RJC Chain-of-Custody Certification
In March 2012, the RJC launched its Chain-of-Custody (CoC) Standard for the precious metals supply chain. The CoC Standard is applicable to gold and platinum group metals (platinum, palladium and rhodium).
The CoC Standard aims to support claims for responsibly-sourced jewellery materials (known as CoC Material) produced, processed and traded through the jewellery supply chain.
RJC defines responsibly sourced as:
— conflict-free as a minimum, and
— responsibly produced at each step of the supply chain.
This means that appropriate standards apply for human rights, labour standards, environmental impact, and business ethics: as articulated in the RJC Code of Practices, applicable to the jewellery supply chain from mine to retail. RJC can also recognise comparable standards from other initiatives under the CoC Standard, and has already done so for gold refiner due diligence audits and the artisanal mining sector.
Live webinar training on RJC CoC Certification for gold and platinum group metals is available to Members and Auditors. Please contact email@example.com for more information and any questions about the standards.
The RJC Chain-of-Custody certification documents, applicable to gold and platinum group metals, can be downloaded below. These documents can be used by interested companies to support the RJC CoC Certification process, or for general guidance about supply chain due diligence.
- Chain-of-Custody Standard
- Chain-of-Custody Standards Guidance
- Chain-of-Custody Certification Handbook
- Chain-of-Custody Assessment Questions and Evidence (revision 0.1)
- Chain-of-Custody Assessment Toolkit (Excel spreadsheet – revision 0.1)
- Outsourcing Contractors Assessment Form (Excel spreadsheet)
Also available: Download Frequently Asked Questions on Chain-of Custody Certification
For information on RJC’s continuing work on chain-of-custody and diamonds, click here.
Overview of the RJC CoC Standard for Precious Metals
- The CoC Standard is voluntary for RJC Members. It is also publicly available as a resource for good practice for chain-of-custody type systems.
- Companies throughout the supply chain – mine to retail – can be certified against the CoC Standard, using third party, RJC-accredited auditors.
- The CoC Certification Scope can be defined to cover all or some of a company’s Facilities, with one or more of gold, platinum, palladium and rhodium, in some or all of their production.
- Implementation of the CoC Standard is supported by a guidance document, assessment handbook, assessment toolkit (an audit protocol) and training.
Download a PDF Overview of the RJC CoC Standard (June 2012).
The CoC Standard sets out requirements for the identification and tracking of ‘Eligible Material’, which once declared by a CoC Certified Entity, becomes ‘CoC Material’. The following types of gold and platinum group metals are eligible to become “CoC Material”, and may be declared as such by CoC Certified companies:
- Conflict-free Mined Material produced by a CoC Certified Entity, by ASM on its concessions, or under a Recognised Responsible Mining Standard, or Mining Byproduct declared by a Refiner;
- Recycled Material sourced from Eligible Recyclable sources, screened according to KYC principles to avoid illegitimate sources;
- Grandfathered Materials in existence in their current form prior to 1 January 2012.
These different types of Eligible/CoC Material can be mixed. Certified companies must have systems in place to segregate CoC Material from non-CoC Material (either temporal and/or physical segregation), and to reconcile movements of CoC Material in their custody over a given time period.
CoC Material may be transferred by CoC Certified companies to other companies as CoC Material by issuing CoC Transfer Document containing information required by the Standard.
Recognised Responsible Mining Standards
- Part A of Fairtrade and Fairmined Standard:
The formal recognition of this ASM standard aims to further the work of the Alliance for Responsible Mining (ARM) and Fairtrade International (FLO) with certified artisanal and small-scale producers, particularly in conflict areas. The benefits for these producers will include expanded access to chain-of-custody pathways through to RJC’s Membership in the jewellery supply chain. RJC CoC Certified refiners can source from certified ASM producers, confident in the practices at the mine, and thus contribute to the further integration of ASM into the formal economy. This builds on the recommendations of the OECD Due Diligence Guidance – Supplement on Gold that all gold supply chain participants support legitimate ASM producers.
While the ARM-FLO partnership ended in 2013, RJC’s recognition of the standard is still in effect, pending the outcome of both ARM’s and FLO’s current standard review processes. It is anticipated that recognition of the producer component of each of the resulting standards will continue.
Download a Q&A – Click here
Due Diligence in the Supply Chain – OECD Due Diligence Guidance
Due diligence to support conflict-sensitive and responsible sourcing practices is of increasing importance to jewellery supply chains, particularly gold. The RJC CoC Standard allows for the tracking of gold and platinum group metals from their starting points in the supply chain, thereby reducing risk and avoiding the need to retrospective inquiries.
RJC CoC Certification can therefore assist companies to conform with the OECD Due Diligence Guidance, LBMA Responsible Gold Guidance and the EICC Smelter/Refiner Validation Program, and to comply with the provisions of the US Dodd-Frank Act (Section 1502, Conflict Minerals). Section 10 of the CoC Standard includes particular requirements for Gold Refiners to apply due diligence towards all sources of gold, in line with the OECD Due Diligence Guidance – Supplement on Gold.
Miners must determine by due diligence that mined material has not provided financial or other benefit to Illegal Armed Groups or their affiliates operating in a Conflict-Affected Area. Conflict is defined as “Armed aggression, widespread violence, and/or widespread human rights abuses”. Conformance with the World Gold Council (WGC) Conflict-Free Standard can be used by miners as objective evidence of appropriate due diligence for the RJC CoC Standard.
Any gold sourced from the DRC and adjoining countries must always be identified in CoC Transfer Documents. This is to assist Dodd Frank Act compliance for those companies impacted by the legislation.
A CoC Certified company will need to:
- Have a complaints mechanism for concerns about CoC Material.
- Have a supply chain policy for materials from conflict-affected areas. It should be communicated to suppliers and made publicly available.
- Consider the risks of non-compliance by its suppliers with its supply chain policy, and take action to prevent or mitigate the risks.
- Use the OECD Due Diligence Guidance as the key reference for due diligence screening for mined gold, particularly from conflict-affected areas.
The Responsible Jewellery Council, the London Bullion Market Association, the EICC-GeSI Conflict Free Smelter program and the Dubai Multi Commodity Centre have agreed to cross-recognise audits of gold refinery due diligence. The agreement aims to reduce duplication for refiners and to support broader supply chain efforts to implement Section 1502 of the Dodd-Frank Act for Conflict Minerals.
RJC’s recognition of the LBMA, EICC and DMCC audits as fulfilling parts of Section 10 of the RJC Chain-of-Custody (CoC) Standard is included in the CoC documentation published in March 2012. The LBMA, EICC-GeSI CFS and DMCC recognition of RJC CoC Certification for Gold Refiners means:
CoC Certified Gold Refiners will also be added to the EICC Conflict-Free Refiner list.
LBMA will accept RJC CoC Certification as demonstrating conformance with the LBMA Responsible Gold Guidance applicable to London Good Delivery refiners.
DMCC will accept RJC CoC Certified gold refineries as demonstrating conformance with the DMCC Practical Guidance and Review Protocol.
The additional benefit of RJC CoC Certification for refiners and their customers is how it can be used to differentiate types of gold sources (mined, recycled, grandfathered). The SEC rule for Dodd Frank has different supply chain inquiries and disclosure requirements for these different types of sources.
RJC welcomes enquiries from Gold Refiners and their stakeholders about RJC CoC Certification and the cross-recognition agreement.
Please note: Under the cross-recognition, all London Good Delivery gold is not automatically Eligible / CoC Material under the RJC CoC Standard. Other aspects of the CoC Standard continue to apply, including criteria for declaring Eligible / CoC Material.
Conflict-Free Due Diligence Assurance for Mining Companies
Due diligence carried out by mining companies in accordance with the World Gold Council Conflict-Free Standard can be used as objective evidence for the Due Diligence requirements of the RJC CoC Standard 4.2 under ‘Eligible Mined Materials’.
Refiners sourcing from mining companies who have implemented the World Gold Council Conflict-Free and Chain-of-Custody standards can use this as objective evidence for compliance of that supplier/material with RJC CoC Standard 10.4 under ‘Conflict-Sensitive Sourcing’.
More information on standards harmonisation can be found in the RJC Chain-of-Custody Certification Handbook and Standards Guidance.
Contact RJC for more information on RJC Chain-of-Custody Certification and how it can be used to support implementation of the OECD Guidance and the SEC rules: firstname.lastname@example.org