12/12/2025ESG
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The physical purity of gold is expressed in carats and describes the proportion of pure gold in an alloy. Certifications ensure that gold bars’ composition does, in fact, measure up to their minted value. But what about purity in terms of ESG criteria? Responsibly sourced gold is indistinguishable visually.
As the issuer of Xetra-Gold®, Deutsche Börse Commodities GmbH is committed to high standards to ensure that all gold held in its custody is mined responsibly. It is the issuer’s stated aim to contribute to a sustainable gold market to the highest degree possible along its entire value and supply chain. To this end, an ESG strategy has been integrated into the overarching business strategy with the fields of action environment (E), social (S) and governance (G) as the main areas of focus for its activities.
Since 2020, a declaration of conformity with the 20 criteria of the German Sustainability Code (DNK) is published in the DNK database biannually. In the future, reporting will be supplemented by the voluntary EU standard for sustainability reporting by SMEs, the VSME (Voluntary ESRS for Non-listed Small- and Medium-sized Enterprises). Based on the results of the double materiality analysis and the corresponding objectives and measures, and within the scope of its capabilities, Deutsche Börse Commodities contributes to achieving the Sustainable Development Goals (SDGs).
ESG topics
Environment
KPIs: 249 t CO2e (2023)
Climate and energy
Climate change, with its far-reaching consequences for all areas of sustainability, is the greatest challenge of the 21st century. The most serious effects include the destruction of ecosystems and biodiversity, health hazards and an increasing competition for resources. Counteracting efforts require the global participation of policy, business and society. To do its part, Deutsche Börse Commodities holds itself, its suppliers and service providers to high standards.
The gold bars for the physically backed Xetra-Gold® security are sourced from our cooperation partner Umicore AG & Co. KG, among others. The bars are produced via sustainable and resource-efficient extraction from recycled materials. Recycling scrap gold generates less than one-twentieth of the CO₂ emissions produced in traditional mining of the same amount of gold.
Deutsche Börse Commodities fully offsets its annual carbon footprint with ForTomorrow, a non-profit organization that reforests climate-resilient mixed forests in Germany to increase carbon storage and promote biodiversity.
Conservation of Resources and circular economy
The London Bullion Market Association (LBMA) guidelines ensure that manufacturers and mines commit to extracting gold in the most environmentally friendly way possible while respecting local ecosystems. As an alternative to mining, gold can be recycled without loss of quality or value, reducing dependence on mines and their impact on nature.
Traditional mining entails a considerable consumption of land, destruction of ecosystems and contamination of water sources. For the physical delivery of Xetra-Gold, Deutsche Börse Commodities GmbH therefore uses bars made from recycled gold by joint venture partner Umicore AG & Co. KG, provided sufficient capacity is available. The gold refinery is certified as conflict-free and uses state-of-the-art processes to recover valuable metals from a wide range of industrial residues and waste products, returning them to the production cycle.
For requirements which exceed these capacities, metal supplies from sustainable, ethically verified primary sources are used, in compliance with the clearly defined conditions of the Charter for Sustainable Procurement.
Social
KPIs: 2 managing directors, 0 operating sites
Employee and human rights
Deutsche Börse Commodities GmbH addresses the ethical challenges surrounding gold trading. Often located in disadvantaged regions of developing countries, gold mines contribute to the economic situation. They pose risks of human rights violations in the extraction, transport or trade of gold. Workers in small-scale mines risk their lives and health every day and do not have the means to build a secure future.
Not all gold is created equal.
Deutsche Börse Commodities has therefore issued a statement regarding modern slavery and human trafficking and has made a commitment to comply with the principles of the UN Global Compact. When it comes to ESG criteria, the production of new gold bars is governed in particular by the Good Delivery Rules and Responsible Gold Guidance as part of the LBMA’s leading Responsible Sourcing Programme standard. The parameters defined in the Responsible Sourcing Programme – prohibition of forced and child labor, ensuring fair working conditions and wages, compliance with occupational health and safety standards for miners, support of local communities, exclusion of gold from conflict zones and prevention of terrorist financing – is periodically inspected on site by independent third parties. The Xetra-Gold® inventory consists exclusively of bars from strictly regulated and audited mines or recycled gold.
Declaration on Modern Slavery and Human Trafficking (available in German only)
UN Global Compact Commitment (available in German only)
Supplier Code of Conduct (available in German only)
Maximal transparency
With its product Xetra-Gold, Deutsche Börse Commodities stands for reliability and integrity in gold investing. Product acceptance, customer trust and safekeeping of the precious metal are top priorities. For Deutsche Börse Commodities, responsible communication is based on transparency. As part of its ESG management, it has developed dialogue strategies for its various stakeholders which are regularly updated, adapted and developed. All relevant documents are available online, ranging from the articles of association to a list of all gold bars in storage.
Key information document, Annual reports, the Xetra-Gold prospectus and other documents can be found here.
Governance
KPIs: 0 party donations, € x donation amount, 0 cases of non-compliance with laws and regulations
Compliance with laws and regulations
The financial sector is a highly regulated environment. Companies such as Deutsche Börse Commodities GmbH and their business partners are prone to the scrutiny of policy makers, authorities and the public. As a special purpose entity, it complies with all applicable laws and regulatory requirements. The lean and highly efficient corporate structure of Deutsche Börse Commodities enable short decision-making processes, direct internal communication and close monitoring of key issues, in accordance with the declaration of conformity under the German Sustainability Code (DNK).
ESG responsibility lies with the management and the external ESG officer. The topic of sustainability is an integral part of all supervisory board and shareholder meetings.
Values, mission statement and codes of conduct
The company lives by the values and vision set out in its mission statement and is committed to the code of conduct for business which summarizes the principles applicable to all contributors. All actions are consistent with safety and profitability aspects, customer focus, and respect for others and their chosen way of life. Further guidelines concern competitive practices and the handling of sensitive information.
Deutsche Börse Commodities promotes responsible procurement as part of its supplier management. It aims to foster and maintain fair and collaborative relationships with its suppliers and in turn expects them to comply with all legal requirements. All suppliers and service providers therefore acknowledge the agreed code of conduct, which covers the areas of economic sustainability, environmental protection, and social and ethical responsibility.
Vision statement (available in German only)
Code of conduct for business (available in German only)
Code of conduct for suppliers (available in German only)
Social commitment
Deutsche Börse Commodities is mindful of its social responsibility. It therefore makes appropriate monetary and in-kind donations to charitable causes and to promote financial education projects. Since 2015, Deutsche Börse Commodities has been regularly supporting ARCHE Kinderstiftung, an organization committed to countering the material and emotional effects of child poverty, with financial donations. Together with their closest external colleagues, the two managing directors also visit the ARCHE annually for a hands-on day of fun and learning. In 2025, a sponsored workshop was held by “Schulgold,” a program for the financial education of children, teenagers and young adults, at a local special education and counseling center.
FAQs and Glossary
Which certifications are important for Deutsche Börse Commodities GmbH?
Is there such a thing as sustainable gold and how is it defined?
What are the measures to prevent child and forced labor in gold mining?
Who are the partners of Deutsche Börse Commodities in terms of sustainability?
- The London Bullion Market Association (LBMA) is an international association which standardizes and regulates the global trade in precious metals such as gold and silver. It is also their most important over-the-counter trading venue. In addition, the LBMA defines the gold underlying a trade via the LBMA Good Delivery Rules and Governance, a quality standard ensuring efficient trading with standardized LBMA Good Delivery bars. The LBMA is an essential partner of Deutsche Börse Commodities GmbH.
- The responsible use of raw materials is a priority both for Deutsche Börse Commodities and its investors. An important partner is Umicore AG & Co. KG, producer of gold bars in the world’s largest recycling plant for waste products containing precious metals. With its closed cycle, the company contributes to the conservation of resources. For example, to produce a 1 kg gold bar of the identical product quality via its recycling process, Umicore requires six tons of old cell phones – instead of 200 tons of natural ore. Annually, the company produces roughly 100 tons of gold from scrap gold and electronic waste.
What is “grandfathered gold”?
Grandfathered gold refers to the investment gold such as bars or coins refined before January 1, 2012, held in bullion bank vaults, central banks, exchanges or refineries. It requires no determination of origin. This also includes third-party holdings. While there is no verification of ESG-compliant sourcing for grandfathered gold, Deutsche Börse Commodities GmbH endeavors to pass on all available information.
What are “green mining” and “green gold”?
Green mining is generally understood as the greatest possible consideration of ESG criteria in gold extraction along the entire value chain, including the environmentally friendly development of gold mines, gold extraction or gold recycling, full respect for human and labor rights, and responsible corporate governance. Green gold is not an officially recognized term. Most gold bars are produced in adherence to the world’s leading standard, the Responsible Sourcing Programme of the London Bullion Market Association (LBMA). While seals such as “Fairtrade Gold,” “Green Gold,” and “Auropelli Responsible Gold” identify sustainably produced gold with minimal emissions, there are no uniform criteria or market standards for the evaluation and classification of gold in terms of sustainability.
What is recycled gold?
Refined gold which does not directly originate from a mine is considered recycled gold. In practice, recycled gold is recovered from scrap gold in the form of jewelry or gold bars or from end-user products, scrap and waste metals, or materials generated during refining and product manufacturing. Whenever possible, Deutsche Börse Commodities GmbH aims to use bars cast from recycled gold. Its primary partner in this endeavor is Umicore AG & Co. KG, a company specialized in state-of-the-art recycling technologies.
What is urban mining?
In urban mining, gold is extracted for recycling purposes from smartphones, tablets, PCs and motor vehicles, i.e. sources found in high concentrations, particularly in urban regions. In terms of growth potential, urban mining is currently the most promising area of recycling. The recycling rate of scrap gold, such as jewelry, is already at 100 percent.
Why doesn’t Deutsche Börse Commodities exclusively rely on recycled gold?
There is simply not enough recycled gold available on the market for the purpose of physically backing the Xetra-Gold® bearer