LIMURA’S RESPONSIBLE SOURCING POLICY
Limura are aware of the risks of inadvertent involvement in or contribution to immoral and unethical practices that may be associated with the extraction, processing, trading, handling, and exporting of precious metals and gemstones from any area, but more specifically, from Conflict-Affected and High-Risk Areas (CAHRAs). Limura’s Responsible Sourcing Programme embeds a number of core corporate policies and principles, as well as the recommendations of the OECD’s Due Diligence Guidance for Responsible Supply Chains (“OECD Guidance”).
Precious metals & gems supply chain policy
Regarding serious abuses associated with the extraction, handling, processing, transportation and trade of precious metals and gemstones: Suppliers should not profit from, contribute to, assist with or facilitate the commission of the following serious abuses:
- torture, cruel, inhuman and degrading treatment;
- forced or compulsory labour;
- the worst forms of child labour;
- other gross human rights violations and abuses.
Regarding risk management of serious abuses: Supplier to suspend or discontinue engagement with upstream suppliers where they identify that they are sourcing from, or linked to, any party committing serious abuses as defined in paragraph above and where attempts to mitigate such impacts have failed. Regarding public or private security forces: Supplier to screen public or private security forces to ensure that individuals or units of security forces that are known to be responsible for gross human rights abuses will either not be hired, in the case of “individuals”, or required to demonstrate measures to mitigate the likelihood of such impacts occurring in future, in the case of “units”.
Regarding bribery and fraudulent misrepresentation of the origin of minerals: Supplier to devise, adopt and implement policies and procedures designed to prevent or mitigate the risk of bribery and/or the solicitation of bribes to conceal or disguise the origin of metals and gems associated with the extraction, handling, processing, transportation and trade of precious metals and gemstones. Regarding money laundering: Supplier to devise, adopt and implement policies and procedures designed to prevent or mitigate the risk of money laundering resulting from, or connected to, the extraction, handling, processing, transportation and trade of precious metals and gemstones. Regarding the payment of taxes, fees and royalties due to governments: Supplier to devise, adopt and implement policies and procedures designed to ensure that all required taxes, fees, and royalties are paid to governments in accordance with the supplier’s position in the supply chain.
Precious metals and gemstones origin rules
Limura has established internal sourcing procedures that aim at ensuring that the mining and sale of the precious metals & gemstone purchases have not directly or indirectly contributed to abuses of human rights, terrorism financing, conflict, irremediable environmental degradation, and that they fully comply with anti-money laundering standards.
Materials from African origin
When sourcing/considering sourcing of materials of African origin, Limura directly conducts the risk assessment and management, and deals directly with the Africa-based entity. Africa- based entities are subject to enhanced due diligence (EDD).
All business partners are required to provide the related procedures of their KYC, AML/CFT, and KYP so that we can verify that they aligned with Limura’s procedures. Limura does not accept materials from sanctioned countries.
If Limura has reason to believe that the sourcing practices of a supplier are not aligned with these expectations or applicable international and host country laws and regulations, Limura may ultimately choose to exit the relationship.
Modern slavery statement
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. Limura acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. Limura has a zero tolerance policy towards modern slavery and will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
- human trafficking;
- forced work, through mental or physical threat;
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
- being dehumanised, treated as a commodity or being bought or sold as property;
- being physically constrained or to have a restriction placed on freedom of movement.
Limura is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains, and to acting ethically and with integrity in all its business relationships. Limura has policies which aim to minimise the risk of modern slavery in our business. These include Due Diligence: Limura monitors suppliers that it believes present high modern slavery risks in its supply chain.
Limura is responsible for assessing the information submitted by suppliers. Should a supplier fail to provide the information requested or to meet its expectations, Limura will take appropriate action, which may include not entering into a relationship or terminating the relationship with the supplier concerned.