Fidelity Gold Refinery — ESG Management System & Responsible Sourcing

My role

• Led the ESG baseline and materiality work.
• Developed the ESG Policy and three-year ESG Strategy.
• Established strategic priorities, governance arrangements and reporting structures.
• Developed ESG performance indicators, targets and monitoring arrangements.
• Designed the data and evidence architecture required for ESG reporting.
• Led responsible sourcing and ASM due-diligence work.
• Developed supplier risk-screening, assessment, evidence and corrective-action processes.
• Supported stakeholder engagement, management training and Board-level reporting.

The baseline as a management diagnostic

• 14 environmental indicators: water, energy, GHG, waste, chemicals, mercury, ASM environmental risk, biodiversity and climate.
• 20 social indicators: OHS, training, labour rights, child labour, gender, community engagement, grievances, ASM support and human rights.
• 19 governance indicators: AML/CFT, anti-corruption, whistleblowing, Board oversight, risk management, traceability, transparency and supplier standards.
• 20 ESG risks assessed with inherent and residual scoring, using a RAG approach to separate evidenced controls from data gaps.

Turning standards into an operating system

GRI Standards informed materiality and reporting; OECD Due Diligence Guidance structured mineral supply-chain due diligence; LBMA Responsible Gold Guidance informed sourcing and market expectations; IFC Performance Standards, UNGPs and TCFD concepts informed environmental, human-rights and climate-risk considerations.

• Systems logic: policy → strategy → priority → action → indicator → data → evidence → reporting → management response.
• 40 ESG KPIs across environmental, social and governance pillars with 2026–2028 targets.
• Each indicator carries a baseline, target, owner, update frequency, decision trigger and defined action.
• Year 1 emphasis on measurement infrastructure: metering, GHG visibility, LTIFR, training completion, KYC audit and whistleblowing data.

Responsible sourcing and ASM formalisation

The formalisation pathway runs registered → assessed → improving → responsible supplier → finance preparedness, supported by a digital evidence platform.

• Supplier and site identification, profiling and red-flag screening.
• Due diligence aligned to the OECD five-step approach.
• Traceability and chain-of-custody evidence requirements.
• Supplier self-assessment questionnaires and corrective action plans for priority risks.
• Evidence platform flow: ASM profile → site assessment → findings → corrective action → evidence → progress tracking → reporting.
• Corrective action architecture covering child labour, mercury use, KYC gaps, environmental non-compliance and AML red flags.

What changed

• A formal ESG baseline created a reference point for future performance measurement.
• A three-year strategy translated ESG priorities into phased implementation.
• Governance responsibilities and Board reporting were formalised.
• The KPI dashboard created a structured ESG data and performance-management mechanism.
• Responsible sourcing moved to OECD-aligned due diligence with evidence and corrective action.
• ESG was connected to market access, audit readiness, risk management and commercial positioning.