El Dorado Trading’s Supply Chain
Our Commitment
To ensure that purchased gold is responsibly sourced by identifying the actual and potential risks within our supply chain.
Participate in global markets by mitigating risks and making continual improvements in our processes, how we support miners, and transparent reporting.
Our Plan
Strong Management Systems
El Dorado Trading recognizes that in order to participate in the global gold markets and engage with refiners that a set of strong management systems needs to be in place. The company is expanding on its systems that follow all local requirements as a licensed dealer of the Guyana Gold Board (GGB) to meet international guidelines.
Assess the Risks
As an aggregator of gold within Guyana El Dorado Trading needs to assess the risks of both its direct operations as well as those of its upstream suppliers in relation to its Supply Chain Policy.
The proximity of Venezuela, a high risk country, presents the significant risk that gold originating from that country is entering the Guyana gold market.
Risk assessment is ongoing and will be updated to reflect changes in the operation of the company, of its suppliers, of local laws and regulations, as well as changes in neighbouring countries.
Respond to risks
Identified risks are presented to the senior management of the company. The company will create risk management plans that will face and attempt to mitigate the identified risks. El Dorado Trading is committed to increasing the professionalism, security, and viability of the Guyana gold mining sector for all involved. The company’s first response is to Engage and Improve with their upstream suppliers where the identified risks fall below the level of serious abuses. The company generally will continue to work with upstream suppliers for a period of time to provide the supplier with the opportunity to improve their processes, and for the company to conduct due diligence and gather evidence to better understand the (potential) risk.
In the case of serious abuses the risk management plan will require the immediate suspension of activities/relationships.
The company will monitor all risk management plans to track the successes and difficulties with mitigating the identified risks.
The company will engage in additional due diligence and evidence gathering to support the risk assessment and mitigation.
Third Party audits
El Dorado Trading recognizes the value from engaging independent third-party auditors to examine the company and their operations. Recently we engaged for the first time, with LBMA approved BDO in Guyana. They performed an extensive audit of our operational procedures and supply chain integrity. Their recommendations were incorporated into our procedures and have changed the paradigm for El Dorado going forward. Audits may be shared with appropriate regulatory bodies.
El Dorado shall continue to contract internationally recognized, independent third-party auditors regularly, to maintain a best practices operational posture.
Audits are also performed in Guyana by local regulatory and supervising bodies annually.
Public report
The company is working towards publicly reporting on the state of its supply chain portfolio which will identify the strengths and weaknesses of its supply chain strategies and operations. This will provide a sound basis for benchmarking its supply chain management best practices and act as a powerful framework for planning performance improvement mechanisms. Findings will be analyzed and shared, as applicable, with its supply chain and regulatory bodies.
El Dorado Trading is focused on delivering sustainable value for our people, stakeholders, and host communities. This is considered one of our key business strategies as we believe in sustainable economic empowerment of our host communities which is part of our company’s core make-up.
Tamesh Jagmohan
Founder
El Dorado Trading
Supply Chain Policy
Serious Abuses
El Dorado Trading does not tolerate and will not source gold from any supplier that engages directly or indirectly in any of the following serious abuses of human rights:
- Torture, cruel, inhuman and degrading treatment
- Forced labour
- Slavery
- Worst Forms of Child Labour
- Sexual violence
- War crimes
- Violations of international humanitarian law
Responding to Serious Abuses
El Dorado Trading will immediately suspend purchases of gold from upstream suppliers where we have identified reasonable risk that are linked to any parties that are committing serious abuses.
Child Labour
El Dorado Trading does not employ anyone under the age of 18. Upstream suppliers must ensure that they too are not using any child labour in the extraction, processing, or transportation of gold.
Non-state Armed Groups
El Dorado Trading will not purchase any gold or otherwise provide direct or indirect support of non-state armed groups. Working to ensure that gold sourced from Venezuela does not enter into the supply chain is a priority.
Responding to Non-state Armed Groups
El Dorado Trading will immediately suspend purchases of gold from any upstream suppliers where we have identified reasonable risk that the gold will benefit a non-state armed group.
Public or Private Security Forces
El Dorado Trading employs private security to ensure the safety of their employees and their suppliers, and to safeguard the company’s offices, purchased gold, and transportation routes. Our employed forces must uphold the laws and respect human rights. All security staff are screened to identify anyone that may have been responsible for human rights abuses.
The company does not support any public or private security force that illegally controls, taxes, or extorts any part of the supply chain: mines, aggregators, transportation.
Responding to Public or Private Security Forces
El Dorado Trading will work with any upstream supplier to develop a risk management plan to mitigate the risks that they are directly or indirectly supporting public or private security forces. If the supplier is unable to mitigate the risks after six months from the start of the plan El Dorado Trading will suspend activity with that supplier.
Bribery and Misrepresentation
El Dorado Trading will not offer, demand, or accept any bribes. The company will not misrepresent the origin of gold purchased nor will it accept any supplier that it reasonably believes is misrepresenting the origin of gold being offered for sale.
Money Laundering
El Dorado Trading supports and adheres to the Anti-money laundering laws and regulations of Guyana. The company will support efforts to eliminate any risk of money laundering from its supply chain.
Payment of Taxes, Fees, and Royalties
Taxes and royalties on the purchase and/or export of gold is fully paid to the Guyana government and are fully documented. Transparency and accountability are ensured by the Guyana Extractive Industries Transparency Initiative (GYEITI) who audit and publicly report their findings.
Responding to Bribery, Misrepresentation, Money Laundering, and Payment of Taxes
El Dorado Trading will work with upstream suppliers and all Regulatory Bodies to mitigate risks related to corruption in its supply chain. The company will suspend purchases from upstream suppliers who fail, after a reasonable time, to take corrective measures to correct identified issues related to bribery, money laundering, or non-payment of government taxes and royalties.
The company will immediately suspend all trading with any upstream supplier it reasonably believes is misrepresenting the origin of its gold to hide a relationship to Venezuela.
El Dorado Trading
Strong company management systems
Supply Chain Policy
El Dorado Trading has adopted a public Supply Chain Policy that is presented above. This policy is developed with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas in mind. This policy provides clarity with how the company handles the risks to its supply chain
Internal Management Controls
El Dorado Trading has an established set of procedures and controls in place to meet the expectations and legal requirements that come with being an authorized gold dealer of the Guyana Gold Board (GGB). These controls continue to evolve over time to support due diligence and risk mitigation.
Chain of Custody
El Dorado Trading has established and continues to improve upon their chain of custody system. This system provides traceability of gold back to the upstream supplier. Controls are in place to ensure that undocumented gold does not enter the processing stream.
Engagement with Suppliers
El Dorado Trading has strong relationships with its upstream suppliers. The company’s principal is also a gold miner who understands the needs and limitations that they face. The company quickly established the largest dealer network in the country bringing buying offices to interior locations to better serve the mining communities. El Dorado Trading is working with its suppliers to ensure that their respective operations and procedures are in line with the company’s supply chain policy. Furthermore, El Dorado Trading is exploring the CRAFT Code to bring it to its artisanal and small scale gold miners to formalize their participation in responsible mining and enhance the durability of the supply chain.
Grievance Mechanism
El Dorado Trading recognizes the need for open reporting of issues and welcomes grievances as an early warning system to shape due diligence and evidence gathering initiatives. The company encourages all staff, upstream suppliers, contractors, and civilians to file grievances related to any aspect of the supply chain.
Anti-Corruption
El Dorado Trading is committed to ensuring its business conduct and the business conduct of those acting on El Dorado Trading’s behalf is done with integrity, the highest ethical standard, and in accordance with El Dorado Trading’s Code of Conduct, applicable laws, and regulations. Read our Anti-Corruption Policy here.