Risk-based, by design
The OECD guidance asks companies to identify, assess, and document supply chain risk, then choose due diligence measures proportionate to that risk. Companies document the risk factors they find and the decisions they make about them. Critically, the framework does not promise 100% certainty of conflict-free status — it focuses on processes that identify, prevent, and mitigate risk based on available information, and on demonstrable, reasonable effort.
That distinction shapes everything downstream. A refiner cannot certify the unknowable; it can maintain a documented process that auditors, regulators, and financial markets accept as diligent. The guidance also expects constructive engagement with suppliers — working with them to progressively improve the chain and cut out its harmful parts, rather than abandoning whole regions at the first sign of risk.
The five steps
- Establish strong management systems. A supply chain policy, internal accountability, and record-keeping across every transaction.
- Identify and assess risk in the chain. Know the chain of custody, know each counterparty, and document risk factors — conflict financing, human rights abuses, provenance gaps.
- Design and implement a risk response. Mitigate with suppliers where progress is possible; disengage where severe abuses cannot be controlled.
- Independent third-party audit.In gold, audit assurance concentrates at the refiner and smelter — the chain's pinch point — rather than at every artisanal mine.
- Report annually. Public reporting lets downstream buyers rely on documented effort instead of repeating it.
CAHRAs: where the bar rises
Conflict-Affected and High-Risk Areas trigger the guidance's enhanced expectations. Sourcing from a CAHRA is not prohibited — the guidance exists precisely so legitimate producers in difficult regions are not cut off from formal markets. What changes is the depth of documentation: origin claims need evidence, counterparties need verification, and severe risks (the guidance's Annex II) demand immediate response, up to and including disengagement.
LBMA: the refiner's version of the same rules
The London Bullion Market Association's Responsible Gold Guidance implements OECD due diligence for the refiners that anchor the market. If a refiner cannot meet the standard, its gold is not accepted by the financial markets that rely on the accredited Good Delivery list. The LBMA's membership — roughly 130 trading houses, banks, refiners, miners, and fabricators — makes this the single strongest commercial incentive in the gold chain: provenance is not a nice-to-have, it is market access.
CRAFT: the artisanal on-ramp
Full OECD-style due diligence is unaffordable at the scale of an individual artisanal mine. The CRAFT Code (Code of Risk-mitigation for ASM engaging in Formal Trade) resolves this deliberately: the producer self-assesses against progressive modules and issues a CRAFT Report — its passport to formal markets — while verification responsibility sits with buyers, and independent third-party assurance concentrates at the refinery pinch point where the OECD expects it. Producers progress from Candidate to Affiliate as severe risks are shown to be controlled or measurably improving.
Supporting the people the frameworks are for
Responsible sourcing is ultimately about the regions the minerals come from. Artisanal mining is often the only livelihood available; gold economies in countries such as Ghana, Tanzania, and the DRC spread benefits well beyond the industry itself. A responsible gold supply chain supports those livelihoods while addressing environmental impact, worker safety, and fair compensation for communities whose land is affected by mining. Producing regions with less developed technical infrastructure need flexibility and investment, not exclusion — and the frameworks are explicitly built to allow both.