Date: February 4,2015
To: Ms. Juliane Kippenberg
Senior Researcher
Children's Rights Division
REFERENCE TO YOU LETTER DATED 19TH DECEMBER 2014
Dear Ms. Juliane
Greetings from Kaloti Precious Metals
We have received your above captioned letter regarding your research on child labor, environmental, and health issues in the Ghanaian gold mining industry and we highly appreciate your work in this area. We thank you for sharing with us the preliminary findings of your research and inviting us to contribute in your ongoing research and take this opportunity to submit the following information in relation to our company:
1. Kaloti Precious metals only deals with licensed suppliers from Ghana that are registered with the Minerals Commission of Ghana;
2. As a Dubai Good Delivery refinery, we are required to maintain robust supply chain due diligence as per with the DMCC Guidelines for Responsible Sourcing of Precious Metals that are based on the OECD principles (available on http://www.dmcc.aelgold-responsible-sourcing precious-metals). These guidelines also adequately address human rights and environmental issues and are an integral part of our compliance policy and procedures that can be viewed on our website (http://www.kalotipm.com/Sustainability);
3. Kaloti Precious Metals has an elaborate and independent compliance function that operates under direct supervision of the Board of Directors. Our compliance team constantly monitors any updates on country risk ratings and reviews any new policies/regulations/notifications/reports with respect to human rights and environmental preservation from UN, Human Rights Watch, OECD, and other such global institutions. These updates are regularly incorporated in our compliance policies that are discussed, approved and monitored by our Board of Directors;
4. In addition to incorporating human rights and environmental regulations in all practical aspects of our supply chain due-diligence mechanism, we educate our suppliers by sharing with them our compliance policies and procedures, elaborating them to our suppliers, and ensuring that our suppliers maintain full compliance with the same. We duly notify the regulator of any suspicious cases or non-complaint suppliers and seek disengagement with the suppliers that do not satisfy our compliance requirements;
5. While operating in regions such as Western Ghana and especially before directly I indirectly dealing with suppliers in any region, Kaloti Precious Metals conducts site visits as part of the continual due-diligence procedure which includes identification of all suppliers in the chain of custody, mining and processing procedures with an aim to identify environmental risks, signs of child labor in the workforce, local market and government opinion on the mining company and its practices, documentary proof of physical presence, mining licenses, documents on beneficial owners, compliance related declarations from beneficial owners etc. We do not take any mining company onboard without a satisfactory completion of a rigorous compliance check. Site visits to Ghanaian suppliers is conducted once a year with the last visits completed in June 2014. During our latest visit we also met Government officials who assured us of their procedures and monitoring activities to eliminate child labor in the Ghanaian mines. Therefore, we have eliminated any risk pertaining to Child Labor or any Human Rights abuses in our supply chain; amongst other regulatory compliance related aspects. Kaloti will be conducting another round of site visits in Ghana in the second quarter of this year to ensure that all aspects of responsible sourcing are intact and to further educate our suppliers of the importance of maintaining and practicing our responsible sourcing policy and procedures;
6. Kaloti Precious Metals has a robust TRACK-AND-TRACE mechanism in place and engages in tracing the origin of gold back to the mine in all cases whether in Ghana or any other country of origin;
7. Kaloti Precious Metals maintains proper documentation on all its suppliers and their transactions for a period of 5 years and constantly updates this information. This documentation is verified and reviewed during our annual statutory supply chain audit in accordance with DMCC Review Protocol (available on http://www.dmcc.ae/gold-responsible-sourcing-precious-metals);
8. Kaloti Precious Metals has been audited against DMCC Guidelines for responsible sourcing of minerals which are based on the OECD principles; with the last audit completed in August 2014 by an independent and internationally reputed third party firm 'Grant Thornton'. We are happy to report that Kaloti Precious Metals is Fully Complaint with DMCC Guidelines for responsible sourcing of precious metals. Our latest Audit Reports can be viewed on our website (http://www.kalotipm.com/Sustainability).
We hope that you will find the above information in order and useful for the purpose of your research. We look forward to viewing your report the subject of which bears significant importance for us.
Sincerely,
Dina Kaloti
Director of Compliance
