Gold

Gold (Au) is one of the four 3TG conflict minerals under Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821. Gold is extracted from ores and is used in electronics (contacts, connectors), jewellery, dental applications, and financial products. Gold presents the most complex conflict minerals traceability challenge among 3TG minerals because it is fungible, traded globally in standardized forms, and a significant source of ASM revenues in the DRC and adjoining countries. Gold refiners are the pinch point for gold supply chain due diligence.

Dodd-Frank Act Section 1502; Form SD Item 1.01(d)(3); Regulation (EU) 2017/821, Annex I.

Gold is the hardest 3TG mineral to trace due to its extreme fungibility and the role of global commodity markets in breaking traceability. Gold can be easily mixed with responsibly sourced gold at any point in the supply chain. RMAP-conformant gold refiners are critical — they are responsible for verifying the origin of gold inputs. Companies should verify that all gold refiners in their supply chain are RMAP-conformant. The World Gold Council’s Responsible Gold Mining Principles (RGMPs) complement RMAP for large-scale gold mining.

A jewellery manufacturer sources gold from a Swiss refiner. The manufacturer verifies the refiner is on the RMAP conformant list for gold, confirming it has audit-verified systems to prevent conflict gold from entering its supply. The manufacturer uses this data in its Form SD and supplier disclosure statements.