OECD Due Diligence Guidance
The five-step framework for responsible mineral supply chains from conflict-affected and high-risk areas. Identify the chain, assess the risk, act on it, have it checked, report on it.
How we are held to account
Compliance
The Ghanaian law we work under, the international standards our counterparties measure us against, and the things this company will not do at any price.
Ghanaian law
The instruments that govern this business.
Named so that a counterparty's legal team can go and read them rather than take our word for it.
| Instrument | What it governs for us |
|---|---|
| Ghana Gold Board Act, 2025 (Act 1140) | The buying, aggregation, assaying and export of gold in Ghana, and the licensing of everyone who deals in it. |
| Minerals and Mining Act, 2006 (Act 703) | Mineral rights, small-scale mining licences, and the legality of the operations we buy from. |
| Anti-Money Laundering Act, 2020 (Act 1044) | Customer due diligence, record keeping, and the reporting of suspicious transactions. |
| Environmental Protection Act, 2025 (Act 1124) | Environmental permitting and the Environmental Protection Authority's jurisdiction over any future mining activity. |
| Companies Act, 2019 (Act 992) | Our corporate standing, our register, our accounts and our directors' duties. |
| Income Tax Act, 2015 (Act 896) | Withholding and tax treatment on the purchase and sale of minerals. |
| Data Protection Act, 2012 (Act 843) | Personal data taken from sellers, applicants and anyone who writes to us through this website. |
International standards
What a foreign buyer will measure us against.
No Ghanaian aggregation desk gets audited on Ghanaian law alone. A bullion house or a refiner applies its own supply chain standard, and the two that come up every time are these.
JED-CONFRA is not accredited under either scheme, and does not claim to be. We build our records so that a counterparty applying them can complete their own assessment without having to reconstruct anything.
LBMA Responsible Gold Guidance
The standard London Bullion Market Association refiners apply to everyone upstream of them. If a refiner cannot trace what you sent them, they cannot accept it.
In practice
What compliance looks like at the counter.
Before a purchase
- Photographic identification of the seller, recorded
- Valid small-scale mining licence or dealer's licence, sighted and copied
- Stated location the material was won
- Screening of the counterparty against sanctions and watch lists
- A question about source of funds where the transaction warrants it
After a purchase
- Ticket, assay record and calibration log filed against the lot
- Seal number and transport manifest recorded
- Records retained for the period the law requires
- Suspicious transactions reported as Act 1044 requires
- Refusals logged with the reason, and reviewed
Five things JED-CONFRA will not do
- Buy from an unlicensed operation, whatever the discount
- Buy material whose origin the seller will not or cannot state
- Split a transaction to keep it under a reporting threshold
- Move metal outside the channel the law requires at the time
- Put a figure in writing to a counterparty that differs from the figure in our own records
These are refusals, not preferences. A commercial argument does not move them.
Raising a concern
If you believe someone is using the JED-CONFRA name improperly, or you have a concern about anything in our supply chain, write to info@jedconfra.com with the detail. Reports can be made without giving your name. We would rather hear it from you than read it somewhere else.