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 company 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 trainings on them.
Code of Conduct
- Respect for human rights
- Environmental protection
- Ensure fair competition
- Preventing and combating corruption
- Anti-money laundering and terrorist financing
- No activity against or violation of national, international or supranational organization regulations
- Avoiding 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
Sustainable Procurement Guidelines
- 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, safety and compliance.
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. To reinforce our commitment towards the ASM sector, our Co-CEO Robin Kolvenbach joined the board of the Alliance for Responsible Mining, the organization behind the FAIRMINED initiative, in 2023;
- 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.
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To uphold our stringent standards, we have numerous measures in place.
These include:
- Extensive checks before entering a new business relationship
- Regular on-site mine assessments conducted by us or a third party, typically every three years
- Incident-based ad-hoc mine assessments
- Screening all information for irregularities, for example regarding ownership, general plausibility, and origin of metals
- Determination and assessment of the origins of delivered precious metals
- Independent assurance reports for intermediate refineries or collectors as per OECD Guideline
- Screening for sanctions and adverse media publications to verify partners’ compliance with human rights laws
- Engaging with legislators, NGOs, industry associations, unions, communities, and local governments
If precious metal suppliers do not meet our standards, we refuse to enter into 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.
Our system for responsible precious metal sourcing is certified by all major responsible precious metals sourcing frameworks such as LBMA, RJC, RMI and LPPM. In addition, we have developed our own policies and processes that go beyond these frameworks. We aim to encourage their widespread adoption throughout our supply chain and across the industry.
By collaborating closely with our supply chain partners, we strive to mitigate any potential negative effects, ensuring that the precious metals we receive for refining do 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 to enhance the integrity and transparency of our sector. Together, we work to define new guidelines, regulations and best practices that will shape the future of our industry.
Grievances
In 2023, we processed three grievance cases, two of which were newly reported to us in 2023.
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As reported in the previous year, the non-governmental organization (NGO) Human Rights Watch approached us with a case from previous years regarding the mining company Midroc Gold Mine Plc in Ethiopia. All clarification processes with various organizations and with our clients were successfully cleared in 2023.
In 2023, we were approached by the NGO Fastenaktion, due to the alleged negative impacts of activities of the mining customer MINEROS. After a detailed exchange, including answering numerous questions, our offer for a joint meeting with the customer MINEROS was refused by Fastenaktion. Their report, published in October 2023, does not reflect the facts and we strongly disagree with its contents. As of today, we continue the dialogue with Fastenaktion.
The other new case in 2023 refers to concerns raised informally by representatives of communities in the Dominican Republic concerning the alleged negative impacts of a mine’s activities on the neighboring communities. We are working together with representatives of the communities and the supporting NGO to formalize the grievance, clarifying the differents views and support the finding of a solution with the respective mining company.
Argor-Heraeus takes suspected violations of human rights, criminal law, environmental law, and other laws and regulations very seriously. We encourage whistleblowers to report suspected violations and concerns via our compliance hotline or external ombudsman. In 2023, we made this even easier by introducing a new communication channel: Heraeus SpeakUp offers the possibility to report a compliance violation via internet, app, or by phone and allows an anonymous communication between the whistleblower and the person handling the incident.
More information under: www.heraeus/speakup
Further improving the traceability of gold
We have taken significant steps to ensure the traceability of gold from primary sources, providing customers with proof of origin. For all primary gold entering our gold refining site in Mendrisio, Switzerland, we conduct a thorough geoforensic analysis including X-ray fluorescence (XRF) scanning to measure the characteristic composition. This allows us to make an exact assignment to its origin.
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To further ensure traceability, we offer DNA markers, which allow us to identify material added during shipment with a PCR test. After proving the origin, traceable gold is processed in segregated lines and digitally traced until it reaches its product state as investment bar, semifinished, or finished product.
To enable the retrieval of the origin data, in 2022 we partnered with Alitheon, a US-based company that specializes in artificial intelligence to authenticate physical products. The optical software generates digital fingerprints of gold bars that make them authenticable, identifiable, and traceable, even if their stamps or serial numbers are lost. This will allow buyers or investors to identify these bars by taking a photo. It is also possible to provide further information like its place of origin or carbon footprint.
In addition, we have entered a partnership with the Swiss start-up aXedras, a provider of distributed ledger technology (DLT) specialized in the gold supply chain. DLT enables to save data from business transactions decentrally and unchangeably. The aim of this collaboration is to create a digital documentation from mine origin to consumer product while guaranteeing data integrity. In the long term, this approach will help us to trace even secondary gold back to its mine of origin, which has been almost impossible until now.