Our compliance and transparency standards are the foundation on which the trust of our employees and customers as well as other stakeholders is built. Earning and maintaining this trust is the basis for our success. It requires an unwavering commitment to integrity and good business practices.
We value long-term relationships over short-term profits and have always ensured that processes are transparent and auditable. Our approach to compliance has three aspects: prevent, detect, and respond. Our highest priority by far is prevention.
Our approach
At Argor-Heraeus, we believe in the power of strong and accountable governance to drive our company forward. Our governance framework, policies, and guidelines far surpass the requirements of the law. Our corporate policies and procedures serve as clear guidelines for our employees. With a strong focus on transparency and responsibility, these policies ensure that we collaborate solely with partners who share our commitment to responsible business conduct.
It is essential for us to maintain a high standard of operation which is why we hold certifications from prominent national and international organizations. Our supply chain management system undergoes rigorous internal and external audits conducted by expert professionals to ensure compliance with rules and standards.
Governance
The Argor-Heraeus governance system, incorporated and aligned with that of the Heraeus Group and Heraeus Precious Metals, aims to ensure compliance with all laws, regulations, standards as well as internal policies and guidelines.
Our Guiding Principles
Our guiding principles are the cornerstone of our culture. They serve as a general orientation and guide as to how we conduct our business. These principles define behaviors and mindsets that are essential for successful cooperation with our partners, customers, and within our company.
We expect all employees worldwide to bring our core values to life and therefore work continuously to ensure their implementation and ongoing development.
We concentrate on our
customers’ needs.
We communicate clearly
and respect each other.
We foster different
perspectives
and diverse teams.
We continuously
want to get better.
We are responsible for
our success and failures.
We care about people
and our planet.
Company policies and rules
Our corporate policies and rules play a key role in facilitating the daily decision-making of all employees.
We regularly update these documents and ensure that our employees receive all necessary training on them.
Code of Conduct
- Respect for human rights
- Environmental protection
- Ensure fair competition
- Fight against corruption
- Fight against money laundering and terrorist financing
- No activity or infringement against the prescriptions of national, international or supranational organizations
- Avoid conflicts of interest
- Creating and maintaining safe and fair working conditions
- Compliance with data protection laws
Complaint Management Policy
- How to present complaints
- Anonymous reporting and whistleblower protection
Guidelines for the Prevention of Corruption
- Prohibition of cash gifts
- Alignment of performance with applicable law and clients' internal rules
- Approval required for gifts that exceed a certain value
Guidelines for Concluding Consultancy and Distribution Agreements
- Risk assessment
- Obtain a self-declaration from the consultant in case of high or medium risk
- Approval requirements for high- or medium-risk consulting or distribution contracts
- Insist on a written agreement
- Prohibition of payment of remuneration to third parties/to an account located in a third country
- Repeat risk assessment after 1-5 years depending on risk class
Guidelines for the Prevention of Money Laundering
- Prohibition of accepting and making payments in cash
- Approval process for third party payments and payments from or to countries where the business partner is not registered
- Process of due identification of business partners
- Communication of suspicions in compliance with the law
- Classification and monitoring of business partners and transactions in compliance with applicable legislation and standards
Guidelines for the Prevention of Antitrust Violations
- Prohibition of price agreements, price reductions or target prices
- Prohibition of market sharing and customer sharing
- No sharing of strategic information with competitors
- No resale price fixing
- Prohibition of abuse of a dominant position on the market
Guidelines on the Protection of Personal Data of Heraeus Employees
- Obligation of employees to treat personal data confidentially
- Measures to ensure the confidentiality, availability and integrity of personal data
Human Rights Policy
- Prohibition of child labor
- Prohibition of forced labor
- Non-discrimination
- Freedom of association and collective bargaining
- Job security
- Human rights in the supply chain
- Human rights due diligence obligations
Supply Chain Due Diligence Policy
- No relationship with entities related to human rights violations
- No relationship with partners who may in turn be linked to entities that violate human rights, including child labor
- No relations with armed non-state groups
- No relationship with partners who may themselves be linked to armed non-state groups
- No tolerance for bribery, lack of transparency to obtain benefits of any kind
- Active effort to prevent or expose money laundering or terrorist financing in our industry-related activities
- Compliance with applicable regulations and sanctions lists
- Attention to environmental aspects and ESG factors in general
Supply Chain Due Diligence Policy
- No gift with a price exceeding 50 euros
- No coverage of travel or accommodation expenses by business partners
Accreditations and certifications
Accreditations and certifications are an external and impartial testimony of the quality of the work we carry out every day, and of our responsible business conduct. We are certified by the major schemes in the sector for work and product quality, processes, and specific topics such as management of the value chain, environment, and safety.
Among others, we:
- are a founding member of the SWISS BETTER GOLD INITIATIVE, to continuously support the artisanal and small-scale mining;
- support the FAIRMINED and FAIRTRADE initiatives, which enhance certification;
- are a member of the LONDON BULLION MARKET ASSOCIATION, with a seat in the refiners’ committee, participating in the definition of the Responsible Gold Guidance;
- are a member of the RESPONSIBLE JEWELLERY COUNCIL, with a seat in the standards committee;
- have held a Melter & Assayer license already since 1952 to guarantee the authenticity, purity and origin of precious metal bars. The assayers report directly to the Swiss Precious Metals Control Office to ensure their independence.
We hold accreditations and certifications from the following bodies and are active members of several industry associations:
- European Precious Metal Federation (EPMF)
- Fairmined
- Fairtrade
- International Platinum Group Metals Association (IPA)
- International Precious Metals Institute (IPMI)
- ISO (45001, 19001, 14001, 17025)
- London Bullion Market Association (LBMA)
- London Platinum and Palladium Market (LPPM)
- Precious Metals Control Office (PMCO)
- Responsible Jewellery Council (RJC)
- Responsible Minerals Initiative (RMI)
- Swiss Association of Manufacturers and Traders in Precious Metals
- Swiss Better Gold Association
- Watch and Jewellery Initiative 2030
Verification of business partners
We thoroughly investigate each and every potential partner before entering into a business relationship.
Our company prioritizes the rigorous protocols known as “know your…” (customer, customer’s customer, business, bank, carrier, etc.) which apply to all potential partners and clients. These protocols include a comprehensive evaluation of economic, environmental, and social criteria to ensure the highest standards of integrity and responsibility. Factors we evaluate include the absence of corruption, respect for human rights, no tolerance for child or forced labor, a commitment to the well-being of local communities and indigenous populations, and social and environmental practices.
To uphold our stringent standards, we have numerous measures in place.
These include:
- Conducting regular on-site visits and performing mine audits, complemented by third-party verifications.
- Screening all information for irregularities, for example regarding ownership, general plausibility of the business model and origin of metals.
- Determination and assessment of the delivered precious metals.
- Screening for sanctions and monitoring adverse media publications to verify partners’ compliance with human rights laws.
- Engaging with legislators, NGOs, industry associations, unions, communities, and local governments.
If upstream precious metal suppliers do not meet our standards, we refuse to enter a business relationship with them. We terminate existing relationships if violations are detected that cannot be resolved or corrected. These stringent controls and evaluations are applied universally across all our global offices and operations.
By consistently adhering to these demanding protocols, we ensure that our partnerships align with our values of transparency, ethics, and sustainability. Through our robust evaluation processes, we actively cultivate responsible business relationships that have a positive impact on our stakeholders and the communities we serve.
Responsible precious metals sourcing
At Argor-Heraeus responsible sourcing of precious metals is a top priority. We are proud to hold certifications from the leading frameworks in responsible precious metals sourcing including RMI, RJC, LBMA, and LPPM. These certifications demonstrate our commitment to adhering to the highest industry standards.
But our dedication to responsible sourcing goes beyond mere compliance. We have developed our own policies and processes that surpass regulatory requirements and industry frameworks. By setting stricter standards, we aim to promote their widespread adoption throughout our supply chain and the entire industry.
By collaborating closely with our mining partners, we strive to have a positive impact on the people, environment, and communities in the countries of origin. We actively work to mitigate any potential negative effects, ensuring that the precious metals we receive for refining not only meet responsible business principles but also contribute positively to the well-being of all involved.
By partnering with supranational bodies, governments, and sector associations, we actively contribute to finding solutions to the challenges we face. We participate in working groups, committees, associations and task forces dedicated to enhancing the solidity and transparency of our sector. Together, we strive to define new guidelines, regulations, and best practices that shape the future of our industry.
Grievances
The NGO Human Rights Watch approached Argor-Heraeus with a case from previous years regarding the mining company Midroc in Ethiopia. We stopped our business relationship with Midroc in 2018, on the day our monitoring systems first detected negative public reporting. At all times we have fully complied with the applicable due diligence requirements of the OECD, the Independent Precious Metals Authority LBMA, and the Responsible Jewellery Council (RJC). The studies quoted by Human Rights Watch were produced only after the situation became known and we had already ended our relationship with Midroc. Over the past years, several organizational and process changes were implemented to respond more directly to risks in our value chain.
Since being contacted by Human Rights Watch, we have maintained regular contact through 2023 to evaluate and implement potential improvements. The report by Human Rights Watch on Midroc was published in 2023, resulting before and after the publishing date in clarifications processes with LBMA, RJC, the Watch & Jewellery Initiative 2030, but also several of our clients.
Argor-Heraeus takes suspected violations of human rights, criminal law, environmental law, and other laws and regulations very seriously. We have a grievance and whistleblowing policy in place and we encourage whistleblowers and stakeholders to report suspected violations and concerns anytime via
our compliance hotline or external ombudsman. Reports can be made anonymously.
Report a concern: argor-heraeus.com/grievances
Projects and initiatives
Tracing, tracing, tracing
In the world of precious metals, the significance of the phrase “gold is gold” has undergone a momentous shift. Today, traceability has become a key issue in the industry, and we dedicate significant resources to address this critical matter.
One such initiative involves collaborating closely with our partners to develop traceable products sourced solely from carefully selected mines or secondary sources. Our production lines operate with complete independence, ensuring that the precious metal of our clients undergoes processing on a segregated production line, never coming into contact with other precious metals.
This process assures our customers of the origin and quality of their precious metals and also sets a new standard for responsible sourcing in the precious metals industry.
Technologies for traceability
Argor-Heraeus has worked for many years to make gold easier to trace. We have used DNA labeling technology since 2019, ensuring traceability of raw materials between the mine and our refinery.
In 2022 we entered into partnership with Alitheon, a U.S.-based company that specializes in using artificial intelligence (AI) to authenticate physical products. Its AI optical software generates a digital twin of gold bars based on more than 1,000 of their unique surface details. The result is a digital fingerprint that makes gold bars identifiable and traced even if their stamps or serial numbers are effaced, or records of the numbers are lost.
The challenges of the sector must be faced together
In our sector, we recognize that addressing the significant challenges we face requires collaborative efforts between various stakeholders. Private companies, industry associations, governments, institutions, and NGOs must come together to drive meaningful change and make a lasting impact.
We have established a “Sounding Board” made up of representatives from the corporate, academic and NGO sectors. Together, we discuss topics concerning responsibility with the goal of refining our practices, so that we can ensure we are continuously striving for excellence in our business conduct.
We also actively seek out collaboration with NGOs that have a strong interest in our industry. By engaging with these organizations, we tap into their expertise and perspectives, leveraging their insight to identify areas for improvement. This collaborative approach strengthens our commitment to responsibility and facilitates the development of innovative solutions that benefit both our industry and the wider community.
