This report sets out the measures implemented by Spuerkeess (hereinafter «the Bank») with regard to responsible management of the supply chain in minerals and gold coming from conflict-affected or high-risk areas.
This report has been drawn up under the terms of Regulation (EU) 2017/821, Article 7, Paragraph 3.
The measures in place to comply with the obligations relating to the management system, as set out in Article 4 of Regulation (EU) 2017/821, are the following:
- Implementation of the supply chain policy and communication of the policy to suppliers and to the public (website www.spuerkeess.lu).
- Integration in the policy of principles governing the exercise of due diligence, under point III. COMMITMENTS:
- Implementation of a procedure that clarifies the management structure responsible for supervision of the processes relating to the management system and maintaining related documentation.
- Incorporation of the supply chain policy into any contracts or agreements with suppliers.
- Implementation and communication of a complaints processing system, under point VI of the policy: REPORTING & TRANSPARENCY.
- Production of a statement of all imports to enable traceability of the supply chain, showing evidence of compliance with the policy.
The measures in place to comply with the obligations relating to risk management, as set out in Article 5 of Regulation (EU) 2017/821, are the following:
- the Bank imports exclusively from smelters that are certified compliant by an approved external auditor.
- the Bank’s import suppliers certify that they source supplies exclusively from LBMA-certified smelters (including an audit by an independent third party).
Consequently, the Bank assesses the risk to the Bank’s supply chain as being very low.