This presentation was made by Argor-Heraeus Group during the session "Progress in fostering mineral supply chain transparency in Colombia" of the 9th Forum for Responsible Mineral Supply Chains, held in Paris on 4-6 May 2015. Find out more at http://mneguidelines.oecd.org/icglr-oecd-un-forum-paris-2015.htm

1. ARGOR-HERAEUS Group
The golden link
High-tech precious metals processing

2. Origin of Gold for fabrication
• Sources of Gold for fabrication:
• Primarily produced Gold from
• Large scale mining
• Small scale / artisanal mining
• Recyclable Gold from
• Industry
• Private sector
• Trade
• Investment sector
• Grandfathered Gold from
• Private sector
• Investment sector

3. Challenges of the Branch
• Sourcing
• Origin: World wide
• Quality: Various kinds of material
• Suppliers: Various
• Industry
• Investment
• Private sector
• Request from market: Must be
• Transparent
• Traceable
• Clean / ethical
• Cost of production

4. Precious metals flow
Products
ARGOR-HERAEUS SA
Recycled Gold
Grandfathered
Gold
Mines
TransformationRefining
Products for:
- Investment
- Industry
- Jewellery
Sourcing
Precious Metal Services

5. Identification of risk in the value chain
ARGOR-
HERAEUS
Trader /
Bank
Trader /
Bank
Manu-
facturer
Consu-
mer /
Retail
Gold for
fabrication
Material flow
Money flow
Grand-
fathered
Recyclable
Primarily
produced
=
=
=

6. Our commitment
company level
Code of Conduct
Accreditations & Certifications
Policy of Compliance and Ethics
Swiss – and international legislation
supply chain level
industry level
Supply Chain Due Diligence Policy
LBMA – RJC – WGC - OECD

7. Employees AH Group Internal rules
Good delivery Refiner LBMA Gold Guidance / RJC CoC
Financial intermediaries directly subordinated
to FINMA
ORD – FINMA (Swiss Financial Market
Supervisory Authority)
Bank and non-bank financial
intermediaries
Law – AMLA (Anti-Money Laundering Act)
Melter Assayer
ORD – PMCO (Precious Metals Control Ordinance)
Melter Assayer
Law – LPMC (Law Precious Metal Control)
Everyone Penal code
Applicable to: Regulations
Pyramid of rules & regulations

8. Tools used by Argor-Heraeus
Governance structure and functional responsibility
Policies and procedures
Ongoing training programs
Internal – and external information system
Grievance system

9. Decision escalation
Governance structure and functional responsibility
Board of Directors
General Management
Compliance officer
Compliance Auditor
Operational Division Management
Account Managers
Back office staff
Receiving and Shipping
Due Diligence Referent
Accounting & Administration
Risk Audit Committee

10. Tools used by Argor-Heraeus
Policies and procedures
Clear and restrictive counterparty opening process
Double-entry precious metals accounting system
Storage of all documents of each transaction for 10 + 1 years
System escalation
Control system of transactions
Continuous relationship and transaction monitoring during the life cycle of a business relation
Ongoing training program
Training of all key people involved in the CoC
Employee policy and information system
Clear employee policy with information system top down – bottom up (grievance procedure)
Material monitoring
Continuous analysis of material quality (fingerprinting)
Monitoring of quantity and composition of each delivery
Assessment of the physical aspect of the delivered material

11. • FAFT Financial Action Task Force
• EICC Electronic Industry Citizenship Coalition
• GeSI Global e-Sustainability Initiative
• OECD Organisation for Economic Co-operation and Development
• LBMA London Bullion Market Association
• RJC Responsible Jewellery Council
• WGC World Gold Council
• DMCC Dubai Multi Commodities Center
• Dodd Frank Act, Section 1502 Conflict Minerals (DRC)
• AMLA Anti Money Laundering Act (= GWG)
• AMLAO Anti Money Laundering Act Ordinance (= GWV – FINMA = Geldwaschereiverodung)
• PMCA Precious Metals Control Act (= EMKG = Edelmetallkontrollgesetz)
• PMCO Precious Metals Control Ordinance (= EMKV = Edelmetallkontrollgesetz Verordung)
• NGOs
Institutions & Associations

12. LBMA Best Practice Toolkit
 Recycled Gold
 Due Diligence Checklist
 KYC Questionaire
 Assessment Forms
 Mined Gold (Large scale, medium & small scale)
 Due Diligence Checklist
 KYC Questionaire
 Assessment Forms

13. Thank you
for your
attention