license
any red flag is raised for the supplier from
– Relevant certificates/permits from
market intelligence or any reliable source)
country of origin

2
I promise to only procure dore which
adheres to industry accepted standards,
the supplier for relevant details such as below
– Weight of each metal present in the bar
Potential Response:
conduct independent tests to ascertain – Presence of other trace elements
the characteristics and document – Country of origin and mine details Long-standing relationships of trust are import-
details for each transaction ant and enhance your ability to know the prove-
• Ensure documentation of relevant details
nance of the product you are providing to your
such as below for each trade
• Purchase dore which adheres to industry – Mine or supplier of the dore customers. However, it is critical for you to
and regulatory standards directly from the – Weight of each element in the bar safeguard your interest against any future even-
source country. Ensure that the provider has – Purity certificate from supplier tuality. You should immediately solicit relevant
complied with regulatory provisions in the – Way bill
source country “Know Your Provider” details such as business
– Purchase order/contract
– Custom clearance records license, miner details, bank references and
• Enter into a formal Sale and Purchase
– Payment details (including payment financials from country of origin, etc. from your
Agreement with clearly stated technical and
commercial terms and conditions terms and supplier’s bank details) supplier

• Independently test (in-house/outsource) • Share details of any deviation with the

supplier for requisite action and resolution You should also solicit and document details
random samples of the dore provided by
such as source of the dore, quality, weight, etc.
• Maintain records of past transactions for
a reasonable period (at least 2 years) for every transaction.

• Conduct business with miners who display

Additional best practices
environmental standards e.g. invest in
restoration of environment, responsibly
I promise to adhere to to global discharge waste
3 responsible sourcing guidelines as
well as consider ESG credentials • With regards to social criteria, support
(Environment, Social and Governance) miners that ensure safe and healthy work
of suppliers environment for their employees and do not
use child labor
• Ensure adherence to responsible gold
standards, e.g. LBMA, OECD, with proper • Work with business partners committed to
audit and certification, especially for the good governance practices (transparency,
purpose of export or trading on commodity internal controls, fair policies)
exchanges

15 16
 Recycling / Purchasing of old gold

I promise to design, convey and I promise to buy / service recycled gold Sample Scenario:
4 practice a fair policy for old gold 5 only upon conducting independent tests
purchase and collect KYC details to ascertain the characteristics of gold I am a gold refiner and I want to start refining scrap gold supplied
of sellers of old gold and documenting details of the by local jewellers. What details should I ask the jeweller for?
scrap gold

• Design and develop a fair and standardised • Independently test (in-house/outsource)

old gold purchase policy for all customers the scrap gold provided by the supplier
for purity of gold in the scrap articles
• Clearly communicate all aspects taken into
consideration while pricing old gold (purity, • Ensure documentation of relevant details
melting charges, melting losses, taxes, etc.) such as below with suppliers for each trade
to all customers, consistently and impartially – Supplier details
as part of “Information on consumer rights” – Gross and net weight of each scrap articles
– Purity level of the articles There are three types of details you
• Key risks (e.g. gold price risk in refining on – Purchase order / contract terms, as
contract) should not be omitted, disguised applicable for contract refining or purchase
should procure from the jeweller
or misstated of scrap gold before initiating refining for them:
• Collect KYC details of selling organisation – Reference of earlier transactions and
origin of the scrap gold • “Know Your Provider” details of the jeweller:
individual before proceeding with the You should procure and document details
scrap gold purchase process such as • Maintain records of past transactions for such as:
– Business license a reasonable period (at least 2 years) – Business license
– GST certificate
– GST certificate
– PAN details • Proactively report any observation indicating
– Residential proof (for individuals) unfair practices such as stolen or smuggled – PAN details
– Information on supplier’s practices from gold to relevant authorities – Conduct market intelligence for information
market intelligence and referee, if any on supplier’s practices

• Maintain a digital/physical track record of • Setup contract details: You should setup the
parties involved, transaction details etc. contract on whether you would procure the
for a reasonable period (at least 2 years)
scrap and take the financial price risk or
conduct contract refining for the jeweller

• Details for each transaction: For each

transaction with the jeweller you should
document relevant details such as:
– Jeweller KYP details
– Gross and net weight of each scrap article
– Purity level of the articles
– Purchase order / contract terms,
as applicable for contract refining or
purchase of scrap gold

17 18
 Refining
I promise to ensure that the refined I promise to have mandatory industrial Sample Scenario:
6 products meet the dimension, 8 licenses/approvals as per applicable
weight, finish, homogeneity and regulations I am the owner of a mid-sized refinery and I outsource part of refining work
purity standards as characterized to contractors. There are 2 contractors to whom I outsource the work
by markings and commitment to
frequently. The working conditions are unsafe and unfit for the contractors'
the customers • Upgrade or set-up factories/refineries
compliant with local regulations workers. I want to help the contractors but not sure how?
• Produce bars that meet the dimension, finish and such as below:
– BIS/NABL certificate
purity characteristics homogenously across the
– Factory license
complete bar / coin
– Pollution license
• Ensure that testing labs are suitably equipped – Environmental clearances
– As applicable to your workplace5
(with equipment rightly calibrated) along with
– Fire and safety clearances6
qualified staffed to reduce the risk of error in
– Labour related registrations
measurement
– Import-Export permit / licenses
• Maintain records of test results, and provide to
Potential Response7:
customers/relevant authorities, if required
You can support contractors through
• Mark accurate weight, purity, serial number, multiple means to improve working
refinery’s mark, certifying body’s mark if allowed conditions of the workers including
to be used (BIS) etc., as applicable under good
delivery standards • Advisory (Assist contractors to identify and apply
for government grant programmes for infrastructure
upgradation/assist contractors to select and apply
to financial institutions for loan to upgrade
I promise to be compliant to I promise to maintain traceability of
7 labour laws and provide requisite 9 gold items throughout the refining
infrastructure)

infrastructure, safety equipment, process from the point of supply to

• Technical (Help contractors to select and procure
benefits and training to my delivery to my customers
right machinery / equipment at best price, offer
employees
training to workers to operate new equipment/
work efficiently on existing equipment)
• Install appropriate tools, machines and safety kits • Deploy physical/digital systems for traceability
to ensure safe operations along with basic hygiene of details such as below for refined gold items • Financial (Invest in upgrading the contractors'
factors such as adequate ventilation, cooling zones, – Date of sourcing facilities through various arrangement such as
protective gears, etc. – Batch details loan, equity investment, etc.)
– Dore and refined gold quality
• Offer benefits mandated by the government such – Mine / supplier details • Incentivise by providing more assignments
as provident fund, tax deductions, labour union – Details of workers who worked on the refining if working conditions are improved
formation, etc. to employees of the specific batch
– Details of contractors/sub-contractors, if relevant 6
List of clearances is indicative in nature – may or may not be
• Offer required trainings such as below to ensure
– Logistics and storage agency applicable depending on the regulation. A refiner should solicit
safety of all workers
appropriate legal advice to understand all the clearances required
– Fire protection drills
• Maintain all the above records for the refined gold 7
Indicative response - to be customized for context of refiner,
– Emergency preparedness
bars for a reasonable period (at least 2 years) contractor, local regulations etc.
– Machine and equipment operations

19 20
 Transportation and storage
I promise to have adequate operational events (such as theft, infidelity, accident, natural Sample Scenario:
10 protocols to safely store and transport disaster) through insurances or capital reserves
valuables (dore / recycled gold, refined I am the owner of a small refinery and I recently visited an exhibition.
gold products, cash, precious metals) • Priority should be given to safeguard customers’ 50+ manufacturers and retailers attended the exhibition and some of them
assets such as gold held on their behalf
exhibited interest in conducting business with me. Manufacturers operate
(e.g. refining on contract basis)
• Deploy adequate physical security/technology in a different geography and I have limited contacts. How can I conduct
enabled access to vaults, strong rooms; physical/ • Seek services of accredited logistic companies for trade with such manufacturers while minimizing my risks?
digital recordkeeping of access to ensure safety international / domestic movement of unrefined
of stored assets or refined gold. Conduct due diligence and collect
relevant KYC details of logistics companies
• Ensure adequate coverage of gold, precious metals
responsible for transportation.
and cash being transported to cover against loss

Potential response:
Customer and complaints management
It is critical to conduct due diligence
I promise to adhere to appropriate KYC • Inform the customers about the system while before embarking on business with new
11 requirements while on-boarding new communicating consumer rights and solicit customers, especially in geographies
customers and update this information customer feedback at regular intervals where limited market intelligence can
periodically be collected. A few must activities to
• Resolve the customer complaints within the agreed
upon timelines
reduce the risks include
• Perform due diligence and capture relevant
information such as below before initiating any
• Request the manufacturer to share all necessary
business transaction with a new customer
I promise to educate customers about KYC details such as GST certificate, PAN details,
– Business license, GST certificate, PAN details 13 testing procedures, refinery markings business license
– Financial stability of the customer or point them to credible sources of
– Bank guarantee (in case of credit to customers) information • Conduct market visit including the manufacturer’s
– Information on customer from market
• Make customers aware about the testing procedures factory to vet some of the KYC details and assess
intelligence and referee, if any
and whether the refinery and the product are certified financial capability of the manufacturer (e.g. use
• Update the information recorded for onboarded (e.g. BIS / LBMA certified) proxy metrics such as inventory in the factory vs.
customers annually or intermittently in case any value of order placed)
• Proactively educate customers to check dimensions,
red flag is raised for the customer from market
fineness, assay stamps and refinery markings as per • Conduct mystery shopping, if possible, to
intelligence or any reliable source
BIS or LBMA guidelines understand the business practices of the
• Encourage customers to check the product specifica- manufacturer
tions (purity, weight and fineness) and price breakup
(e.g. benchmark price of bullion, storage charges) • Sell the bars against advance payment or
I promise to implement adequate
12 systems and mechanisms to receive,
• Guide customers to credible sources of information
payment on delivery. Solicit bank guarantee,
record and redress customer queries in case the bars are sold on credit
(e.g. BIS website, LBMA standards, WGC) to help
and complaints
them know more about best practices in the gold
industry and make informed decisions
• Set-up physical/digital systems for customers to
file complaints and for the refiner to record and
track complaints

21 22
 Payments

I promise to clearly communicate – Timelines for the payment Sample Scenario:

14 and adhere to terms, conditions and – Information on customer rights
timelines of payments with every I am a refiner and my current supplier has a shortfall next month and
• Adhere to terms, conditions and timelines as
customer and supplier, consistently I am considering sourcing from a new supplier of dore for a few months.
and impartially agreed upon with the suppliers and customers
My existing supplier has referred the supplier to me. While I will collect
• Adhere to Foreign exchange rules and necessary “Know your Provider” details for the new supplier, what
• Disclose/solicit key terms and conditions regulations in case of international payments
additional practices should I follow to minimize my risks?
with customers and suppliers such as
– Applicable purchase price and charges • Any changes to terms and conditions is
including any additional operational charges communicated to the customers and suppliers
(transaction, delivery, storage, etc.) explicitly in writing (especially in case of repeat
– Trade settlement and insurance business)
arrangements

Potential response:
Risk management List of indicative actions to minimize
your risk
I promise to identify and mitigate sentiments (limited financial stability,
15 financial and non-financial risks to involvement in unfair trade practices, etc.)
my business and take appropriate • Review the accreditation regulations that apply to
– Check list for reporting and disclosures
steps to mitigate/manage the risks to ensure compliance with regulations you such as LBMA and BIS to assess whether
– Build adequate financial reserves to cover the miner / supplier meets the requirements
• Proactively identify and measure major risks that business choses to incur
risks for the business such as – Have contingency plan to mitigate supply • Formalize an agreement with the supplier including
– Operational risks side risks (e.g. restrictions on import) relevant business details such as pricing, timelines,
(risks due to error or fraud) rights of each party, etc.
– Financial risks (gold price risk, settlement
risk, counterparty risk) • Include an option in the contract for contract
– Legal and compliance risk Additional best practices cancellation in case of unsatisfactory dore or
– Third party/Outsourcing risk
mismatch with regulatory requirements
– Cyber risk
I promise to have a dedicated and
• Deploy risk controls covering policies, roles 16 trained risk management team without • Assess whether your refining infrastructure can
and responsibilities to mitigate / manage linkage to any business incentive process the dore including the trace elements that
identified risks. E.g. may be present in the dore supplied by the new
– Manage gold price risk by hedging (MCX, • Deploy a dedicated risk management team supplier
advance selling) or undertaking minimal without any business incentive which can
risk in the business model (e.g. gold price perform regular risk assessment, maintain
risk lies with customer in case of contract a risk register, design and implement risk
refining) mitigation plans
– Maintain financial wherewithal to reim
burse customers in event of losses for • Implement the “separation of duties
which the refiner is responsible, either principles”, where two independent people
through own resources, bank guarantees are required to complete certain critical
or insurance activities. Helps to prevent or mitigate
– Minimum/No credit window for fraud and operational errors
customers to reduce the counterparty
• Deploy adequate safeguards to protect the
risk
KYC information collected from suppliers,
– Minimum/No business with suppliers/
customers, logistics agencies, etc.
customers/logistic providers with negative

23 24
 Audit and compliance Dissemination and application
of the Code of Conduct
I promise to abide by the law of land
17 and disclose required information to
designated statutory bodies in time The proposed sound practices, additional best practices and
implementation guidance are voluntary so, at present, there will
• Hire professional auditors without any conflict be no audit or public endorsement by the World Gold Council.
of interest to conduct audits (as applicable However, we believe that conforming with these practices will
to the business) strongly benefit providers and customers. Over time, we expect
stakeholders to push for implementation of the sound practices
• Audit to include verification of gold holdings outlined in this document.
and reconciliation with refiner’s records and
information system Providers are therefore encouraged to independently demonstrate
compliance with the sound practices. This should strengthen trust
• Audit to also include any inspection mandated
in their offerings, facilitate customer acquisition, drive business
by the government including industrial, waste
growth and foster cooperation with external partners such as vault
management, labour laws compliance, etc.
operators, security carriers, gold dealers and banks. Providers can
• Audit results that can be published on the demonstrate adherence to the practices through public disclosure
company website and/or made available to to customers, investors and other interested parties. This can be
investor community to build trust an achieved in several ways – via providers’ own websites, through
credibility marketing materials or more generally online.

Providers who choose to go beyond to additional best practices

will be able to differentiate themselves from peers

Disclaimer
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magna aliqua.Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo
consequat. Duis aute iruredolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur.
Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum.

Lorem Ipsum dolor Lorem Ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt
labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip
ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat
nulla pariatur. Excepteur sint occaecat cupidatat non proident, runt mollit anim id est laborum.

25 26
 Annexure A:
Self-assessment guide Introduction to Self-assessment guide

The self-assessment guide is applicable for organisations of any size

as the test is based on the practices deployed and not the volume of trade
conducted. It is voluntary at present and there will be no audit or public
endorsement by the World Gold Council. Providers can demonstrate
adherence to the practices through public disclosure to customers,
investors and other interested parties. This can be achieved in several
ways – via providers’ own websites, through marketing materials or
more generally online

Self-assessment guide aims to help the provider with current state

assessment of their practices against corresponding Code of Conduct
and entails three steps for assessment

Read the corresponding Code of Conduct thoroughly

1. before beginning this assessment

Refer to guiding questions to develop conclusion for the organisation's

2. practices against each Code of Conduct statement – to determine the
extent to which a Code of Conduct is observed by the organisation

Assess current state against each Code of Conduct. The assessment is

3. built on the gravity and urgency to address the areas of improvement.
Assessment outcome would be as following –

A. Observed (O)
The provider observes the Code of Conduct in entirety

B. Broadly Observed (BO)

The provider broadly observes the Code of Conduct. The assessment has identified
one or more areas of improvement that the provider should address and follow up
within a defined timeline

C. Partly Observed (PO)

The provider partly observes the Code of Conduct. The assessment has identified one
or more critical areas of improvement and should be addressed as high-priority items

D. Not Observed (NO)

The provider does not observe the Code of Conduct.

The self-assessment guide is evolving in nature and will mature over

time with inputs from the market participants

27 28
 Detailed assessment guidance

I promise to conduct “Know Your Provider” checks and record all I promise to only procure dore which adheres to industry
1 the relevant information about my suppliers before onboarding 2 accepted standards, conduct independent tests to ascertain the
new suppliers characteristics and document details for each transaction
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you conduct due diligence / have internal processes to evaluate 1. Do you have a criterion to only procure gold which adheres to
suppliers before initiating business with them? Indian industry accepted standards only?

2. Do you collect requisite documents from suppliers for Know Your Provider 2. Do you conduct independent test for dore received? Do you test for all the
checks? Do you conduct business with the suppliers if they can’t fulfil relevant characteristics (such as weight, presence of trace metals, etc.)?
the minimum requirements?
3. Do you document all information (such as weight, miner details, etc.)
3. Do you maintain record of the information and documents collected? related to the trade in purchase agreements / other documents?
Do you update the information collected on an ongoing basis? Do you maintain the records of past transactions for reasonable
period (at least 2 years)?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

29 30
 I promise to adhere to global responsible sourcing guidelines I promise to design, convey and practice a fair policy for old gold
3 as well as consider ESG credentials (Environment, Social and 4 purchase and collect KYC details of sellers of old gold
Governance) of suppliers
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you have a criterion to only procure gold which adheres to global 1. Do you have a standard old gold purchase policy for all customers?
responsible sourcing guidelines (OECD, LBMA, etc.)? Do you ensure
adherence with proper audit and certification? 2. Do you clearly communicate all aspects taken into consideration while
pricing old gold (purity, melting charges, melting losses, taxes, etc.)
2. Do you ensure that imported gold complies with regulatory provisions to all customers, consistently and impartially?
of the country of origin?
3. Do you state key risks (e.g. gold price risk in refining on contract)
3. Do you consider environmental standards, beyond the applicable laws objectively?
(e.g. invest in restoration of environment) while selecting a supplier?
4. Do you collect KYC details of sellers of old gold?
4. Do you consider other social (e.g. safe working environment, Do you purchase gold if the seller does not meet KYC requirements?
child labour free) and governance (e.g. transparency) criteria?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

31 32
 I promise to buy / service recycled gold only upon conducting I promise to ensure that the refined products meet the dimension,
5 independent tests to ascertain the characteristics of gold and 6 weight, finish, homogeneity and purity standards as characterized
documenting details of the scrap gold by markings and commitment to the customers
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you conduct independent test for the received scrap gold? 1. Do you ensure that the marking on refined bars conforms to the
Do you test for all the relevant characteristics (such as weight, purity, etc.) product specifications?
before accepting gold?
2. Do you have testing labs (in-house or external) suitably equipped
2. Do you document all information related to product, supplier and and staffed to ensure accuracy in measurement?
transaction? Do you maintain these records for reasonable period
(atleast 2 years)? 3. Do you maintain the records of refined bars including characteristics
(dimensions, weight, finish, homogeneity, purity, etc.)
and test results?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

33 34
 I promise to be compliant to labour laws and provide requisite I promise to have mandatory industrial licenses/approvals
7 infrastructure, benefits and training to my employees 8 as per applicable regulations

Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you ensure compliance to all applicable labour laws? 1. Do you ensure compliance to all applicable industrial licenses / approvals
for your organization (including refinery / testing lab)?
2. Do you have adequate workplace policies and benefits to provide
a safe and healthy workplace to employees? 2. Do you maintain records of cases of non-compliance, queries
from regulator along with actions taken to resolve them?
3. Do you offer regular training to employees, as required?
3. Do you have adequate processes to ensure timely renewal of licenses?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

35 36
 I promise to maintain traceability of gold items throughout the I promise to have adequate operational protocols to safely store
9 refining process from the point of supply to delivery to my 10 and transport valuables (dore / recycled gold, refined gold products,
customers cash, precious metals)
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you ensure complete traceability of gold throughout the refining 1. Do you deploy adequate safety measures (e.g. physical security, access
process? Do you maintain details related to source of input dore/scrap control) to store and transport valuables (dore/scrap gold, refined gold
gold, custom clearance records, batch details, workers, etc. for all products, cash, precious metals, etc.)?
refined gold?
2. Do you have adequate insurance or capital buffers to cover against
2. Do you have physical/digital systems to capture these details accurately? events of loss?

3. Do you maintain these records for reasonable period (at least 2 years)? 3. Do you seek services from accredited logistics companies only for
international / domestic movement of unrefined or refined gold?

4. Do you conduct due diligence / “Know Your Provider” checks to

evaluate logistics agencies before empanelling them?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

37 38
 I promise to adhere to appropriate KYC requirements while I promise to implement adequate systems and mechanisms to
11 on-boarding new customers and update this information 12 receive, record and redress customer queries and complaints
periodically
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you conduct due diligence / KYC checks to evaluate customers 1. Do you have physical/digital systems in place to receive customer
before initiating business with them? complaints?

2. Do you conduct business with the customers even if they are 2. Upon receiving a complaint, do you commit a timeline for redressal?
unable to fulfil the KYC requirements?
3. Do you maintain records of the customer complaints
3. Do you update this information periodically? (number of complaints received, pending, resolved) for reasonable period?

4. Do you solicit customer feedback at regular intervals?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

39 40
 I promise to educate customers about refinery markings I promise to clearly communicate and adhere to terms, conditions
13 or point them to credible sources of information 14 and timelines of payments with every customer and supplier,
consistently and impartially
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Have you developed any educational material for customers? 1. Do you communicate and clearly align on key terms of payment
Do you include details on products, pricing, testing procedures, before finalising trade with suppliers / customers?
refining standards, markings, etc.?
2. Do you ensure that you as well as the suppliers/customers adhere
2. Do you train frontend staff to offer material to educate customers? to the terms?

3. In absence of in-house materials, do you point customers 3. Do you have mechanisms in place for events when one party violates
to other external sources of credible information? the terms?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

41 42
 I promise to proactively identify major financial and non-financial I promise to have a dedicated and trained risk management team
15 risks to the business and take appropriate steps to mitigate / 16 without linkage to any business incentives
manage the risks
Current state: Current state:

Observed Broadly observed Observed Broadly observed

Partly observed Not observed Partly observed Not observed

Key questions to consider: Key questions to consider:

1. Do you proactively identify, measure and monitor major financial 1. Do you have a team that is independent of other business operations
and non-financial risks to business? that is responsible for risk management?

2. Do you have risk management practices including policies, 2. Do you have appropriate policies, processes and governance to ensure
governance in place to mitigate / manage the identified risks? their independence?

Assessment notes: Assessment notes:

Area(s) of improvement: Area(s) of improvement:

43 44
 Activity Sound Practices Rating

Sourcing dore 1. I promise to conduct “Know Your Provider” checks and record O / BO / PO / NO
all the relevant information about my suppliers before
onboarding new suppliers
I promise to comply with all applicable laws and regulations,
17 maintain adequate documentation and disclose required
2. I promise to only procure dore which adheres to industry
accepted standards, conduct independent tests to ascertain
O / BO / PO / NO

information to regulatory/statutory bodies the characteristics and document details for each transaction

Current state: 3. I promise to adhere global responsible sourcing guidelines as O / BO / PO / NO

well as consider ESG credentials (Environment, Social and
Governance) of suppliers (Additional best practices)
Observed Broadly observed
Recycling/ 4. I promise to design, convey and practice a fair policy for O / BO / PO / NO
Partly observed Not observed Purchasing of old gold purchase and collect KYC details of sellers of old gold
Old Gold 5. I promise to buy / service recycled gold only upon conducting O / BO / PO / NO
independent tests to ascertain characteristics of the gold and
Key questions to consider: documenting details of the scrap gold

1. Do you comply with laws and regulations that are applicable to your Refining 6. I promise to ensure that the refined products meet the dimension, O / BO / PO / NO
business operations (dore import, refining, etc.) in India? weight, finish, homogeneity and purity standards as characterized
by markings and commitment to the customers
2. Do you maintain records and documentation for all compliance and audit
procedures? Does it include details of audit findings, queries from regulator, 7. I promise to be compliant with labour laws and provide requisite O / BO / PO / NO
events of non-compliance and corresponding actions taken? infrastructure, safety equipment, benefits and training to
my employees
3. Do you conduct internal audits and record its findings for reasonable period? 8. I promise to have mandatory industrial licenses/approvals O / BO / PO / NO
Do you hire professional auditors without any conflict of interest to conduct as per applicable regulations
external audits?
9. I promise to maintain traceability of gold items throughout the O / BO / PO / NO
refining process from the point of supply to delivery to
4. Do you disclose this information to customer or regulatory authorities when
my customers
requested? Do you also publish audit results in public domain to enhance
credibility of your practices?
Transportation 10. I promise to have adequate operational protocols to safely store O / BO / PO / NO
and Storage and transport valuables (dore, recycled gold, refined gold
Key comments: products, cash, precious metals)

Customer and 11. I promise to adhere to appropriate KYC requirements while O / BO / PO / NO

Complaints on-boarding new customers and update this information
Management periodically

12. I promise to implement adequate systems and mechanisms O / BO / PO / NO

to receive, record and redress customer queries and complaints

13. I promise to educate customers about testing procedures, O / BO / PO / NO

refinery markings or point them to credible sources
of information

Area(s) of improvement: Payments 14. I promise to clearly communicate and adhere to terms, O / BO / PO / NO
conditions and timelines of payments with every customer
and supplier, consistently and impartially

Risk 15. I promise to proactively identify major financial and non-financial O / BO / PO / NO

Management risks to the business and take appropriate steps to mitigate
/ manage the risks

16. I promise to have a dedicated and trained risk management team O / BO / PO / NO

without linkage to any business incentives (Additional best practices)

Audit and 17. I promise to abide by the law of land and disclose required O / BO / PO / NO
Compliance information to designated statutory bodies in time
45 46
 Annexure B: Version control Notes
The Code of Conduct is a continuously evolving document intended to
incorporate latest and best practices in the industry. The below table
reflects the history of updates and latest version of the document

S.No. Version Number Timeline

1. Code of Conduct_Refining_vMar2021 Mar, 2021

47 48