Conflict Free Metals Policy

By: Joe White | President

On August 22nd of 2012, the US Securities and Exchange Commission (SEC) released the final rule for Section 1502 on Conflict Minerals in the Dodd ‐ Frank Act. Section 1502 is a provision regulating the trade of gold. Compliance with this provision impacts manufacturers, distributors, wholesalers and retailers within the jewelry industry. As part of this legislation, certain companies who file reports with the SEC, will be required to provide annual disclosures in regards to their use of conflict minerals defined in sec 1502. The deadline for the first disclosure requirements will be May 31, 2014 (for the 2013 calendar year). It is important to note that this law does not apply to minerals which were outside of the supply chain prior to January 31st of 2013 – i.e., minerals that were smelted or fully refined, or were outside of the DRC or other adjoining countries covered by the law.

LeachGarner remains committed and focused on our leadership role in working with stakeholders and industry peers to develop sustainable, practical solutions that create transparency in the supply chain and promote responsible sourcing of minerals. The LeachGarner chain ‐ of ‐ custody process continues to be the platform of our sustainability and accountability efforts and programs.

Currently LeachGarner is in compliance with the following criteria:

  • Only accept gold from refiners on the LBMA good delivery list, EICC/GeSI conflict –free compliant smelter list, certified members of the Responsible Jewellery Council or refiners which certify and independently audit that all gold supplies are conflict free, in accordance with one of the following standards: RJC chain of custody standard, OECD Responsible Supply Chain of Minerals from Conflict ‐ Affected and High Risk Areas Supplement or the World Gold Council Conflict ‐ Free Standard.
  • Only accept gold from Banks which certify and independently audit that all gold is supplied from Refineries which adhere to the refinery compliance requirements listed above.
  • Only accept gold from Precious Metals Trading Companies which certify and independently audit that all gold from Refineries and / or Banks which adhere to the Refinery & Bank compliance requirements listed above.

LeachGarner is currently performing due diligence with all of its metal sources in regards to the following criteria:

  • Only accept scrap and/or recycled gold from customers or suppliers which certify and independently audit that all scrap and recycled gold is identifiable as its own production and supply, i.e. scrap gold is returned product from customers, faulty inventory or scrap generated during the production process.

Our commitment to supporting this policy re ‐ affirms our dedication to the industry, to lead not only in technology, innovation and quality but also in the pursuit of being a responsible global citizen.

Regards,

Joe White
President