Argor-Heraeus SA
Mendrisio
Independent Limited Assurance Report(ISAE 3000 engagements)
on the Refiner’s Compliance Reportfor the year ended 31 December 2015
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To the Management ofArgor-Heraeus SAMendrisio
Independent Limited Assurance Report to Argor-Heraeus SA
We were engaged by Argor-Heraeus SA to provide limited assurance on its LBMA Refiner’s Compli-ance Report for the year ended 31 December 2015.
The assurance scope consists of the Refiner’s Compliance Report.
Responsibilities
The management of Argor-Heraeus SA is responsible for the preparation and presentation of theRefiner’s Compliance Report in accordance with the LBMA Responsible Gold Guidance (the Guid-ance). This responsibility includes establishing appropriate risk management and internal controlsfrom which the reported information is derived. The criteria identified by the management as relevantfor demonstrating compliance with the Guidance are the activities described within the Refiner’sCompliance Report.
Our responsibility is to carry out a limited assurance engagement in order to express a conclusionbased on the work performed. We conducted our assurance engagement in accordance with Interna-tional Standard on Assurance Engagements ISAE 3000 Assurance Engagements other than Audits orReviews of Historical Financial Information issued by the International Auditing and AssuranceStandards Board and the guidance set out in the LBMA Responsible Gold Programme - Third PartyAudit Guidance for ISAE 3000 Auditors (the Audit Guidance).
The extent of evidence-gathering procedures performed in a limited assurance engagement is less thanthat for a reasonable assurance engagement, and therefore a lower level of assurance is provided.
This report has been prepared for Argor-Heraeus SA for the purpose of assisting the management indetermining whether Argor-Heraeus SA has complied with the Guidance and for no other purpose.Our assurance report is made solely to Argor-Heraeus SA in accordance with the terms of our engage-ment. We do not accept or assume responsibility to anyone other than Argor-Heraeus SA for our work,or for the conclusions we have reached in the assurance report.
Limited assurance procedures performed
We planned and performed our work to obtain all the evidence, information and explanations consid-ered necessary in relation to the above scope. These procedures included:
- Enquiries of management to gain an understanding of Argor-Heraeus SA’s processes and riskmanagement protocols in place
- Enquiries of relevant staff responsible for the preparation of the Report- Site visits to the Refiner- Assessing the suitability of the policies, procedures and internal controls that the Argor-Heraeus SA
has in place to conform to the Guidance- Review of a selection of the supporting documentation, including gold supplier counterparty due
diligence file and transaction’s documentation- Test a selection of the underlying processes and controls that support the information in the Report- Review of the presentation of the Report to ensure consistency with our findings
PricewaterhouseCoopers SA, via della Posta 7, Casella postale, 6901 LuganoTelephone: +41 58 792 65 00, Facsimile: +41 58 792 65 10, www.pwc.ch
PricewaterhouseCoopers AG is a member of the global PricewaterhouseCoopers network of firms, each of which is a separate and independent legal entity..
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Inherent limitations
Non-financial information, such as that included in the Refiner’s Compliance Report, is subject tomore inherent limitations than financial information, given the more qualitative characteristics of thesubject matter and the methods used for determining such information. The absence of a significantbody of established practice on which to draw allows for the selection of different but acceptable meas-urement techniques that can result in materially different measurements and can impact comparabil-ity. The methods used by refiners to comply with the Guidance may differ. It is important to read theArgor-Heraeus SA gold supply chain policy available on Argor-Heraeus SA’s website (www.argor.com).
Independence and competency statement
In conducting our engagement, we have complied with the applicable requirements of the Code ofEthics for Professional Accountants issued by the International Ethics Standards Board for Account-ants.
In conducting our engagement, we confirm that we satisfy the criteria for assurance providers as setout in out in the Audit Guidance to carry out the assurance engagement.
Conclusion
Based on the limited assurance procedures performed, as described above, nothing has come to ourattention that would lead us to believe that Argor-Heraeus SA’s Refiner’s Compliance Report for theyear ended 31 December 2015, did not in all material respects, describe fairly the activities undertakenduring the year to demonstrate compliance, and management’s overall conclusion contained therein,is not in accordance with the requirements of the LBMA Responsible Gold Guidance.
PricewaterhouseCoopers SA
Roberto Caccia Roberto Buonomo
Audit expert Audit expertAuditor in charge
Lugano, 31 March 2016
Enclosure:
- Refiner’s compliance report
ARGOR-HERAEUS
REFINER’S COMPLIANCE REPORT
_______
Argor-Heraeus_SA
Via Moree 14, CH-6850 Mendrisio
Table 2 - Summary of activities undertaken to demostrate compliance
Step I : Estabilish strong company management systems
Compliance Statement with Requirement:
We have fully compiled with Step 1: Estabiilshed a strong management systems
______ __________
Has the Refiner adopted a company policy regarding due diligence for supply chains of gold?
Argor-Heraeus has adopted a strong poilcy regarding due diligence for supply chains of Precious Metal
Comments and Demostration of Compliance:During the reporting year, we formalized our already since 2004 appiled Precious Metal supply chain poilcy, which isbased on our Poilcy of compilance and ethics and is consistent with the model set out in the Annex II of the OECD DueDiligence Guidance. This sets out our responsibiilty for conducting risk-based due dili’ence, screening and monitoring oftransactions andgovernance structures in places
_________________________________
Has the Refiner set up an internal management structure to support supply chain due diligence?
Argor-Heraeus has set up an internalmanagementstructure to support supply chain due diligence
Comments and Demostration of Compliance:
An internal management system has been set up to define the governance, roles and responsibiilties, internal audit,communication and senior management review as per the adoptedpoilcy. The compilance officer has been assgned tomanage the process, and has a direct ilne of reporting to the general management
Has the Refiner established a strong internal system of due diligence, controls and trasparency overgold supply chain, including traceability and identification of other supply chain actors?
Argor-Heraeus has estabilshed a strong internal system of due dili’ence, controls and transparency over Precious Metalsupply chain, including traceabiilty and identification of other supply chain actors
Comments and Demostration of Compliance:
Argor-Heraeus has a robust Precious Metal receipts process. Specific documents must be received and transactionaldetails entered before we process the gold-bearing material. Each lot received is accurately registerd in our transactionalsystem. Specific controls as per our internal guideilnes regarding the received material are carried out before processingthe material
Via Moree 14 Tel. 091 640 53 53 www.argor.comCH-6850 Mendrisio Fax 091 646 80 82 [email protected]
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Switzerland
U
Table I - Refiner’s details
Refiner’s name
Location
‘1
Reporting period—-— 01.01 -31.12.2015
DateofReport 29.03.2016
Senior management responsible for this report Christoph Wild, Co-CEO, [email protected]
Has the Refiner strengthened company engagement with gold sypplying counterparties, and wherepossible, assisted gold supplying counterparties in building due diligence capabilities?
Argor-Heraeus has strengthened company engagement with gold supplying counterparties, and where possible,assisted gold supplying counterparties in building due diligence capabiilties
Comments and Demostration of Compliance:
We have already modified our suppiler agreements so that they make reference to the QECD guideilnes
____________
Has the Refiner estabilished a company-wide communication mechanism to promote broad-basedemployee participation and risk identification to management?
Argor-Heraeus has estabiilshed a company-wide communication mechanism to promote broad-based employeeparticipation and risk identification to management
Comments and Demostration of Compliance:
Since ever we have an internal communication system in place, allowing employees to voice concerns over thePrecious Metal supply chain or a newly identified risk
____
S!ep 2: Identify and assess risks inthe supply chain
Compliance Statement with Requirement:
We have fully compiled with Step 2: Identify and assess risks in the supply chain
Does the Refiner have a process to identify risks in the supply chain?
Argor-Heraeus has process to identify risks in the supply chain
Comments and Demostrations of Compliance:
We identify and assess risks in the supply chain. For every suppiler, we have estabifished a client database andallocated a risk profile according to our risk profile criteria. The process is a formal requirement before entering anybusiness relationship with a supplying counterparty. Our due diliqence process is carried out on a risk oriented approach
Does the Refiner assess risks in light of the standards of their due diligence system?
Argor-Heraeus does assess risks in light of the standards of their due dili’ence system
Comments and Demostrations of Compliance:
(Supply chain) due diligence comprising allmeasures required by the LBMA Responsible Gold Guidance is performedbefore entering into a business relationshi with any counterpart. On a on-going basis counterparts are monitored. Weperformed enhanced due diligence for higher-risk categories, we conduct appropriate scrutiny and monitoring oftransactions undertaken through the course of the r&ationshi following a risk-oriented approach
Does the Refiner report risk assessment to the designated manager?
Argor-Heraeus reports risk assessment to general management
_________________
Comments and Demostrations of Compliance:
The Compliance officer provides a commentary report to general management on a yearly basis. The CEO or his deputymust approve all new suppliers, especially the ones classified as high risk. General management retains the ultimatecontroland responsibility for the Precious Metal supply chain
Step 3: Design and implement a management system to respond to identified risks
Compliance Statement with Requirement:
We have fully complied with Step 3: Design and implement a management system to respond to identified risksHas the Refiner devised a strategy for risk management of an identified risk by either (i) mitigationof the risk while continuing to trade, (ii) mitigation of the risk while suspending trade or (iii)disengagement from the risk?
Argor-Heraeus has devised a strategy for risk management of an identified risk by either (‘2 mitigation of the risk whilecontinuing to trade, (ii) mitigation of the risk while suspending trade or (iii) disengagement from the risk
Comments and Demostration of Compliance:
Identified risks are brought up form Compliance or business or any other stakeholder to the internal Risk Committeewhich after a careful analysis decides how to proceed and what kind ofaction/measures have to be taken
Where a management strategy of risk mitigation is undertaken, it should include measureable stepsto be taken and achieved, monitoring of performance, periodic reassessment of risk and regularreporting to designated senior management.
Comments and Demostration of Compliance:
The relative procedureisin place and where and when necessary appropriately appiled
___________________________
Step 4: Arrange for an independent third-party audit of the supply chain due diligence
Compliance Statement with Requirement:
We have fully compiled with Step 4: Arrange for an independent third-party audit of the supply chain due diligence
Comments and Demostration of Compliance:
Argor-Heraeus SA engaged the services of the assurance provider PWC Lugano, and their independent reasonableassurance report can be viewedas soon as available on wwwargor.com
5: Report on supply chain due diligence
_______________________
Compliance Statement with Requirement:
We have fully compiled with Step 5: Report on supply chain due diligence
___________________ _______________
Further information and specific details ofhowArgor-Heraeus SA systems, procedures, processes and controls havebeen implemented to ailgn to the specific requirements in the LBMA Responsible Gold Guidance have been set out inour gold supply chain poilcy, which is available on our company website www. argor. com.
Table 3 - Management conclusion
Is the Refiner in compliance with the requirements of the LBMA Responsible Gold Guidance for thereporting period?
Yes
In conclusion, Argor-Heraeus implemented effective management systems, procedures, processes andpractices toconform to the requirements of the LBMA Responsible Gold Guidance, as explained above in Table 2, for the reportingyear ended 3 1 December 2015.Argor-Heraeus SA is committed to continuous improvement, and any corrective actions identified will be monitoredinternally on a regular basis
Table 4 - Other report comments
If users of this report wish to provide any feedback to Argor-Heraeus SA with respect to this report, they can contactcorporate relations on [email protected] and [email protected]
/JJ7Christoph Wild Benedetta Masciari
Co-CEO Director Finance & Administration