Supporting a gold refinery to meet audit requirements

Stack of gold bars

Supporting a gold refinery to meet audit requirements

Kumi was commissioned by a gold refiner in the United Arab Emirates (UAE) to advise the company on how to address non-conformance issues that had resulted in it failing a responsible sourcing audit.

With several responsible sourcing programmes having introduced significant changes to their standards in order to align with the recommendations of the OECD’s Due Diligence Guidance, a recent audit of this refinery – which had passed previous years’ audits with no major non-conformance issues – had found that some of its due diligence processes were not sufficient to meet the programme’s standards. Kumi was commissioned to determine whether the corrective actions that the refinery had put in place post-audit would be sufficient to meet the requirements of the responsible sourcing programme.

Stacked pile of gold blocks with one block on the top of the pile on its own

Review of the company’s supply chain due diligence processes

To deliver this work, Kumi’s responsible sourcing consultants first performed a desk-based review of the audit findings, the company’s existing due diligence policies and procedures and the corrective actions that had been undertaken post-audit. The team then undertook a site visit to the company’s operations in the UAE to interview senior management and compliance staff and review the company’s supply chain due diligence processes in depth.

Through this process the Kumi team identified several areas where the company’s supply chain due diligence processes were not aligned with the OECD’s recommendations (and hence programme requirements) and advised management on the specific changes that they needed to make to their due diligence processes and procedures.

The final step was to review the revised processes and procedures developed by the company and issue a report providing the conclusions of this review that the management team could provide to relevant stakeholders. Recommendations for further improvements to supply chain due diligence activities beyond the scope of the audit corrective actions were also provided to company management.

“Kumi advised us on how to address non-conformances identified during an RMAP audit, providing very clear guidance on how to update and strengthen our company’s responsible sourcing management system and due diligence processes. Thanks to Kumi, we have passed our latest audit!”

Jamie Belino, Compliance Officer, Al Etihad Gold DMCC

Stack of gold bars