Responsible Minerals Policy
A risk-based policy informed by international expectations for human rights, conflict, corruption, environment and traceability in mineral supply chains.
1. Policy objective
GMZ seeks to avoid facilitating mineral activities linked to serious human-rights abuse, conflict financing, bribery, money laundering, unlawful armed groups, environmental harm or fraudulent origin claims.
2. Risk-based due diligence
Members should identify and prioritise the most significant actual or potential impacts in operations, supply chains and business relationships, then prevent, mitigate, track and communicate responses proportionate to risk.
3. Supply-chain information
- Mine or origin location where relevant and lawful.
- Producer, exporter, trader, processor, refinery and transporter identities.
- Licence, tax, customs and shipment documentation.
- Product description, quantity, assay and custody records.
- Beneficial ownership, payment route and unusual intermediaries.
4. Conflict-affected and high-risk areas
Enhanced review may be required where armed conflict, political instability, repression, weak governance, corruption, organised crime or serious human-rights risk is present. Responsible engagement and risk mitigation may be preferable to automatic disengagement, depending on the facts and professional advice.
5. Environmental and community considerations
Relevant review may include water, emissions, waste, tailings, biodiversity, closure, land access, labour, health and safety, indigenous peoples, local communities, grievance mechanisms and security practices.
6. Traceability and assurance
Traceability tools, certifications and audits may support due diligence but do not automatically prove responsible origin. Their scope, methodology, independence, chain of custody and limitations must be understood.
7. Response to identified risk
GMZ may request additional evidence, condition access, pause an introduction, seek remediation, reject a listing or terminate engagement. Serious concerns may be reported where law requires or permits.
8. Continuous improvement
Responsible sourcing is an ongoing process. Members should retain records, review suppliers and update risk assessments when jurisdictions, counterparties, products or routes change.
