What is a smelter of high concern?

Source Intelligence has identified key criteria that define a smelter of high concern. These criteria include, but are not limited to geolocation, reputation, supply chain footprint, and history of human rights violations. Here are some recently identified smelters of high concern you should be aware of.

Elemetal Refining, LLC

CID001322

Formerly known as “Ohio Precious Metals”, Elemetal Refining, LLC has been accused of money laundering as of early 2017. Elemetal LLC is the parent company of NTR Metals, which was found to smuggle at least $3 billion worth of Peruvian gold. As of December 2017, the facility has ceased operations. Click here for more information.

Kaloti Precious Metals

Location: Dubai, UAE

CID002563

UAE is an RMI Level 2A country, meaning it is a known or plausible destination of smuggled or exported gold from conflict regions. Kaloti Precious Metals was removed from the Dubai Multi Commodities Centre (DMCC) “Dubai Good Delivery List” in 2015.

African Gold Refinery (AGR)

Location: Entebbe, Uganda

CID003185

This smelter is located in the covered countries and sourcing gold from the region. Tony Goetz, N.V., another smelter of concern, is also AGR’s majority shareholder.

Fidelity Printers and Refiners LTD

Location: Harare, Zimbabwe

CID002515

The US Department of Treasury has sanctions against certain entities doing business with the Government of Zimbabwe. Fidelity Printers has (or had) relations with one such entity. Additionally, four bosses at Fidelity Printers were accused of fraud in 2015.

Jiangxi Copper Co., LTD

CID000855

The Taliban has offered “security” protection for the Mes Aynak copper mine project in Afghanistan. Investigation is ongoing to assess Jiangxi Copper’s involvement with Mes Aynak. Mes Aynak has yet to start production but Jiangxi Copper has invested billions of dollars in the project. Click here and here for more information. 

Sudan Gold Refinery

Location: Khartoum, Sudan

CID002567

The US Department of Treasury has a trade embargo on Sudan for violations of human rights. In addition to embargoes, The Enough Project released this report in 2015 explaining the concerns around Sudan’s gold trade. Click here for more information.

Tony Goetz N.V.

Location: Antwerp, Belgium

CID002587

According to this report published in 2012 by The Enough Project, “The U.N. Group of Experts documented in 2009 how a Belgian gold refinery —Tony Goetz […] —purchased gold from eastern Congo and was linked to the major Burundian smuggler of Congolese gold, Mutoka Ruganyira.” In February 2016, Tony Goetz N.V. formally obtained the Dubai Good Delivery and Market Deliverable Brand certifications, accredited by Dubai Multi Commodities Centre officials. Tony Goetz, N.V. also underwent an independent audit by Grant Thornton for their processes from January 1, 2014 to December 31, 2014. Grant Thornton determined that Tony Goetz N.V.’s compliance controls gave “’reasonable’ but not absolute assurance” that the processes were followed. Click here for more information.

Yunnan Tin Company LTD

Location: Geiju, China

CID002180

Yunnan Tin Company is reported to have involvement with the United Wa Army, a Burmese (Myanmar) insurgency group. Reportedly, the mine is controlled by the United Wa State Army (UWSA), which the United States placed under sanctions for alleged narcotics trafficking in 2003. Companies extracting tin from the mine are all owned or controlled by Wa military, government leaders, Wa officials, and people with close ties to UWSA.

Britannia Refined Metals and CCR Refinery - Glencore Canada Corporation

Britannia Refined Metals Location: Gravesend, UK

CID000170

CCR Refinery – Glencore Canada Corporation Location: Quebec, Canada

CID000185

Britannia Refined Metals and CCR Refinery – Glencore Canada Corporation are both owned by Glencore PLC, a Swiss multinational commodity trading and mining company. A French-led investigation into the Paradise Papers revealed in 2017 that “Glencore secretly loaned tens of millions of dollars to an Israeli billionaire after it enlisted him to secure a controversial mining agreement in the Democratic Republic of the Congo.” Of note is that at this time, SI is unable to validate the veracity of the findings of this investigation. Click here for more information.

Information updated – December, 2017

So, what can you do if you find a smelter of high concern in your supply chain?

1. Confirm the smelter data 

Confirm the smelter data: Contact your supplier(s) associated with the smelter of high concern to make sure they are in fact sourcing from that smelter. You may also check if the smelter of high concern is used specifically for the product(s) supplied to your company.

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2. Develop Corrective Action Plan 

The OECD Due Diligence Guidance outlines steps to mitigate risk involved in working with smelters of high concern. Develop a plan with your suppliers to work through the problem with the smelter.

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3. Educate and improve processes 

The most crucial step for mitigating risk is to work with and educate the supplier and smelter on the correct processes to work by and work as a team to mitigate the risk. Educating suppliers is not an easy process, but once achieved can lead to a strong, long lasting relationship that is beneficial for both parties.

Need help identifying and verifying smelters in your supply chain? 

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