Last updated: 2026-07-09
Human Rights Watch — Pushing the LBMA Toward Mandatory Refiner Disclosure
Human Rights Watch has moved from documenting abuses after the fact to directly shaping the London
Bullion Market Association's rulebook, submitting formal comments on the LBMA's disclosure guidance in
September 2025 and publicly framing mandatory refiner transparency as the mechanism to disrupt armed-group
gold financing in Venezuela and beyond. This marks a structural shift from advocacy-through-report
to advocacy-through-rulemaking-participation.
1. The September 2025 LBMA submission and the Venezuela case
On 22 September 2025, Human Rights Watch submitted formal comments directly addressing the
disclosure guidance of the London Bullion Market Association, arguing that new industry disclosure
requirements could disrupt abusive armed groups' trade in gold
(Human Rights Watch, Submission re: the Disclosure Guidance of the London Bullion Market Association).
The organization's companion statement cites a 2020 investigation in which a 17-year-old boy in
Venezuela's Bolivar state told researchers he witnessed armed-group members amputate both
hands of a miner accused of stealing gold, and states that summary executions and forced child labor by
armed groups persist in the region as of the 2025 publication
(Human Rights Watch, New Industry Requirements Could Disrupt Abusive Armed Groups' Trade in Gold).
HRW's central policy argument is that public disclosure of refiners' gold supply chains — the exact
mechanism embedded in the LBMA's Gold Bar Integrity Database mandatory-compliance track for 2027 —
could help detect and diminish illegal supply chains feeding these abuses.
2. “Sparkling Jewels, Opaque Supply Chains”: ranking 15 jewelry companies
HRW's 24 November 2020 report, Sparkling Jewels, Opaque Supply Chains, scrutinized
and ranked 15 major jewelry companies on efforts to prevent human rights abuses in gold and
diamond supply chains between 2018 and 2020, following up on the organization's 2018 report The Hidden
Cost of Jewelry
(Human Rights Watch, Sparkling Jewels, Opaque Supply Chains).
Recommendations directed at these companies included annual public reporting on human rights due diligence
steps, publication of the names of gold and diamond suppliers, unannounced mine-site visits, and requiring
suppliers — particularly gold refiners and diamond cutters and polishers — to provide credible
evidence of due diligence rather than simple supplier assurances
(Human Rights Watch, Sparkling Jewels, Opaque Supply Chains).
The original 2018 report, The Hidden Cost of Jewelry, documented child injury and death in
small-scale gold and diamond mining pits, forced displacement of Indigenous peoples near mines, and
conflict-related abuses by armed groups profiting from gold and diamond extraction, based on interviews with
victims and written exchanges with 13 major jewelry and watch brands
(Human Rights Watch, The Hidden Cost of Jewelry).
3. 2025 mining-sector advocacy: calling for mandatory rules over voluntary standards
Throughout 2025, HRW escalated its position from documentation to explicit regulatory advocacy. In a
20 February 2025 statement, HRW argued that greater 2025 mining demand requires new
protections, explicitly criticizing industry-led voluntary standards — even robust ones such as the
Initiative for Responsible Mining Assurance (IRMA) — for risking glossing over human rights and
environmental harm without transparent, detailed company-level performance analysis
(Human Rights Watch, Global Demand for Minerals Requires New Mining Protections).
On 6 May 2025, HRW and Climate Rights International submitted joint recommendations to the
UN special rapporteur on human rights and climate change, drawing on documented abuses in mining in Guinea,
Indonesia, Panama, the United States, and Zambia to argue that robust national mining regulation —
not investor-state dispute mechanisms — is the most important protection for affected communities
(Human Rights Watch, Competition for Minerals Should Respect Rights and the Environment).
By 17 December 2025, HRW explicitly backed the initiative for a global mining treaty,
calling for mandatory rules covering both industrial and small-scale mining operations, and cited ongoing
documented violence in Peru, Zimbabwe, and the Central African Republic alongside Venezuela
(Human Rights Watch, Will Governments Move to Address Mining Abuses?).
Current status: HRW has positioned itself as a
direct participant in LBMA rulemaking ahead of the 2027 mandatory Gold Bar Integrity Database compliance
date, while simultaneously pushing for a binding global mining treaty rather than continued reliance on
voluntary industry standards. Watch: whether HRW's submitted comments are reflected in the
LBMA's final 2027 mandatory disclosure rules, and the global mining treaty's progress through 2026.
Last updated: 2026-07-09
Global Witness and Public Eye — Naming Refiners, Tracing Conflict Gold to Source
Global Witness and Switzerland's Public Eye have built a track record of naming specific refiners
and companies rather than describing supply-chain risk in the abstract, from Global Witness's 2014 Kaloti
Jewellery investigation to Public Eye's 2015 “A Golden Racket” report implicating one of the
world's largest Swiss gold refineries. Both organizations continue refiner-level investigations
into 2026, most recently on manganese supply chains for EV batteries.
1. Global Witness's refiner-naming model: Kaloti and DRC gold-army links
Global Witness's 2014 whistleblower report alleged that Dubai-based Kaloti
Jewellery International, one of the world's largest gold refiners, breached international
anti-money-laundering rules, specifically failing to report over $5 billion in potentially
suspicious cash transactions in 2012, with the report noting a “substantial risk” that conflict
gold entered the refiner's supply chains even though no direct evidence of conflict-gold sourcing was found
(Mining.com, Dubai Refiner Responds to Conflict Gold Charges, citing Global Witness findings).
A separate 18 July 2017 Global Witness investigation documented how a mining company in
eastern Democratic Republic of Congo ceded roughly one-third of its gold production — potentially
worth tens of thousands of dollars per year — to the son of a senior Congolese army
Brigadier-General, in apparent evasion of a Congolese Mining Code provision banning direct
military involvement in mining
(Global Witness, Senior Congolese Army Officer Receiving Major Slice of Gold Production from Mining Company).
The organization's due-diligence template, Do No Harm, sets out five required components for
companies sourcing from conflict-affected supply chains: a conflict-minerals policy, supply-chain risk
assessments grounded in on-the-ground research, remedial action for identified problems, independent
third-party audits, and public reporting
(Global Witness, Do No Harm due-diligence guidance).
2. Public Eye's “A Golden Racket”: Swiss refining and Burkina Faso child labour
Public Eye (formerly the Berne Declaration) published “A Golden Racket” in
2015, documenting that Switzerland's largest gold refinery purchased gold extracted by
children in Burkina Faso, where the report found 30 to 50 percent of the artisanal-mining
labour force were children working 12-hour shifts without safety equipment, in conditions the International
Labour Organisation classifies among the “worst forms of child labour”
(Public Eye, Largest Swiss Refinery Purchases Gold Extracted by Children).
The report's core finding was that voluntary due-diligence measures were not working: companies ought to
know and verify the source of their gold, but the investigation revealed major shortfalls — or
deliberate blind spots — in the refinery's human-rights due diligence and its efforts to trace the
true origin of the gold it refined
(Public Eye, A Golden Racket).
A related Public Eye investigation examined the “true source of Switzerland's ‘Togolese’
gold,” documenting how gold recorded as originating in Togo for customs purposes was traced back to
different underlying source countries, illustrating a specific commodity-laundering technique used to
obscure origin in trade statistics
(Public Eye, The True Source of Switzerland's “Togolese” Gold).
3. Global Witness's 2026 pivot to battery-metals: the Ghana manganese report
Global Witness's investigative model has extended beyond precious metals into critical minerals for the
energy transition. An April 2026 Global Witness investigation into a manganese mine in
Ghana — a material critical to electric-vehicle battery technology — documented meetings with
more than 150 people living near the mine, finding chronic health problems, poisoned water
supplies, and communities afraid to eat dust-covered crops, while the mine's own disclosed 2026 production
target of 10 million tonnes of ore implies roughly triple the associated waste volume of
its 2024 baseline
(Global Witness, Murky Manganese report, April 2026).
The report's recommendations mirror the organization's longstanding conflict-minerals due-diligence
template — calling for guaranteed regular ongoing surveillance of community health and enforcement of
existing legal instruments — demonstrating continuity in methodology as Global Witness's mandate
expands from 3TG conflict minerals to the broader critical-minerals complex driving the energy transition
(Global Witness, Murky Manganese report, April 2026).
Current status: Global Witness and Public Eye
remain the two watchdogs most willing to name specific refiners and mining companies directly, a model dating
to Global Witness's 2014 Kaloti investigation and Public Eye's 2015 Golden Racket report, now extending into
2026 critical-minerals supply chains for the energy transition. Watch: whether Global
Witness's manganese and critical-minerals investigations trigger the same kind of refiner-level disclosure
reforms that its precious-metals work helped catalyze at the LBMA.
Last updated: 2026-07-09
EITI, Publish What You Pay, and Amnesty International — Revenue Transparency and the Cobalt Supply Chain
The Extractive Industries Transparency Initiative's 2023 Standard requires implementing countries to
disclose how they verify production and export data, while Amnesty International's long-running cobalt
investigations — from 2016's “This Is What We Die For” through 2023's forced-eviction
reporting — established the DRC's artisanal and industrial cobalt sector as the reference case study
for supply-chain human-rights due diligence.
1. EITI's 2023 Standard: artisanal mining disclosure and country-level requirements
The EITI Standard 2023 requires implementing countries to disclose all material payments
by oil, gas, and mining companies to governments, and to disclose how they monitor and verify the accuracy
of production and export data typically sourced from the companies themselves
(EITI, EITI Standard 2023 — Summary of Changes).
Critically for metals traceability, the 2023 Standard specifically requires an estimate of
production and exports resulting from artisanal and small-scale mining to be disclosed alongside
industrial-scale figures — formally bringing the informal mining sector into the transparency
framework rather than treating it as an unmeasured residual
(EITI, EITI Standard 2023 — Summary of Changes).
EITI's requirements framework mandates that implementing countries disclose material payments and revenues
to a wide audience in a publicly accessible, comprehensive, and comprehensible manner, with a formal
country validation process assessing compliance
(EITI, EITI Requirements).
2. Publish What You Pay: mandatory disclosure advocacy and the 2026 UK renewal
Publish What You Pay (PWYP), the global civil-society coalition advocating for mandatory
(rather than voluntary) extractive-revenue disclosure, secured a renewed UK government commitment to
extractives transparency as of 29 June 2026, continuing its long-running campaign for
legally binding payment-disclosure rules rather than reliance on voluntary reporting
(Business & Human Rights Resource Centre, Publish What You Pay UK Welcomes Renewed UK Government Commitment to Extractives Transparency).
PWYP's Australian chapter separately welcomed a domestic political commitment to mandatory disclosure in
the mining and oil sectors, reflecting the coalition's core strategic position that transparency should be
a statutory requirement rather than an optional corporate-responsibility practice
(Publish What You Pay, A Transparent Mining and Oil Industry Is One Step Closer).
3. Amnesty International's cobalt trilogy: 2016, 2023, and ongoing DRC advocacy
Amnesty International's 19 January 2016 report, co-researched with African Resources Watch
(Afrewatch), “This Is What We Die For,” was the first comprehensive account tracing how
cobalt mined by children as young as seven in the DRC entered the supply chains of major electronics and
automotive brands, based on interviews with 87 current and former cobalt miners — 17 of them children
— across five mine sites, alongside 18 cobalt traders
(Amnesty International USA, This Is What We Die For).
UNICEF's 2014 estimate, cited in the report, put the number of children working across all southern DRC
mines at approximately 40,000
(Amnesty International, “This Is What We Die For”).
A 2017 follow-up report assessed and criticized the human-rights due-diligence policies of
29 global companies named in connection with DRC cobalt supply chains
(Amnesty International, Corporate Action and Inaction to Tackle Abuses in the Cobalt Supply Chain).
By September 2023, Amnesty's focus shifted from artisanal to industrial-scale mining,
documenting forced evictions and human-rights abuses at four industrial cobalt and copper mining sites
around Kolwezi based on interviews with more than 130 people across six mining projects, finding sexual
assault, arson, and beatings connected to community displacement for mine expansion
(Amnesty International, Forced Evictions at Industrial Cobalt and Copper Mines in the DRC).
Independent academic research cited in Amnesty's 2020 statement — a joint study by the universities of
Lubumbashi, Leuven, and Ghent — found evidence that toxic pollution exposure is causing birth defects
in children of cobalt and copper miners in the DRC's Katanga region
(Amnesty International, DRC: Alarming Research Shows Long-Lasting Harm from Cobalt Mine Abuses).
Current status: EITI's 2023 Standard formally
extends transparency requirements to artisanal and small-scale mining disclosure, Publish What You Pay
secured a renewed UK transparency commitment in June 2026, and Amnesty International's decade-long cobalt
documentation has shifted focus from child labour in artisanal mining toward forced evictions at
industrial-scale operations. Watch: EITI country validation outcomes through 2026 and
whether renewed UK/Australian disclosure commitments translate into binding legislation.