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.
I. Management system:
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:
https://www.spuerkeess.lu/en/about-us/sustainability/csr-policy-of-spuerkeess - 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.
II. Risk Management:
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.
