Implementation of V5 is mandatory for Assurance Engagements commenced on or after 1 January 2026. From that date the LPPM Responsible Sourcing Programme (the “Programme”) will be based on the Responsible PGM Guidance (“RPG”) and the new version will be referred to as “RPG5”.
RPG5 includes STEP 5 – REPORT ANNUALLY ON SUPPLY CHAIN DUE DILIGENCE.
The Programme is devised as a means of enabling members of its Refiner Lists to demonstrate their commitment to expunging human rights abuses and criminality from the PGM supply chain. The RSRC has been conducting feedback sessions, to discuss implementation of RPG5. As always, we welcome such dialogue and the insights it brings, and we encourage Refiners to approach us with any questions they may have about RPG5 and its reporting requirements.
After consultation the RSRC decided to continue with the requirement that Reasonable level assurance engagements should be performed before a Refiner added to a Refiner List and thereafter at least once every three years or more frequently, at its discretion.
While there are no rules governing the layout of a Compliance Report, many Refiners choose to present it in the form of three tables, as suggested in the enclosed appendix.
Important Changes to Version 5
1. Need for Supply Chain Policy Statement
RPG5 includes a paragraph, under STEP 1, titled “Policy Statement on theft of PGM-containing materials”. This paragraph refers to the treat that the illicit trade in stolen minerals poses to the PGM industry in general and Refiners in particular. It exhorts Refiners – particularly those handling High Risk materials such as some autocatalytic scrap – to add to their Responsible Sourcing Supply Chain policy a statement underscoring their commitment to:
A. Undertake Enhanced Due Diligence on Suppliers that have not publicly committed to a Responsible Supply Chain Policy similar to, or based upon, OECD Guidance.
B. Investigate and consider suspension of any Supplier it suspects of handling stolen PGM, pending further Due Diligence.
C. Cooperate with Authorities in seeking to end the trade in stolen PGM.
D. Refuse to make cash payments (or part-payments) for autocatalytic material and work towards the elimination of cash payments from the industry.
The RSRC requires all Refiners that include autocatalytic scrap in their supply chain, whether directly or indirectly (through one or more Intermediate Processor), to declare in their Compliance Report whether they have made such a Policy Statement and commitments, on a ‘Comply or Explain” basis. The commitments may be made via an amendment to an existing Supply Chain Policy, or may be issued trough a separate, publicised statement, available and clearly sign-posted on the Refiner’s website. Refiners that do not include autocatalytic scrap in their supply chain (particularly those who may handle High Risk material) may also chose to make such policy commitments, and this would be welcome.
FOR THE AVOIDANCE OF DOUBT:
- Assurance Providers must ask Refiners whether they have a) autocatalytic scrap material in their supply chain, and b) whether they have made a Policy Statement on theft of PGM containing materials (the “Policy Statement”).
- If the answer to a) is “No” and the answer to b) is “Yes”, the Assurance Provider must insist that the Refiner declare the existence of the Policy Statement in its Compliance Report.
- If the answer to a) is “Yes” and the answer to b) is “Yes”, the Assurance Provider must insist that the Refiner declare the existence of the Policy Statement in its Compliance Report.
- If the answer to a) is “Yes” and the answer to b) is “No”, the Assurance Provider must insist that the Refiner provide a detailed explanation, under STEP 1 in its Compliance Report, of its reasons for failing to make such a Policy Statement and a detailed explanation under STEP 3 of the steps that it has taken to ensure that no stolen material has infiltrated its supply chain.
2. Inclusion of Rhodium
RPG5 requires Refiners who are on the Rhodium Sponge Accredited List to undergo the same supply chain due diligence checks as currently undertaken with their other PGMs. To comply with RPG5 a separate COO must be submitted.
It is important that Refiners and Assurance Providers, respectively in their Compliance Reports and Assurance and Management Reports, declare the scope of the report in terms of the metals sampled and covered. (For Refiners, this may be covered in ‘Table 1 – Refiner details’ or in the introduction to STEP 1 reporting). The RSRC recognises that Assurance Engagement timing constraints may preclude the inclusion of rhodium in the Assurance Provider’s sampling and in its reports. The Due Diligence systems and processes for rhodium do not differ materially from those of platinum and palladium sponge, so the continued accreditation of members of the Rhodium Sponge Accreditation List is not contingent on specific rhodium sampling or metal-specific assurance. This does not affect the requirement to list any or all rhodium content in the Country of Origin Annex (see below).
3. Updated Country of Origin (COO) requirements
Following this year’s review cycle the RSRC have reviewed the COO requirements and amended the RPG5 COO Annex to clearly show the material categories that must be shown. The aim of the change is for all Refiners to demonstrate their understanding of the risk of where the PGM entering their supply chain originates, both its country and its industry. For example, it is no longer acceptable to use terms such as ‘Process Residues’. The COO must show from what industry the residues originate from. The amended COO Annex and the acceptable Material Categories are enclosed in appendix 2
Other News from the LPPM RSRC
- The LPPM has recently signed a Memorandum of Understanding (MoU) with IRMA (Initiative for Responsible Mining Assurance). The aim of MoU is for the LPPM to benefit from knowledge exchange and to for the two organisations to jointly explore opportunities to improve the audit process for our mutual members.
- The RSRC is starting a review of the Programmes’ Third-Party Audit Guidance with the aim of publishing a new version in early 2026. The aim is to better guide the Assurance Providers through the audit process of the LPPM programme.
- The RSRC is currently reviewing its policy on the appointment and managing of its Approved Assurance Providers. Given the specialist knowledge required for this task it will be led a 3rd party organisation with expertise in this area.
Amended Country of Origin Annex Guidance (Appendix 1)
Refiners and Assurance Providers should note that the RSRC has amended the Guidance on the LPPM website, regarding the layout and content of the Country of Origin Annex.
Firstly, the text of the paragraph within the section STEP 5 – REPORT ANNUALLY ON SUPPLY CHAIN DUE DILIGENCE is amended to the following:
"Refiner’s Country of Origin (COO) Annex (Confidential)
The Country of Origin Annex must meet the requirements outlined in Appendix 1. Information must include PGM sources (shown separately) giving the following detail:
- Country of Origin from which the Refiner and its subsidiaries sourced PGM
- Gross weights and fine contents (Platinum, Palladium, Rhodium separately)
- Type of material, using only the categories shown in Appendix 1
- Highlight any material that was subject to EDD
Details which must be excluded:
- Customer names or references
- GD Platinum/Palladium and PGM sponge received directly from the original member of the relevant SAL ,or from an LPPM Full or Associate Member, must also be excluded from the report. (For the avoidance of doubt, Platinum / Palladium ingot or PGM sponge which is NOT supplied direct from a member of the relevant Refiner List MUST be included in the figures supplied in the Country of Origin Annex).
The Annex will be held by the RSRC in complete confidence and only shared within the LPPM under strict embargo and for the purpose of ensuring compliance with the Guidance. It will not be divulged to any other parties outside of the LPPM or used for any purposes other than for Responsible Sourcing compliance."
The RSRC apologises for any inconvenience or confusion that the changes to Appendix 1 may cause. We have made them in the interests of clarity and simplicity and hope that Refiners and Assurance will find them more ‘user friendly’, over time.
Please see the new Appendix 1, below.
Appendix 1: Country of Origin Annex RS Guidance V5
The Country of Origin Annex shall contain country of origin data for Mined PGM and Recycled PGM. This must include all PGM received for purchase and toll refining but exclude high grade PGM received directly from a Good Delivery/Sponge Accredited refiner and material in a closed loop process.
To improve supply chain and transaction risk assessment, the Annex should include the following information (amounts expressed in kilogrammes at all times, except where stated and decimal points shown as 0.0 not 0,0):
- The Country of Origin of all Pt/Pd/Rh in all forms, including those received for refining or processing. To be reported by the following material types: Autocatalyst, Mine Material, Catalysts (non-auto), Jewellery, Dental, High-Grade Bullion, Electronic Scrap or Industrial Alloys. Further explanation of the eight material types shown in the table below.
- The approx. gross weight of material received (in Kg)
- PGM received from subsidiaries, wholly or partially owned by the Refiner, the Country of Origin is the country from which the subsidiaries received the material; not the country where the subsidiary is based
- All PGM material received from a CAHRA or subject to other Enhanced Due Diligence must be highlighted in the COO Annex.
- All fine content weights for Platinum, Palladium and Rhodium to be shown separately and not as a combined weight.
The following Platinum, Palladium or Rhodium containing material is to be excluded:
- GD Platinum/Palladium and sponge received directly from a member of the relevant SAL, or from an LPPM Full or Associate Member, must also be excluded from the report.
- PGM received for processing and returned to the same Supplier as a PGM containing product in a ‘Closed Loop’ process. If however, the PGM is not re-used for manufacture, it must be included.
The Annex will be held by the LPPM RSRC in strict confidence and will not be divulged to any other parties inside or outside of the LPPM or used for any purposes other than for Responsible Sourcing compliance.
Table of Required Categories and Material Types:
Example of COO Table:
