The Management Committee and the LPPM’s Compliance Team oversee the policy development and implementation of the Responsible Sourcing programme, for example the complaints mechanism and incident handling procedure.
The LPPM’s Compliance Team is responsible for the day to day running of the programme and participates in the compliance review process reporting to the Compliance Officer for the governance and development of the Responsible Sourcing programme. Non-conformances are escalated to the Compliance Officer for review and action. The Management Committee is notified of any action taken by the Compliance Officer.
Incident Review Process
The Incident Review Process is invoked in response to a particular stimulus of a reputational nature. Information can come from a variety of sources (trade associations, law enforcement agencies, market intelligence, etc.) and the LPPM will seek corroboration wherever possible as part of the process. Due to the sensitivities involved, the LPPM may keep the process confidential until the issue has been resolved.
Refiners can raise concerns about the process directly with LPPM. Complaints must be made in writing and be accompanied by supporting evidence. The Compliance Officer will review the details of the complaint and the outcome will be formally communicated to all interested parties.
Failure to meet the standards required could have serious implications for LPPM Good Delivery refiners. Sanctions could include suspension subject to resolution or being transferred to the Former List with immediate effect.
It is vital that refiners develop and publicise a mechanism allowing any employee or external stakeholder to anonymously voice concerns about the Platinum and Palladium supply chain activities of a refinery or any newly identified risk.
Similarly, anyone else involved in the Platinum and Palladium supply chains is encouraged to contact the LPPM email@example.com with all legitimate concerns they may have.