CAPACITY BUILDING FOR A RESPONSIBLE MINERALS TRADE …

CAPACITY BUILDING FOR A RESPONSIBLE MINERALS TRADE (CBRMT) IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD FROM THE DEMOCRATIC REPUBLIC OF THE CONGO

APRIL 2015

This publication was produced for review by the United States Agency for International Development. It was prepared by Tetra Tech.

Prepared by Tetra Tech for the United States Agency for International Development, USAID Contract No. AID-OAA-I-12-00032/AID-660-TO-14-00002, under the Strengthening Tenure and Resource Rights (STARR) Indefinite Quantity Contract (IQC). This report was prepared by: Tetra Tech Tetra Tech 159 Bank Street, Suite 300 Burlington, Vermont 05401 USA Telephone: (802) 495-0282 Fax: (802) 658-4247 Email: [email protected] Tetra Tech Contacts: Dr. Denis Roumestan, Chief of Party Email: [email protected] Dr. Catherine Picard, Project Manager Email: [email protected] COVER PHOTO: Artisanal Gold Nyamurhale, South Kivu, DRC, by Armel Nganzi

mailto:[email protected]

mailto:[email protected]

CAPACITY BUILDING FOR A RESPONSIBLE MINERALS TRADE (CBRMT) IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD FROM THE DEMOCRATIC REPUBLIC OF THE CONGO

APRIL 2015

DISCLAIMER

The author’s views expressed in this publication do not necessarily reflect the views of the United States Agency for International Development or the United States Government.

CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD i

TABLE OF CONTENTS

TABLE OF CONTENTS ................................................................................................................... I LIST OF TABLES AND FIGURES .................................................................................................. II ACRONYMS AND ABBREVIATIONS ........................................................................................... III EXECUTIVE SUMMARY ................................................................................................................ VI 1.0 OBJECTIVES OF PILOT PROJECTS .................................................................................... 1 2.0 WORKING CONTEXT ............................................................................................................. 3

2.1 CHAIN OF CUSTODY, DUE DILIGENCE, ASSURANCES, AND DOWNSTREAM ACCEPTANCE

FOR PILOT SITES ................................................................................................................ 3 2.1.1 Traceability Options for Pilot Projects ................................................................. 3 2.1.2 Due Diligence and Regional Certification ............................................................ 6

2.2 BARRIERS AND CONSTRAINTS ............................................................................................. 9 2.3 NECESSARY FACILITATING CONDITIONS ............................................................................. 11

3.0 PILOT MODEL OVERVIEWS ................................................................................................ 12 3.1 OVERVIEW…. ................................................................................................................... 12 3.2 BASELINE CRTIERIA ........................................................................................................... 13 3.3 PILOT PHASES .................................................................................................................. 16 3.4 PILOT AREAS .................................................................................................................... 19

3.4.1 Pilot area One: Maniema – ZEA Model ............................................................. 20 3.4.2 Pilot Area Two: Orientale .................................................................................. 24

3.5 PILOT SCALING-UP PHASE.................................................................................................. 29 3.5.1 Scaling-UP Pilot Site Option: Banro Concession – Twangiza/Mukungwe ........ 29 3.5.2 Scaling-UP Pilot Site Option: MUsebe/katanga ................................................ 31

3.6 SUMMARY OF PILOT SITE RECOMMENDATIONS FROM CBRMT ............................................ 32 4.0 ENVIRONMENTAL MITIGATION AND MONITORING ........................................................ 34

4.1 BACKGROUND................................................................................................................... 34 4.1.1 Monitoring and Mitigation .................................................................................. 35

4.2 POTENTIAL ENVIRONMENTAL IMPACTS ............................................................................... 36 4.3 REPORTING… .................................................................................................................. 37

5.0 GENDER ................................................................................................................................ 39 5.1 BACKGROUND................................................................................................................... 39 5.2 ACTIONS….. ..................................................................................................................... 40

APPENDIX A: PROPOSED IMPLEMENTATION SCHEDULE .................................................... 42 APPENDIX B: ASM GOLD WORKSHOP ..................................................................................... 46 APPENDIX C: PARTICIPANTS ATTENDING L’ATELIER RELATIF A L’EXPLOITATION

ARTISANALE DE L’OR (FEBRUARY 18–19, 2015) ............................................................ 52 BIBLIOGRAPHY ............................................................................................................................ 55

ii CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD

LIST OF TABLES AND FIGURES

Table 3.1: Proposed Criteria for CBRMT Pilot Models .................................................................. 14 Table 3.2: CBRMT Pilot Phases and Deliverables ........................................................................ 16 Table 3.3: Illustrative CBRMT Training Modules ........................................................................... 17 Figure 3.1: Localization of Namoya Permit and Matete ZEA ......................................................... 21 Table 4.1: Environmental Mitigation and Monitoring Measures ..................................................... 38 Table 5.1: Key Consideration and Recommendations to Address Gender Dynamics at CBRMT Pilot Sites ......................................................................................................................... 41 Figure B.1: ZEA Conceptual Model ............................................................................................... 50

CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD iii

ACRONYMS AND ABBREVIATIONS

3Ts Tin, Tantalum, and Tungsten

ADINOM Association de défense des intérêts des négociants et orpailleurs de Mambasa

AEC Artisanal Exploitation Card

AGC Artisanal Gold Council

ANORI Association des Négociants et des Exploitants d’Or (Association of Gold Traders

and Miners)

AODERPI Association des Orpailleurs pour le Développement, la Reconstruction et la Paix

(Association of Artisanal Gold Miners for Development, Reconstruction and

Peace)

AOMARPI Association des exploitants miniers artisanaux pour la pacification et la

reconstruction de l’ituri

ARM Alliance for Responsible Mining

ASM Artisanal and Small-Scale Mining

ASTRAMINES Association des sous-traitants miniers (Association of mining subcontractors)

ATEDRAPO Association des Tenanciers des Dragues de la Province Orientale

BEPAT Bureau d’Etudes des Projets et d’Application Technique

BEST Bureau d'Études Scientifiques et Techniques

BGR Bundesanstalt fur Geowissenschaften und Rohstoffe (Federal Institute for

Geosciences and Natural Resources)

BSP Better Sourcing Program

CAMI Cadastre Minier de la RD Congo (Mining Registry Office of the Democratic

Republic of Congo)

CBMRT Capacity Building for a Responsible Minerals Trade

CDC Cadre de Concertation

CdCRN Cadre de Concertation de la Société Civile sur les Ressources Naturelles

CEEC Centre d’Expertise, Evaluation, et Certification

CENADEP Centre National d’Appui au Développement et à la Participation Populaire

CLS Comités Locaux de Suivi

iv CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD

COMICA Coopérative Miniére des Creuseurs Affectés (Namoya, Maniema Province)

CPS Comités Provincaux de Suivi

DFID Department for International Development

DMCC Dubai Multi Commodities Center

DRC Democratic Republic of the Congo

EL Large Scale Mining License

ETF Exchange Traded Fund

FARDC Forces Armées de la République Démocratique du Congo (Congolese National

Army)

GDRC Government of the Democratic Republic of the Congo

GIZ German International Cooperation

ICCM International Council on Mining and Metals

ICGLR International Conference on the Great Lakes Region

IOM International Organization for Migration

ITOA Initiative de Traçabilité de l’Or d’Exploitation Artisanale (Traceability Initiative

for Artisanal Gold)

iTSCi International Tin Supply Chain Initiative

JMAC Joint Mission Activity Cell (United Nations MONUSCO)

KYC Know Your Customer/Know Your Client

LBMA London Bullion Market Association

LSM Large-Scale Mining

MALI Maniema Libertés

MoM Ministry of Mines

MONUSCO Mission de l’Organisation des Nation Unies pour la Stabilisation en RD Congo

(United Nations Stabilization Mission in the DRC)

MOU Memorandum of Understanding

NGO Non-Governmental Organization

OECD Organization for Economic Cooperation and Development

OGP Peace and Governance Observatory

OKIMO Office des Mines d’Or de Kilo-Moto

PA Protected Area

PAC Partnership Africa Canada

CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD v

PAMP/MKS Produits Artistiques Métaux Précieux

PE Permis d’Exploitation (Exploitation Permit)

PR Permis de Recherche (Research Permit)

PROMINES World Bank’s Growth with Governance in the Mining Sector Program

PwC PricewaterhouseCoopers

RCM Regional Certification Mechanism

SAESSCAM Service d’Assistance et d’Encadrement du Small-Scale Mining (Small-Scale

Mining Technical Assistance and Training Service)

SAKIMA Société Aurifère du Kivu et du Maniema, SARL

SOKIMO Société minière de Kilomoto

SSME Small Scale Mining License

UN United Nations

USAID United States Agency for International Development

WGC World Gold Council

ZEA Zone d’Exploitation Artisanale (Artisanal Exploitation Area)

vi CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD

EXECUTIVE SUMMARY

According to the United Nations Group of Experts and other expert reports, at least 97 percent of the

Democratic Republic of the Congo’s (DRC) current artisanal gold production is illegal and untaxed at

export. Artisanal gold serves as a significant source of revenue for armed groups and militias. The

absence of a legal and well-regulated artisanal gold sector results in the loss of millions of dollars

annually in lost revenues for the DRC government, while also contributing to regional instability. For

those who mine and trade in artisanal gold there are little-to-no incentives to act in a legal manner due to

unfavorable tax structures, no proven traceability systems for gold in country, limited capacity to conduct

monitoring oversight and due diligence and a limited number of buyers willing to legally purchase and

export artisanal gold from the DRC.

The Capacity Building for a Responsible Minerals Trade (CBRMT) program has analyzed the

recommendations and takeaways of numerous research studies and gathered stakeholder input to develop

a proposed implementation plan for the piloting of legal and responsibly-sourced artisanal gold. Our

approach recognizes that developing and sustaining a formalized and legal artisanal and small-scale gold

sector in the DRC will require political will and support at national, provincial and local levels, credible

and self-financing traceability and due diligence systems, increased stakeholder coordination, well

governed cooperatives, and a willingness on the part of downstream buyers to participate.

In late February 2015, CBRMT, in collaboration with the Ministry of Mines (MoM) and the Federal

German Institute for Geosciences and Natural Resources (BGR), convened a two-day workshop in

Kinshasa, DRC with approximately 90 stakeholders from the Artisanal and Small-Scale Mining (ASM)

gold sector in attendance. Participants included senior Government of the Democratic Republic of the

Congo (GDRC) officials, international technical experts, comptoirs, large-scale mining (LSM) actors,

donors, and traceability providers. Discussions focused on the demand for responsibly sourced artisanal

gold from the DRC, opportunities and barriers that the ASM gold sector currently faces, avenues for

stakeholder collaboration, potential traceability solutions, and lessons learned from previous mineral

sourcing programs. The workshop not only produced valuable feedback, which informed the design and

implementation of our approach, but also revealed significant government support for the responsible

sourcing of artisanal gold, and the urgent desire to start as soon as possible.

Accordingly, CBRMT proposes to fund the initial pilot projects in Maniema and Orientale Provinces.

Once the proof of concept has been established in Maniema and Orientale, it is expected that scaling- up

can occur with additional time and resources at sites in South Kivu, Katanga, and Orientale. The

Maniema pilot project will be located on the existing Artisanal Exploitation Zone (ZEA) at Matete in the

Muzizi locality of Maniema Province, and will leverage the ongoing engagement between Banro and the

Coopérative Miniére des Creuseurs Affectés (COMICA). The second model will be located on a yet to be

determined concession in Orientale Province, and will require a protocole d’accord with a legal and a

willing title owner. Pilot projects are deigned to test the application of different gold traceability and due

diligence assurance systems, and will engage with large scale mining companies, cooperatives,

government mining officials and civil society. The precise number of mine sites to be included in the

pilots are difficult to determine before an enumeration has been conducted, however we anticipate the

export of legal artisanal gold from a minimum of six mine sites at Matete, and an estimated 20 sites in

Orientale, for an estimated total of 26 mine sites.

Our proposed plan is designed to learn from different pilot models in order to respond and adapt to

opportunities and barriers. These lessons will contribute to the scaling up of successful pilot models in

order to achieve a critical mass of exports. It addresses the limited timeframe and resources of the

CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD vii

CBRMT program, and aims to engage with multiple stakeholders to build a platform for a sustainable and

formalized artisanal mining system for the responsible sourcing of conflict-free gold from the region.

CBRMT is also cognizant that it is necessary to leave sufficient room for unique approaches in the

implementation of the pilot models. The suggested models described in this report are meant to provoke

discussion, and provide a framework for implementing partners to work within, while still providing

opportunities for our partners to develop and tailor their own approach. Our plan also contains a number

of facilitating conditions we believe are essential for the success of our implementing partners.

CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD 1

1.0 OBJECTIVES OF PILOT PROJECTS

The Capacity Building for a Responsible Minerals Trade (CBRMT) program seeks to catalyze the flow of

legal, responsibly sourced and internationally accepted artisanal gold from the Democratic Republic of

the Congo (DRC). This is a long term vision that can only transpire through carefully analyzing best

practices and utilizing lessons learned. CBRMT will act as a test bed for multiple methods of traceability

for legal artisanal and small-scale (ASM) gold, in order to support the Government of the DRC (GDRC),

the international community, large-scale mining (LSM) companies, and other critical stakeholders in their

efforts to establish and scale-up credible and sustainable systems for legally exporting artisanal gold from

the DRC. CBRMT pilot models will contribute experience and knowledge around the structure and

practice of establishing and sustaining traceable and legal gold supply chains, while fostering a favorable

investment climate for development in the DRC.

Among the four “conflict minerals” (tin, tantalum, tungsten, and gold) extracted in the DRC, artisanal

gold remains the most pressing problem, with more than half of the estimated 800 artisanal gold mines in

eastern DRC under illegal rebel or army control. According to the United Nations Group of Experts and

other independent reports, more than 97 percent of artisanal gold production is smuggled out of the

country. 1 The illegal mining, trade, and taxation of artisanal gold provides a significant source of

revenue for illegal armed groups and threatens to undermine the stability and security in many parts of the

DRC. Conversely, the inability of the state to collect legal taxes on artisanal gold results in the loss of

millions of dollars in much needed revenue each year. For those who mine and trade in artisanal gold

there are little to no prospects to act in a legal manner, impaired by an unfavorable tax structure, no

proven traceability systems for gold, limited government resources and capacity to conduct monitoring

oversight and due diligence in accordance with international guidance and few international buyers

willing to buy and export legal, artisanal gold.

Despite these constraints, CBRMT seeks to prove that the trade of legal artisanal gold is not only

possible, but preferential, for those members of the supply chain who rely on ASM gold for their

livelihood. CBRMT conducted a review of potential systems for the sourcing of artisanal gold, identified

possible synergies across different models, and reviewed the systemic barriers and opportunities for legal

and traceable supply chains. This assessment informed the design of CBRMT’s pilot approach for

artisanal gold, which will be implemented, adapted, and scaled-up over the course of the project. Pilot

projects will advance the implementation of chain of custody schemes, drive the formalization of

participating cooperatives, and actively develop the capacity of civil society to monitor legal gold

systems. Pilot approaches will be implemented using an adaptive approach, meaning that lessons will be

continually harvested from the pilot project to improve the pilot’s efficacy and sustainability.

Pilot models will require close coordination with the Ministry of Mines ([MoM] including Division des

Mines; Service d’Assistance et d’Encadrement du Small-Scale Mining [(SAESSCAM) Small-Scale

Mining Technical Assistance and Training Service]; Centre d’Expertise, Evaluation, et Certification

[CEEC]; Cadastre Minier de la RD Congo [(CAMI) Mining Registry Office of the Democratic Republic

1 UN Group of Experts Report. (2014a). http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2014_42.pdf

2 CBRMT IMPLEMENTATION PLAN FOR RESPONSIBLE SOURCING OF ARTISANAL GOLD

of Congo]; and traditional authorities, as well as the International Conference on the Great Lakes Region

(ICGLR). These stakeholders must be consulted during the formative stages of CBRMT’s pilots in order

to understand their interests better, respond to their needs and constraints, and garner their support.

Regular engagement with LSM gold operators will also be necessary to comprehensively understand the

context of collaboration between ASM communities and LSM concessionaires. CBRMT offers a platform

for dialogue among critical stakeholders to collaboratively develop a sustainable and formalized supply

chain for the responsible sourcing of conflict-free gold from the region. While CBRMT pilot models can

help facilitate the necessary systems for responsible gold, ultimately these stakeholders are responsible for

the long-term success of a legal artisanal gold trade in the DRC.


2.0 WORKING CONTEXT

2.1 CHAIN OF CUSTODY, DUE DILIGENCE, ASSURANCES, AND DOWNSTREAM ACCEPTANCE FOR PILOT SITES

Any successful pilot will need to have in place the various elements that constitute a responsible mineral

trade, including a traceability or tracking system, credible due diligence and assurances, risk evaluation

and mitigation measures, independent third party auditing and monitoring mechanisms, and downstream

acceptance. Several of these elements are described below (including the risks and opportunities

associated with each element). While this is not an exhaustive set of descriptions, it highlights some of the

available partners and necessary steps for traceability that can be trialed under a CBRMT pilot. The

current traceability systems in development are promising, but many have not been tested or adapted to

the context of the DRC and will require adjustments, while others will require collaboration with partners

to provide the full suite of assurances that downstream buyers require.

2.1.1 TRACEABILITY OPTIONS FOR PILOT PROJECTS

GeoTraceability: GeoTraceability Ltd., owned by PricewaterhouseCoopers UK, is a London-based

traceability and data collection service provider. GeoTraceability works to link geographic and

traceability information, while physically separating minerals throughout the supply chain, in order to

trace minerals from mine to export. Participants in the supply chain are registered and issued a unique ID

number and card. The electronic tracking solution has been piloted for Tin, Tantalum, and Tungsten (3Ts)

through pilot projects in North Kivu and Uganda, but has yet to be tested in artisanal gold.

GeoTraceability has an established Memorandum of Understanding (MOU) with the DRC MoM, which

is necessary prior to operating a traceability solution in the country.

The GeoTraceability solution fulfills the chain of custody requirements of the ICGLR Regional

Certification Mechanism, which is compliant with the Organization for Economic Cooperation and

Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from

Conflict-Affected and High-Risk Areas (OECD Due Diligence Guidance). Data collection includes mine

site location, production statistics, chain of custody tracking, incident reports and other data that is

provided prior to export, and can be shared with relevant regional and national mine site databases. At the

mine site, GeoTraceability maintains a binder with artisanal miners’ traceability cards grouped by team,

and information about the minerals at the site, including weights and grade. Minerals are placed into sacks

and tagged with a barcode to be bought/transported by a negociant. The traceability card of the supply

chain participants and the barcoded tags attached to the sacks are scanned throughout each stage of the

supply chain. The GeoTraceability solution is adaptable to customer needs, and can be deployed in areas

with limited internet connectivity.

Key constraints of the GeoTraceability system include their lack of experience with the intricacies of the

DRC’s artisanal gold sector, a lack of transportation route validation, and (as with most traceability

providers) a need to be paired with a due diligence assurance provider. Under the GeoTraceability system

the information gathered is owned and managed by the mineral exporter, which could limit the

dissemination of data if exports chose not share the data. GeoTraceability has developed a partnership

with the Better Sourcing Program (BSP), a London-based supply chain due diligence implementation and

assurance scheme, in order to fill this gap in their solution. BSP facilitate local information collection on

ASM production and supply chain dynamics in a manner that satisfies the ICGLR RCM and OECD Due

Diligence Guidance, in order to support conflict-free minerals export. Participants in the Better Sourcing


Program supply chains are required to abide by the Better Sourcing Standard, which seeks to improve

transparency, provides assurance that worker’s rights and wellbeing have been maintained.

CBRMT cannot directly or indirectly contract with GeoTraceability because of their ownership by

PricewaterhouseCoopers ([PwC] a Tetra Tech financial auditor). However, in the case of 3T traceability,

GeoTraceability has secured private sector funding from minerals exporters to support their traceability

services, and there is potential for the same mechanism to be utilized with gold within the pilot program

period of performance. GeoTraceability have stated their readiness to test their approach in artisanal gold

to the CBRMT team. Their services could be applicable to a CBRMT pilot project as a full-service

traceability provider from mine to export with a partnership with BSP, or utilized in a niche role as a

synergistic partner with another traceability or due diligence provider.

Initiative de Traçabilité de l’Or d’Exploitation Artisanale (ITOA): ITOA is a traceability system

developed by the CEEC which consists of colored tamper-proof bags that contain specific information

regarding the seller, amount, and source of the gold. The tamper-proof bags, the basic element of their

initiative, come in different colors and sizes depending on the stage in the supply chain and trace the gold

from mine to export. ITOA is backed by a designated minerals certification software, which has been

developed by the CEEC, and is currently deployed for the traceability of industrial gold. According to

CEEC, the software has been highly operational and the process of web conversion is soon to be

launched. The ITOA system is designed for CEEC agents to fill in and supervise data collection, bag-

sealing and the transport of the minerals. The costs of the bags and tracking are presumably passed on to

producers, traders, and exporters. ITOA is a progressive model of tracing information associated with the

extraction and trade of gold from the mine site to the point of export. Stage 1 begins at the mining site,

Stage 2 occurs at the points de vente, Stage 3 is at the level of the comptoir and Stage 4 is at the level of

the exporter. A separate model has been developed for use at industrial sites. Responsibility for bagging

and oversight of data collection using the ITOA system is described by CEEC as follows:

Stage 1: For use at a specific mine site with primary oversight by SAESSCAM. SAESSCAM is

responsible for ensuring the gold is placed in a tamper proof bag which includes the following data:

name and location of the mine site where the gold was extracted, the name of the cooperative, the

quantity of gold (grams), the name of the SAESCAM agent verifying the weight and other

information and the date of issue.

Stage 2: For use at points de vente with oversight by Division of Mines, CEEC and SAESSCAM.

Information includes details about the negociant, provenance and weight of the gold being sold in

addition to the other details described above.

Stage 3: For use at the comptoir or processing center with oversight by Division des Mines and

CEEC. Information includes details about the comptoir, the negociant and any other previous data

collected relative to the weight, provenance and location of the mine site.

Stage 4: At the level of the exporter, CEEC verifies all previous information collected and adds

information with respect to the importer, and issues the ICGLR-RCM certificate

CEEC has stated that that they are ready to work with CBRMT on a pilot project, and will be able to meet

international standards including ICGLR RCM and the OECD Due Diligence Guidance. A key constraint

of ITOA is the lack of incentives for artisanal producers or traders to use the technology. Other

traceability providers detailed in this report have stated their intention to integrate community benefits

into their solution to drive adoption (MineralCare for example) In addition, ITOA is exclusively a

traceability solution and does not address the needs for due diligence and assurances, incident reporting,

risk evaluation and mitigation measures, independent third party auditing or monitoring. As a result ITOA

would ideally be paired with a partner/partners who would be able to provide these services and

incentives. Other concerns are the relatively unknown cost of the new system, whether CEEC will be able


to implement ITOA through their regular revenue streams, and the sustainability and functionality of the

ITOA database. It is currently unclear for example how adaptations to the database can be made, and if

necessary, the time and resources it would take to develop a database that conforms to international

assurance standards. As with the other traceability providers, a key constraint will be ITOA’s ability to

prevent rent seeking behavior by other DRC government authorities or other actors in the supply chain.

Various stakeholders have expressed their concern that the ITOA system could add another layer of cost

and bureaucracy in ASM areas where taxation and the cost of business already are already very high.

MineralCare: MineralCare is a Belgium-/Dubai-based supply chain assurance system based on a Know

Your Customer/Client framework. The platform is designed to validate the credibility of the users

throughout the supply chain – from diggers, to buyers, to importers- by verifying the validity of the

information offered and matching it against governmental requirements, available criminal lists and other

blacklists. Diggers are registered through an electronic application that collects basic demographic data

and carte de creuseur information, with actors investigated by governmental departments to ensure that

the complete chain is in control of the government. All security personnel guarding the mine site as well

as couriers transporting the shipments are required to have a government approved credential. The

MineralCare credential is a rubber wristband for diggers with RFID-code containing demographic data

and other information. Diggers must use their wristband to identify themselves when selling their

production to negociants responsible for their area. Control units are in the form of a small hardware tool

to be connected to a smartphone. The wristband can also be used be to access related social benefit

programs that MineralCare has stated will be part of the system. Paying members of the MineralCare

system (exporters, negociants, and refiners) are credentialed using colored electronic card that is

accessible on a smart phone or other mobile devices. Trading, handling and processing and other

information related is captured on the electronic credential, enabling a full chain of custody story to be

told. MineralCare have an established MoU in Province Orientale, and have developed a draft

implementation plan for work in Orientale based on their discussions with government officials and local

stakeholders. Included in the plan is a stated need to conduct a baseline feasibility study in order to build

their business model for a pilot project.

Constraints to the system include the assumption that diggers, government officials and security agents

are already registered, and the Government has sufficient will and resources to provide oversight to this

registration system. MineralCare also relies on miners, negociants and comptoirs registering in the system

although the incentives for doing so are unclear when the social benefits of participation remain opaque

and under-developed. MineralCare also requires a certain level of technology (PDAs, bracelets, tablets,

etc.) that may be not sustainable or suitable for the DRC context. MineralCare is unproven in the DRC

and thus far has only been tested on rough diamonds in Angola, an environment where the state is capable

of exerting more stringent control than in the DRC.

SERCAM: The SERCAM system centers on mineral bags with one-way radio-frequency tags. The

tracking of minerals occurs at select points in the supply chain in combination with GIS data through

radio-frequency reader, with data fed into a database. Anyone handling the minerals must be certified and

must use tracking devices on their vehicles. The SERCAM system has a data management software in

order to analyze data. The system is untested and unproven in the DRC context for ASM Gold, and in the

DRC in general. Attempts to contact SERCAM by the CBRMT team about the pilot projects have been

unsuccessful.

MetTrak: MetTrak describes itself as an “integrated real time software solution specializing in the

tracking and tracing of all materials such as, minerals, associated products and consumables, utilized in

the mining industry.” MetTrak has flexible reporting capabilities designed to meet the needs of the

customer, the various international monitoring organizations and government requirements. The system is

capable of tracking ore from the mine to end user and has a comprehensive audit trail.


According to a 2012 Partnership Africa Canada (PAC) evaluation on MetTrak’s operational traceability

system at the Rutongo Mine in Rwanda, “in terms of ease of use, accuracy of data collected, and labor

force requirements, the system is very promising.2” MetTrak collects data on the origin, transport and

processing of minerals, from the small lots produced by individual miners up through to the large

processed export lots. Data is collected automatically and in real time, including the mine site where each

smaller lot was sourced, the data and time of its production, and the individual miner who produced it.

The data set can be transferred, again in real time, to the custody of regulatory agencies and the ICGLR.

The system adequately fulfills the chain of custody requirements of the ICGLR RCM and conforms to the

ICGLR RCM Data Sharing Standards. MetTrak was first implemented on a test basis at Rutongo Mines

in October of 2011, and has been fully operational there since November 2011.

A major constraint with MetTrak is the system’s lack of associated due diligence and incident reporting.

As with GeoTraceability, ITOA, SERCAM, and MineralCare, MetTrak would need to be partnered with a

due diligence partner to fill this gap. The system is untested and unproven in the DRC context for ASM

Gold, and as with other traceability systems it is unclear what the initial and maintenance costs of the

system are, and whether the system can be financial sustained over time.

2.1.2 DUE DILIGENCE AND REGIONAL CERTIFICATION

Local Monitoring Mechanisms

Monitoring of incident reports, compliance with national and regional certification standards, and due

diligence regarding the conflict environment are key elements of the ICGLR RCM and OECD Due

Diligence Guidance. One effective tool in this regard has been the creation of local oversight committees

(Comités Provincaux de Suivi (CPS), and Comités Locaux de Suivi (CLS) to monitor conditions in and

around targeted mine sites, and report on any issues of concern. Establishing these local committees when

necessary, or collaborating with existing provincial committees and building their capacity to support

CBRMT gold pilots is critical, and will require an upfront commitment to training, and ongoing support

for meeting and reporting costs.

Several DRC non-governmental organizations (NGOs) including Centre National d’Appui au

Développement et à la Participation Populaire [CENADEP], Observatoire Gouvernance et Paix [OGP],

and Bureau d'Études Scientifiques et Techniques [BEST] and Maniema Libertés [MALI] have significant

experience in local monitoring and reporting, and their capacity could be supported to build credible local

monitoring networks.

ICGLR Regional Certification Mechanism

The ICGLR Mineral RCM has four main pillars:

1. Mineral Tracking from Mine Site to Export (including mine site inspection and certification, chain of

custody tracking and certification of exports);

2. Regional Mineral Tracking via an ICGLR Database;

3. Independent Third Party Audits of Exporters; and

4. ICGLR Independent Mineral Chain Auditor.

The ICGLR Regional Certificate serves as the assurance to purchasers that a mineral shipment is conflict

free and meets all ICGLR standards. In this manner it functions much the same manner as the Kimberley

Process Certificates for diamond exports, or the International Tin Supply Chain Initiative (iTSCi).

2 Blore, Shawn (2012). The MetTrak System at Rutongo. A Preliminary Assessment. Prepared for Partnership Africa Canada.


Though there is a phase-in period for the ICGLR Scheme, government authorities in Rwanda and the

DRC have already issued ICGLR Certificates for the 3Ts. In the case of artisanal gold in the DRC, a

small number of certificates have been issued by CEEC. There however have been concerns by civil

society and other stakeholders as to the criteria and standards used for these gold certificates issued in the

DRC, and many artisanal producers are likely not in compliance with the current RCM requirements.

However, should an industrial gold company, such as Banro or Anglo Gold Ashanti, ever be willing to

purchase gold from artisanal miners, their existing ICGLR certification would likely be sufficient.

Downstream Acceptance

The success of CBRMT Pilot Sites hinges on downstream acceptance and a willing buyer, exporter and

refiner lined-up during the design phase. Opportunities exist to partner with firms such as Emirates Gold,

Produits Artistiques Métaux Précieux (PAMP/MKS), Emeko RDC SARL, and Rand Refinery. In order to

partner with these companies, CBRMT pilots must work to overcome the reputation of artisanal gold

from the DRC and demonstrate that a credible, legal artisanal gold supply chain is possible that meets

international standards and guidance. CBRMT implementing partners will need to verify a steady

production, as well as the credibility of all traceability and due diligence procedures in order to secure a

reputable buyer. For the PAC pilot site, PAMP served this purpose, and also played a major role in

supporting due diligence for the pilot. The Public-Private Alliance for Responsible Minerals Trade may

be helpful in identifying and helping to secure a downstream buyer/refiner for CBRMT pilot sites.

CBRMT has been in contact with a range of downstream actors to explore their interest in participating

and supporting the CBRMT pilots. There has been initial interest from many of these stakeholders, and

most have shown their openness to discussing their participation in CBRMT pilot projects. CBRMT will

continue to conduct outreach with these stakeholders, and share the recommendations and feedback,

however implementing subcontractors themselves must proactively secure sourcing and purchasing

agreements with downstream actors. It is expected that implementing subcontractors will engage with

some or all of the following organizations in order to develop their approach to downstream acceptance.

CBRMT has also been invited to attend a closed-door meeting on the margins of the May OECD meeting

to discuss market-oriented initiatives to allow for commercialisation of responsible artisanal gold from the

DRC. The meeting, which is being organized by the OECD, intends to serve as a pragmatic, outcome-

oriented discussion with the objective of reaching agreement on concrete steps that would be taken to

bring responsible DRC ASM gold to market. The discussion will also clarify the potential roles of all

stakeholders (large-scale mining companies and permit-holders, refiners, civil society, implementing

agencies, donors, international organisations, etc.) to support this objective. Other invitees include Banro,

Emirates Gold, the Better Sourcing Program, London Bullion Market Association, and PAMP among

others. A summary specific downstream stakeholders consulted to date is provided below:

Emeko RDC SARL: Emeko is an international company headquartered in Belgium, with a DRC

business presence in Kinshasa, Province Orientale, North Kivu and Maniema, operating as Emeko RDC

SARL. According to export figures from January to June 2014, Emeko RD SARL exported 105 kg of

ASM gold (value of $4,453,000) to Belgium, making them the largest exporter in ASM gold in the DRC

during this period3. Emeko RDC SARL opened their first DRC office in Kisangani in early 2014, with a

business model centered on pre-financing the purchase of ASM Gold through negociants, and the

subsequent export of gold, with the financial backing of the Emeko Belgium office. In September 2014

they decided to alter their strategy, integrating lessons learned from their first eight months of DRC

operations. This shift included the opening of offices in Kindu, Luizal, and Kinshasa, in addition to their

Kisangani office. Of 33 Emeko RDC SARL employees, 5 are expats. In an April 2015 conversation with

3 UN Group of Exports Report. (2014b). http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-

CF6E4FF96FF9%7D/s_2015_19.pdf

http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2015_19.pdf



CBRMT, Emeko expressed their strong support and interest in participation in the pilot projects. Emeko’s

network of pre-screened negociants, their willingness to pre-finance pilot projects, and their ability to act

as an exporter of gold make them a promising partner for CBRMT. Emeko has stated their willingness to

strategize with subcontractors responding to the CBRMT RFPs to develop a solution that works for both

Emeko and pilot project stakeholders.

Signet Jewelers: Signet Jewelers is the world’s largest retail jeweler, and owner of the Kay Jewelers,

Jared, and Zales jewelry stores. Signet has been active in the development of industry guidance and

approaches, including OECD, RJC, and LMBA. Signet is legally required to comply with US legislation

relating to conflict minerals, and has produced a global guidance standard for suppliers, the “Signet

Responsible Sourcing Protocol” in order to ensure Signet’s supply chain is conflict-free. Signet has

expressed an interest in learning more about the CBRMT pilot projects and how they can credibly support

responsible sourcing of artisanal gold from the DRC. Engagement with Signet will require that the pilot

sites can provide assurances about the credibility of the supply chain and due diligence measures, and a

sufficient volume of gold to make the effort worthwhile. CBRMT will be meeting with Signet at the

OECD meeting in May to clarify their interest and concerns related to the ASM Gold Pilot Projects.

Artisanal Gold Council Gold Exchange Traded Funds (ETF): The Artisanal Gold Council (AGC) is a

not-for-profit organization focused on improving the livelihoods, environment, and health of the millions

of people involved in Artisanal and Small-Scale Gold Mining. One of the initiatives that the AGC is

working on the creation of a gold ETF, with physical ASM gold backing the investment instrument. In an

April 2015 conversation with CBRMT, AGC expressed their tentative interest in supporting pilot sites

from a demand perspective through the AGC Gold ETF. Pilot site implementers planning to explore this

opportunity should directly contact AGC, and build this into their Export Report.

Emirates Gold: Emirates Gold specialize in the processing of precious metals such as gold and silver.

Emirates Gold have developed a due-diligence framework based on risk assessment and modeled on the

guidance issued by the OECD, the London Bullion Market Association (LBMA) and the Dubai Multi

Commodities Center (DMCC). Emirates Gold has undergone and passed on due-diligence audits in

accordance with the LBMA guidance and also the DMCC guidance for 2014, 2013, and 2012. CBRMT

will be meeting with Emirates Gold at the OECD meeting in May.

Rand Refinery: Rand Refinery is the world’s largest refiner. Rand Refinery refine Banro’s gold

production the Twangiza and Namoya mines, and require that gold exported to its South African refinery

was produced in compliance with the Conflict Free Gold Standard as established by the World Gold

Council (WGC). Rand Refinery stated in a conversation with CBRMT that they would require 100

percent traceability, compliance with OECD Due Diligence Guidance, and a third party audit verifying

due diligence, in order to refine artisanal gold from any pilot project. Rand Refinery also made it clear

that they would only work with a gold exporter who they trusted, and suggested CBRMT consider INTL

FCStone and Sterns Casting and Refiners for such a role.

PAMP: PAMP has previously expressed learning more about the CBRMT pilot projects, and is a

member of the Public Private Alliance. CBRMT will be meeting with PAMP at the OECD meeting in

May to determine how serious their interest is, and what criteria would need to be in place in order to

establish a partnership with the pilot sites.

Other companies to explore for partnerships by CBRMT subcontractors include Brinks, INTL FCStone,

Sterns Casting and Refiners Metal Aurum, Metalor (formerly Métaux Précieux SA Metalor),

Johnson-Matthey, Argor-Heraeus, and Edalven.


2.2 BARRIERS AND CONSTRAINTS

Pilot projects designed to support conflict-free artisanal gold from the region will face numerous barriers

to success. It is important to recognize these barriers early in the design phase, and develop

implementation plans that directly mitigate the risks to project success from these conditions. Continuous

learning, flexibility and willingness to adapt will also be necessary to overcome these barriers and

constraints.

Policy and Legal Challenges Surrounding Tenure: Potential constraints for CBRMT artisanal gold

pilot sites include: the limited number of clearly demarcated exploitation zones for ASM (ZEAs), title

conflicts between the pilot site and any existing mineral claims, unclear legal status of artisanal miners on

industrial concessions, disputes between the title holder and the cooperative or another entity, and a

concern among industrial title holders that they could be sanctioned by the government for working with

ASM populations. Under the current (2002) DRC Mining Code, it is illegal for artisanal mining to take

place within any legally designated industrial concession area operating under either a permit for research

or exploitation. Under the small scale mining license (SSME license) and large scale mining license (EL)

it is possible to have mining related partnerships in these respective areas, but the code or amendment is

not explicit about this, which provides a grey area for the legality of establishing a partnership between a

cooperative and an LSM concession holder through the development of a protocole d’accord. Proposed

Mining Code Amendments may allow ZEAs to be designated and recognized within existing LSM

concessions. Currently, the holder of the Artisanal Exploitation Card (AEC) can only work in the ZEA

designated on the card, and a ZEA currently cannot be defined in an area covered by a valid mining title

(for example an exploitation license or exploration license).

Smuggling: There are widespread and deeply embedded systems for the smuggling of artisanal gold

throughout the DRC. Each of these systems includes localized supply chain dynamics, and include

varying types of incentives for diggers, buyers (negociants), exporters and government officials. Pilot site

locations are no different, and will experience competitive market forces from these illegal market forces.

External gold smuggling networks located in neighboring countries also still play an active role in the

contraband movement of DRC artisanal gold. CBRMT believes both “carrots and sticks” are necessary to

create the necessary incentives and control mechanisms for supply chain operators to engage in the legal

trade of artisanal gold.

Time and Resource Constraints: CBRMT pilot projects have a limited implementation time within

which to test the pilot chain of custody systems, institute corrective measures, and develop mitigation

plans to address risks. CBRMT also has limited resources to implement pilot projects. CBRMT and its

implementing partners should therefore strive to leverage outside resources from large-scale mining,

exporters, and gold purchasers in order to effectively launch pilot projects, while maintaining continued

technical quality and credibility.

Taxes and Rent Seeking Behavior: Rent seeking behavior and illegal taxation by armed groups and

government mining agents at the pilot site and/or along trade routes are a challenge to any pilot site and

implementers should be prepared to monitor and mitigate if necessary. Possible keys to success include

eliminating lowering, and/or standardizing taxes to incentivize actors to channel artisanal gold through

legal channels.

Supply Chain Complexities: There are insufficient systems for due diligence on statutory and customary

land tenure claims. Conducting this work involves collaboration with the Cadastre Minier and the Office

of the Minister of Mines in order to identify inconsistencies in records or potential concerns. In order to

select effective pilot site locations land tenure title and claim issues must be clear as to not delay or

interrupt pilot site work. Another constraint can be the unclear and often secretive methods used in

financing of the DRC gold trade. The issue of pre-financing, and the roles of buying houses, negociants,

comptoirs and buyers all need to be carefully examined.


Provincial, National, and Regional Acceptance: The potential lack of political will and support from

senior government officials and local traditional authorities could be a major constraint. It is critical that

CBRMT pilot sites have the full support of provincial, national and traditional authorities and such pilots

confirm, whenever possible to existing laws and regulations and guidance related to the extraction, trade,

and export of artisanal gold. Delays in the development and issuance of ICGLR certificates for ASM gold

could, for example, delay implementation. Additional constraints include conflict between customary

authority and statutory laws over access to and/or or use of subsurface resources. It should be noted that

the role of SAESSCAM, Division des mines, police de mines, CEEC, and DEARGRI is not always clear

on site.

Downstream Acceptance: Delays in identifying a willing buyer or refiner to accept artisanal gold from

CBRMT pilot sites is a potential constraint that will need to be addressed early in the project. Support

from USAID, the State Department, the OECD, the Public Private Alliance and international civil society

can help to broker these agreements, and assure downstream buyers and refiners that the systems,

processes and due diligence undertaken conform to international guidance and best practices.

Cooperatives: CBRMT recognizes that the successful launch of any ASM gold pilot will involve

engagement and partnership with a local cooperative. While cooperatives provide useful structures

through which to engage miners they frequently also suffer from gross mismanagement, elite capture and

limited capacity. As such, CBRMT should consider a program of basic administrative training for

targeted pilot project cooperatives. Topics should include keeping an updated list of members, collection

and recording of dues, issuing receipts, opening and maintaining a bank account, sound and transparent

accounting procedures, and keeping and preparing minutes of meetings. Technical training will also likely

be required during the pilot projects, with topics including both exploration training (reserve analysis) and

exploitation training (value added processes).

Conflicts and Security: The interests of different stakeholder groups operating in the gold industry are

widely divergent and often conflicting. Conflicts exist between many stakeholders of artisanal gold,

including ASM communities and industrial mining companies. Armed group presence is common in the

Eastern Congo, and security situations rapidly change. The 2016 Presidential elections could further

escalate tensions in the region.

Environmental Impacts: CBRMT pilot sites could face challenges related to environmental degradation

from the use of mercury and cyanide at mines sites. Evidence indicates that mercury will be a higher risk

because it it’s prevalence, affordability, and access for artisanal mining populations. Cyanide is often used

at more mechanized, small-scale mining operations, but a baseline assessment followed by regular

monitoring should be undertaken confirm the presence and availability of cyanide in addition to mercury.

Our implementing partners will be required to follow CBRMT’s Environmental Management and

Mitigation Plan, including educating mining communities about the risks of using mercury, and

introducing sustainable alternatives. Environmental impacts and mitigation are covered in more detail in

Section 5.0 of this plan.

Project Influenced In-Migration: CBRMT may face a rush of in-migration with the launch of the pilot

projects. If it is widely communicated that there will be legally-mined artisanal gold at these sites, there

could be raised expectations regarding production, employment opportunities, community development

and the ability to access social benefits, equipment or financing. In-migration issues can compound issues

of security, title, environment, and cooperative conflicts. All of these will need to be considered by our

implementing partner when designing their approach.


2.3 NECESSARY FACILITATING CONDITIONS

In light of the considerable constraints that exist for the CBRMT pilot projects, there are a number of

facilitating conditions that should be met, in order to find program success. We highlight six critical and

necessary facilitating conditions below:

1. Formal support from provincial and national government bodies before the launch of any pilot

projects.

2. Assurance and/or written agreement from a buyer/exporter and refiner to purchase ASM gold from

pilot sites.

3. A protocole d’accord or ZEA for pilot sites must be established prior to export of gold (Matete

excluded as it already has a ZEA), with support from USAID, national government authorities, and

other key actors as needed. If the pilot project is launched on or near a large scale mining concession,

there must be support from the concessionaire to allow ASM on the concession during the pilot

program and with written approval from relevant provincial and national authorities.

4. Collaboration with International Organization for Migration (IOM) and BGR to prioritize multi-

stakeholder validation missions to validate pilot sites for gold.

5. Stable and secure environment in which to implement pilots, particularly with elections approaching.

6. A registered cooperative (or able to become registered during the pilot period), who is willing to take

part in pilots.


3.0 PILOT MODEL OVERVIEWS

This section presents the baseline criteria for pilot site selection and model design, the three different

phases of the pilot projects, and the different pilot areas where activities are proposed to be launched. The

descriptions provide a rationale for launching pilot activities in each proposed area, and highlight the

major elements of the CBRMT pilot approach. This selection of pilot model options has been developed

with the input gathered from the February workshop in Kinshasa; relevant research reports; and ongoing

engagement with implementing stakeholders and downstream actors.

Pending approval of this implementation plan, CBRMT intends to release an RFP for the selection of

pilot site implementing partners in May. This request for proposals will be open competition that will

encourage the development of consortium teaming, and the inclusion of downstream actors. Our

suggested pilot models are meant to provide a framework for the pilot project implementers to work

within, while still providing opportunities for these partners to develop their own approach to certain

elements of the model including approach to traceability, due diligence, capacity building and

downstream engagement. We will request that pilot project proposal be designed to last for 12 months

while understanding that the final six months of the project would require an extension to the CBRMT

contract.

3.1 OVERVIEW

CBRMT proposes the launch of two initial project offices in Maniema and Orientale Provinces. The

Maniema pilot is located on an existing Artisanal Exploitation Zone (ZEA) at Matete, in the Muzizi

locality of Maniema Province, and will leverage the ongoing engagement between Banro and the

COMICA cooperative. The second model will be located on a yet to be determined concession in

Orientale Province, and will require a protocole d’accord with a legal and a willing title owner. Pilot

Projects will be led by one implementing partner (CBRMT subcontractor) with oversight from the

CBRMT project and home office team. Once the proof of concept has been established at Matete and in

Orientale, scaling-up can occur with additional time and resources at sites in South Kivu, Katanga, and

Orientale. CBRMT’s approach encourages continuous adaptation and learning in order to harvest lessons,

and improve implementation over time.

The specific number of mine sites to be supported by CBRMT at the initial pilots in Matete and Orientale

are difficult to determine with precision for several reasons: First, there is no agreed upon official

definition of a “mine site”. For example, the ICGLR Regional Certification Mechanism defines a mine

site as: “a mining concession recognized by the Member State government, owned or operated by an

individual, cooperative, state entity or corporate entity.” In contrast, the 2002 DRC Mining Code defines

a mine as “any deposit which can be exploited by means of open cast or underground mining, and/or any

plant for the processing or transformation of the products of such exploitation located within the

Perimeter of the mine”. Other sources state that a mine “site” is defined by (and named) by the artisanal

miners themselves and usually refers to a cluster of mine pits managed under a single chef du puit or

negociant. Others do not refer to a mine site but rather a “carré minier” (mining area), which is an area

defined by DRC Mining Cadastre (CAMI) as part of the permitting and registration process (for example

Matete has 6 carré minier). Last, but not least, others use mine site to refer to cluster of pits where a

traceability system is implemented.


Second, because the precise location of the Orientale pilot has yet to be identified, it is difficult to have an

accurate estimate of productive mine sites without a thorough baseline and enumeration. Third, mine sites

are abandoned and created over time, while others are only active in the dry season, thus any accurate

estimate would require a site visit. Fourth, if the definition of a mine site is the location where primary

identification (tagging) of material occurs (as was proposed in CBRMT’s original proposal) then the

number of mine sites is dependent upon what type of traceability system is being used, and is not a

uniform measure.

Accordingly, CBRMT proposes to define a mine site as a cluster of mining pits which are defined and

acknowledged by the multi-stakeholder validation team, the GDRC mining authorities (SAESSCAM,

Division des Mines) and relevant artisanal mining community to constitute a single “site.” There may be

multiple “sites” in a concession, and multiple locations where traceability is being implemented at a

single site. Based on this definition, CBRMT anticipates the export of legal artisanal gold from a

minimum of six mine sites in Matete and an estimated 20 mine sites in Orientale, for an estimated total

of 26 mine sites.4 The precise number of sites will be further refined after the project area in Orientale has

been selected and an enumeration study conducted. With additional funding from Banro or international

donors, scaling-up at Twangiza, Mukungwe, or Musebe can drive this number substantially higher.

3.2 BASELINE CRTIERIA

CBRMT hosted a small working group during the ASM Gold Workshop (see Annex B for more details)

to develop the key guiding principles of CBRMT’s pilot approach, and to ignite interest among

implementing partners to respond to the Request for Proposals, once released. With USAID’s approval,

Tetra Tech will include the following criteria in the request for proposals for CBRMT Pilot sites. CBRMT

will require subcontractors follow the “Must Have” criteria, and will request the subcontractor to specify

their approach to implementing the “Work Towards” criteria as part of their proposal. The criteria listed

for the pilot models include both must and have and work toward criteria in recognition that while certain

foundational conditions must be met, there are additional criteria towards which the pilot should be

striving towards; the distinctions between the two are clarified in the far right column

The first section of the table focuses on the pilot criteria from a site level. These criteria were used to

inform our selection of pilot areas, and will be useful for the CBRMT pilot site implementers to select

their exact mine sites during their initial Baseline Assessment. The second section of Table 3.1 outlines

criteria for the pilot model design.

4 The number of “mine sites” (per the definition provided above) is not known at Matete, but CBRMT can confirm that there are six

carré minier; accordingly the number of mine sites may actually be much higher but can only be confirmed after an enumeration is conducted


TABLE 3.1: PROPOSED CRITERIA FOR CBRMT PILOT MODELS

Criteria Must Have

Criteria

Work Towards Criteria

Definition of Criteria

PILOT CRITERIA – SITE LEVEL

Accessibility X

Sites must be less than a 1/2 day travel from a safe and reasonable place to spend the night. It is

important to note that more remote sites also means more armed groups, are more costly to reach for partners and for validation teams.

Mineral Rights X

The pilots must export legal artisanal gold. Artisanal gold is only legal if from a registered cooperative operating (or in progress of being formed) in a ZEA, or if there is explicit (written) permission (protocole d’accord) from the concession/title holder and approval from government officials for this approach.

Co-Operative Registration And Structure

X X

Pilots must work with a cooperative with a legal existence or one with willingness to be reformed if needed. Pilot projects should work towards a “well” governed cooperative that is managed in a transparent

manner, where members are engaged and represented at higher levels of leadership and profit sharing occurs.

Security

X

A site must be green validated by time of export. Revalidation may need to occur. The site should be

chosen by looking at risks that could threaten the system in and around pilot site, and ensure there is a secure “perimeter”. Sites must have a functional civil society in place that can help monitor local security and report on

incidents.

Gold Production Volume X X

There must be a sufficient production to support a sustainable business model at the pilot area. Pilots should works towards identifying the minimum amount of gold that needs to be produced, as well as

develop production goals in order to create profit.

Child Labor X X

Pilots must conform to DRC law regarding child labor. Work towards building relationships with community to promote self-enforcement. It may be necessary to

incentivize youth to stay out of the mine.

Human Trafficking & Sexual Exploitation X

Implementing partner should works towards addressing coercion, sexual exploitation and trafficking of persons at or near CBRMT funded sites in collaboration with other partners, and work towards developing

a mechanism to report trafficking and sexual exploitation at mine sites. (* would require added resources).

Gender Equity

X X

Must conduct a baseline assessment and regular M&E to determine and monitor the different roles of

women in and around the pilot site. Must educate actors about the law related to women working at mine sites. Work towards building the capacity of state and civil society to work on gender specific issues, while

collaborating with other partners focusing on gender issues

Negociants and Comptoirs

X Must work with licensed negociants, maison d’achats and/or comptoirs. Must understand how pre-financing is structured.

PILOT CRITERIA – MODEL DESIGN

Conformity with Standards/Guidance X X

Must conform to OECD Due Diligence Guidance and conduct due diligence. Must comply with DRC Law. Work Towards compliance with ICGLR Regional Certification Mechanism.

Integration With GDRC X X

Must interface and be compatible with GDRC objectives regarding the establishment of legal artisanal gold. Data must be transparently shared with GDRC, while maintaining responsibility to security and rights of

community.


Criteria Must Have

Criteria

Work Towards Criteria

Definition of Criteria

Must work directly with SAESSCAM, Division of Mines, and CEEC. Work towards reducing corruption and rent seeking behavior.

Traceability X X

Traceability must be compatible with OECD Due Diligence Guidance. Work towards full traceability from mine to export, with the expectation that full traceability will occur by the

time of export.

Certification X Must conform with any export certificate to be used in the DRC, which will be determined by the GDRC.

Environmental Monitoring and Mitigation

X X

Must follow the CBRMT EMMP Must conduct an environmental baseline to capture potential environmental impacts of CBRMT pilot sites. Must conduct a baseline measurement of the availability and use of mercury and cyanide at CBRMT pilot

sites. Must work outside of a protected area. Must work towards reducing environmental and health impacts through technical interventions and

education.

Incentives

X X

Must identify appropriate incentives and incentive structures for different actors throughout supply chain

prior to implementation. Must monitor and evaluate how CBRMT pilot sites impacts earnings and livelihoods. Work towards reducing official tax rates for artisanal gold. Work towards improved productivity, health, and safety through technology transfer and/or capacity

building.

Political Will X

Must have political will and support from national, provincial, local and traditional authorities, and local buy-

in.

Financing X X

Must conduct due diligence on providers of pre-financing. Work towards implementing alternative and sustainable financing mechanisms through legal channels

when appropriate.

Sustainability Plan X

Work towards developing a business plan for cooperatives that earns profit, covers operating costs,

creates profits for individual coop members, allows for future investments, and enables sustainability of operations at the site in an environmentally responsible manner.


3.3 PILOT PHASES

CBRMT pilot projects will conducted in three phases; an Enumeration and Assessment Phase, an

Implementation and Capacity Building Phase, and an Export and Sustainability Phase. Each

implementing partner will be expected to develop deliverables specific to each phase to be delivered to

CBRMT for review and oversight. The deliverables are explained in more detail below Table 3.2.

CBRMT plans to release an RFP for subcontractors in May 2015, requesting that these deliverables are

included in their proposal timelines.

TABLE 3.2: CBRMT PILOT PHASES AND DELIVERABLES

Phase One: Enumeration and Assessment – Months 1-3

Activities: Deliverables:

Miner and Site Enumeration Staff and Resource Report

Research and Stakeholder Engagement Baseline Assessment Report

Communication Plan Development Communication and Stakeholder Coordination Plan

Training Module Development Training and Capacity Building Plan

Traceability, Due Diligence, and Supply Chain Planning

Traceability and Due Diligence Plan

Understand structure of legal/illegal taxes in pilot site area

Monitoring and Evaluation Plan

Overview of land tenure systems and rights including ZEAs, customary rights and legal title holders.

Land Tenure and Property Rights Assessment

Phase Two: Implementation and Capacity Building - Months 4-9


Supply Chain Analysis and Strengthening Downstream Acceptance Report

Technical Training Technical Intervention Report

Communications Plan Implementation Capacity Building Progress Report (monthly)

Traceability Approach Implemented Traceability and Due Diligence Progress Report (monthly)

Due Diligence Approach Implemented Stakeholder Coordination Update Report (monthly)

Environmental Baselining Environmental Baseline Report

Cooperative Business Planning Cooperative Business Plan

Phase Three - Export and Sustainability – Months 10-12


Export of Legal ASM Gold Sustainability Report

Plan for Pilot Area Sustainability Final Report

CBRMT will require that subcontractors submit the following deliverables for CBMRT approval, and

will develop a deliverable-based payment schedule. Proposed deliverable due dates are in parenthesis

after the deliverable title. Area-specific details to be included in these deliverables are listed in Section

3.4.

Staff and Resource Report (Month 1): Subcontractor will update their proposed approach to

staffing and management on the pilot program based on CBRMT’s feedback to their pilot site

proposal. This report will include final details on the qualifications of personnel, the use of second-

tier subcontractors, the proposed use of local organizations, as well as any additional relevant

proposed partnerships. The subcontractor will describe the role of all headquarters staff in the

effective implementation of the pilot program.

Baseline Assessment Report (Month 3): The Baseline Assessment Report will describe progress on

miner enumeration, as well as provide an overview of the stakeholder analysis and engagement that

has occurred during the first three months of pilot work. Miner enumeration should be conducted in

collaboration with civil society, industry, and government officials as possible. The Report should


detail all progress made related to the establishment of local partnerships, engagement with miners

and cooperatives, local conditions and working environment, and in defining mine site locations for

pilot activities made during the first three months of pilot project work. This report will also detail

efforts and successes made with engagement with provincial government officials, Division de

Mines, SAESSCAM, CEEC, and civil society. The report should outline and document the legal and

illegal taxes that exist throughout the pilot site gold supply chain, and present an approach for

reduction of taxes, if at all possible, to be implemented during the remainder of the pilot program.

The report should also assess the tenure and property rights in the area, including customary property

right in the area.

Training and Capacity Building Plan (Month 3): This report will detail the subcontractors

approach to training and capacity building during the pilot program, including number and type of

targeted beneficiaries, training schedule, expected outcomes and an overview of the training modules

to be delivered.. We expect implementing partners to focus heavily on capacity building and training

for cooperative members, provincial staff from Division des Mines, CEEC, and SAESSCAM and

local civil society. Drawing on a recommendation from CBRMT’s Organizational Function Plan, we

will require implementing partners to develop modules in collaboration with targeted beneficiaries

anticipated training modules are explained in Table 3.3. Gender should be integrated throughout the

training and capacity building sessions. CBRMT will develop a specific modules for gender and land

tenure and property rights for the mining sector. The subcontractor should plan to collaboratively host

these two specific training modules, and should plan to lead the other training modules. Training

modules are expected to train a minimum of 150 people per pilot area.

TABLE 3.3: ILLUSTRATIVE CBRMT TRAINING MODULES

Module Target Audience Illustrative Training Description

Business Administration

Cooperative Training should include basic administration including basic book keeping and accounting, marketing, managing meetings, decision-making, record keeping, and data gathering on site.

Business Planning Cooperative Training should focus on cooperative operating costs, profit sharing for coop members, estimating costs of technical upgrades for the cooperative, and enables sustainability of operations. Module should be used as a forum for gathering input for the Cooperative Business Plan deliverable.

OECD Due Diligence Guidance, ICGLR RCM Certification Requirements, DRC Mining Code

Cooperative, Civil Society, SEASSCAM, Division des Mines

Ensure that members of the cooperative, civil society, and local government bodies are sensitized and knowledgeable on the OECD Due Diligence, ICGLR RCM Certification, and the DRC Mining Code and relevant DRC legislation. Ensure that civil society are aware of their roles and responsibility on local oversight committees (comites de suivi).

Environmental Impact Reduction

Cooperative Mercury reduction training, education campaigns about the health hazards of mercury, training on damage to biological and ecological functions from ASM.

Occupational Health and Safety

Cooperative Health and safety training, and training related to structural integrity of ASM gold mining activities—including open pit and tunneling.

Gender Cooperative, Civil Society, Division des Mines, SAESSCAM, Mine Police

Training to elaborate and clarify the gender roles in the ASM sector and identify how the pilots can be more gender responsive to enable full and equal access to both men and women.*Modules to be developed by the CBRMT team

Land Tenure and Property Rights

Cooperative, Civil Society, CPS, Division des Mines, Mine Police

Participatory workshop to discuss conflicting claims between statutory and customary authorities to land and sub-surface rights and provide training and technical assistance on how to resolve such conflicts. *Modules to be developed by the CBRMT team.

Technical Assistance and Production Improvement

Cooperative, SAESSCAM

Trainings could include; Exploration training, including reserve analysis or deposit geology and/or Exploitation training, including value added processes, mechanization of equipment (based on technical equipment provided), and building capacity to implement effective processing facilities with improved technology.


Communication and Stakeholder Coordination Plan (Month 3): The Communication and

Stakeholder Coordination Plan will describe how the subcontractor plans to communicate with

project beneficiaries, project stakeholders, and those impacted by pilot site activities. The plan must

be in accordance with USAID CBRMT Branding and Marking requirements, should outline an

approach to pilot site communication, and should propose an ongoing mechanism for collaboration

between pilot project stakeholders to ensure necessary discussion and communication occurs. This

Plan must include an approach to engagement and communication at the local level (customary

leadership, civil society, and community members) as well as external stakeholders (DRC Ministry of

Mines, ICGLR and downstream buyers and users).

Monitoring and Evaluation Plan (Month 3): The implementing partner should work with CBRMT

staff to develop a monitoring and evaluation plan. Key indicators should capture information relevant

to environmental impacts such as mercury and/or cyanide use, and negative impacts on biodiversity,

the impact on women and youth, the number and type of cooperative members trained, and pricing

and production figures both at the mine site and at export. By Month three, it is anticipated that the

pilot project subcontractor will begin reporting progress of the agreed upon indicators to CBRMT.

Traceability and Due Diligence Plan (Month 3): The implementing partner should submit a

Traceability and Due Diligence Plan to be approved by CBRMT and USAID by the end of the third

month of pilot implementation. While it is expected that subcontractor will present a convincing

approach in their proposals, this plan will update their methodology for chain of custody and due

diligence criteria (as listed in Table 3.1) based on their on the ground experiences. The Traceability

and Due Diligence Plan will detail how mineral are being tracked and traced from the mine of origin

up to the point of export. This plan should ensure that roles and responsibilities of all traceability and

due diligence providers are clearly defined and monitored. The plan must explain how data from the

chain of custody system will be transmitted to CBRMT and the ICGLR Secretariat. Collaboration

with DRC NGOs who have experience in the area of Due Diligence is likely required in order to

develop local monitoring networks. The plan should explain progress towards the development of

local oversight committees (comites de suivi) in order to monitor conditions in and around targeted

mine sites, and report on any issues of concern. Establishing these local committees may require

upfront commitment in training, and ongoing support, which needs to be addressed the Training and

Capacity Building Plan. The plan must also include an approach to ensuring that the pilot area is

green site validate by the multi-stakeholder joint validation mission by the time of export.

Technical Intervention Report (Month 4): CBRMT will not define the portfolio of incentives that a

subcontractor should include in the pilot site. The proposed incentives in this report should be directly

linked to the Training Modules in the case of the provision of technical equipment to miners. This

equipment/technology could include, but is not limited to: improved sluices/sluice

technology/improved sluice linings, hand-cranked centrifuges for gold concentration, or crushing and

grinding equipment. The report should simply provide a description of technical interventions and a

rationale for why the technical interventions will improve participation in the pilot model’s success.

Downstream Acceptance Report (Month 4): The report should highlight a clear agreement with

exporters, and should define the roles of a buying office and/or negociants. The report should provide

a detailed overview of actors in the current supply chain, and the current status of pre-financing

arrangements. The implementing partner must conduct due diligence on those providing pre-

financing, and work towards implementing alternative financing mechanisms through legal and

sustainable channels if necessary. The implementing partner must articulate and design a convincing

model for a buying network and artisanal gold export. The plan must conform to any export

certificate to be used in the DRC, which will be determined by the GDRC.


Environmental Baseline Report (Month 4): The implementing partner will produce a baseline

environmental assessment documenting the current status (is mercury or cyanide being used and/or

available) as well as anticipated impacts on both ecosystems and human health, at or near CBRMT

pilot mine sites and steps to mitigate the identified risks.

Cooperative Business Plan (Month 6): The pilot model will develop a business plan for all

cooperatives working in pilot sites that describes cooperative organizational structure and governance

(including decision-making), operating costs, strategies for sustainability of operations , including

future investments in technical upgrades for the cooperative,. The Business Plan should be developed

with input gathered at the Business Planning Training Module. The pilot projects should work

towards advancing these cooperatives towards a “well” governed state that is managed in a

transparent manner, where members are engaged and represented at higher levels of leadership, and

profit sharing occurs. This should include the establishment of a grievance procedure for disaffected

members/workers. The plan should propose a road map for “creuseur” formalization, to be operated

by the cooperative. This will consist of a database, and a mechanism to monitor the numbers of

miners on the site in a daily basis. The implementing partner must ensure that cartes de creuseur are

obtained by miners.

Monthly Report (Months 6–10): The subcontractor will submit a monthly report detailing the

amount of gold being exported, number of miners benefitting from CBRMT support, risks and

challenges, progress made in meeting the targets set in the Training and Capacity Building Plan, the

Traceability and Due Diligence Plan, the Communication and Stakeholder Coordination Plan, and

will highlight project success stories and challenges.

Sustainability Report (Month 11): The Sustainability Plan will articulate an approach to ensuring

the export of legal and responsible ASM gold after CBRMT funding is no longer occurring, lessons

learned and opportunities for scaling up. The plan should layout necessary next steps for civil society

and government officials in order to ensure progress and gains made during CBRMT are carried on.

Final Report (Month 12): A final report documenting important lessons learned, as well as

opportunities for future donor-funded or market-driven interventions to further expand the legal ASM

gold industry.

3.4 PILOT AREAS

CBRMT proposes to launch pilot activities in two initial areas: Matete in Maniema Province and Ituri,

Orientale Province. Should additional resources be made available, an additional set of area for scaling up

are detailed after the descriptions of the first two pilot areas. CBRMT will not pre-determine or prescribe

where implementing partners should work, as this is an open competition. However, certain implementing

partners have knowledge and experience in some areas more than others. For example, Partnership Africa

Canada is well-positioned to provide responses to an approach in Orientale, where they have an

understanding of the local context and capacity of local partners. In Maniema, we believe that Better

Sourcing Program/GeoTraceability or the Alliance for Responsible Mining would be well–suited to work

with Banro given their experience in working with the private sector to ensure that artisanal supply chains

have access to international conflict-free markets. CBRMT also recognizes the desire of the GDRC to

pilot the ITOA traceability model; as such, the Request for Proposals will encourage applicants to clarify

how their approach can incorporate ITOA, either independently or paired with another traceability system

that is adapted for this purpose.


3.4.1 PILOT AREA ONE: MANIEMA – ZEA MODEL

Proposed Total Subcontract Budget for Maniema Pilot Area: The total proposed subcontract budget

was $300,000 for pilot project staff, office, and activities in Maniema. The budget for this pilot is slightly

lower than Orientale based on the assumption that additional resources can be leveraged and costs shared

with Banro to advance initiatives at Matete, or at an alternative location for efforts in South Kivu (see

scaling-up plan). Recent CBRMT conversations with Banro indicate that the company is willing, for

example, to distribute a fixed amount of additional technical equipment to the Coopérative Miniére des

Creuseurs Affectés (COMICA) cooperative at Matete under the guidance of the CBRMT Subcontractor.

As of September 2014 Banro had provided approximately $250,000 of equipment to COMICA. Twenty

percent of this originally purchased equipment remains available to distribute and could be utilized as

incentives for participation in the pilot program. Additional resources added to the pilot project funding

could be used for scaling-up of traceability and due diligence to additional mine sites at alternative

locations, the purchase of additional technical equipment to provide to COMICA, additional capacity

building for local stakeholders, or to implement the “Work Towards” criteria defined in the previous

section.

Anticipated Staff Resources: During the RFP phase, subcontractors will propose their approach to

partners, staffing, and office location for the Matete Pilot Area. Subcontractors will be expected to update

this approach based on CBRMT input and will deliver a Staff and Resource Report in the first month of

pilot site implementation, which must be approved prior to mobilization. CBRMT anticipates that staffing

for the pilot will include: 1 Full-Time Due Diligence and Traceability Manager, 1 Full Time Capacity

Building and Communications Manager, 1 Short Term Technical Expert, and any additional consultants

and/or staff necessary in order to complete the deliverables outlined above. Full-time staff could

potentially be co-located with IOM or a local NGO to reduce costs, or could be based in the nearby town

of Salamavila. Banro has also stated their willingness to provide limited helicopter trips from Bukavu to

Matete to the pilot project team as necessary.

Pilot Model Background: In early 2013 approximately 650 artisanal miners were repositioned from the

Banro concession at Namoya to Matete5, which was identified as a productive site outside of Banro’s

official concession area (25 kilometers from the Namoya site) where deposits could be artisanally mined

in a safe and secure manner off of the concession. According to a PROMINES report, as of June 2014,

there were 820 members of the COMICA cooperative working at Matete, The miners are originally from

many different regions of the country and range in age from 18–70. The PROMINES study recognized

the presence of a large number of government officials on the site (approximately 17 government agents)

from police des mines, SEASSCAM, Direction Generale des Recettes de Maniema, SAESSCAM, and

Division des Mines.6 Based on recent CBRMT conversations with Banro, there is concern that members

of the COMICA cooperative or other local artisanal miners continue to, or will increasingly begin to,

illegally encroach on Banro’s Namoya site. This is a particularly challenging issue for all stakeholders

involved, because it is apparent that the Namoya site is more productive in terms of gold production

capacity than Matete, and is less burdened with the presence of government officials charging legal and

illegal taxes.

IOM and CBRMT, in collaboration with Banro, have developed a draft action plan for work with ASM

communities on the Matete Site. The pilot project on Matete will build on this foundation and serve to

support a collaboration among Banro, IOM, and CBRMT. During the past two years Banro has provided

technical advice and geological analysis to COMICA, and cooperatives statutes were developed with

5 Banro 2014 Sustainability Report: A 360˚ Approach to Sustainability. www.banro.com/i/pdf/Banro-9634-CSR-EN.pdf

6 Estelle Levin and Rupert Cook (2014). PROMINES. Etude comparative des systèmes de Certification et de Traçabilité en cours en République Démocratique du Congo (RDC).

http://www.banro.com/i/pdf/Banro-9634-CSR-EN.pdf


assistance from SAESSCAM, Division des Mines, and IOM. The pilot model should build upon the

lessons learned from these initiatives on Matete, and advance the efforts of exporting legal artisanal gold

from the site.

Rationale for a Pilot Site on Matete: The proposed pilot at Matete has an established partner in IOM, a

registered cooperative willing to collaborate in COMICA, and a large-scale mining company in Banro

with the resources and interest to contribute to the pilot project. Matete would serve as one of the first

pilot projects for artisanal gold supported by a major large-scale mining stakeholder in the DRC, and

could establish an important precedent for other LSM stakeholders throughout the DRC. The ZEA at

Matete has been Green Site validated from the multi-stakeholder joint validation mission, and is

considered secure and free from armed group presence. The effort will highlight Banro’s efforts to work

collaborative with the artisanal sector, helping to maintain their social license to operate, and will

contribute to the stability of the gold industry in the DRC.

FIGURE 3.1: LOCALIZATION OF NAMOYA PERMIT AND MATETE ZEA

Produced by CBRMT from Banro/IPIS/BGR/UNOCHA sources

Tenure: The designated ZEA at Matete sits outside of the Namoya concession in Maniema Province, and

includes six different “carré minier” within the confines of the zone. In 2013 Banro reached an agreement

with artisanal miners in Namoya to reposition them to Matete. The traditional leaders at Matete have

been, and should continue to be consulted with and engaged with throughout the pilot program. Previous

concerns about the location of the Matete site being located on the Domaine de Chasse Luama-Kivu

hunting reserve have been resolved, as by DRC law the extraction of minerals is allowed within a hunting

reserve. Regardless of DRC law, additional measures will need to be taken implemented to ensure that the


introduction of a pilot project monitors for any potential negative impacts to the surrounding ecosystem

and habitat.

Key Roles of Pilot Implementing Partner:

Ensure that the pilot criteria described in Table 3.2 are implemented during the pilot programs.

Oversee and coordinate with the selected traceability provider.

Ensure the submission of all deliverables described above in a timely fashion.

The Implementing Partner is responsible for Capacity Development, Due Diligence, Traceability,

and the development of a strategy for the financing and export of artisanal gold from Matete as

described in previous sections.

The implementing partner should work with CBRMT staff to ensure that the monitoring and

evaluation plan is implemented. Key indicators should capture information relevant to

environmental impacts such as mercury and cyanide use, the impact on women and youth,

number and type of cooperative members trained, pricing both at the mine site and at export and

production figures.

Lead Stakeholder Coordination for the pilot project. Stakeholder coordination will include:

The implementing partner will work directly with SAESSCAM, Division of Mines, CEEC,

and other government stakeholders. The implementing partner should develop an ongoing

mechanism for collaboration between pilot project stakeholders to ensure discussion and

communication occurs.

The implementing partner shall identify and work with civil society organizations to develop

provincial-level monitoring committees. Local NGO organizations to consider could include

organizations such as OGP, BEST, Max Impact, and CENADEP, which are all active near

Matete.

The implementing partner will be the main point of contact for the pilot project between the

COMICA cooperative and CBRMT.

The implementing partner will formalize the role of the customary leader in land

management, and will incorporate customary leadership (Mwami) and politico-administrative

authority considerations into the pilot project. This approach should be detailed as part of the

Communication and Stakeholder Coordination Plan.

The implementing partner will work under the supervision of CBRMT’s Eastern Congo

Coordinator Armel Nganzi and CBRMT’s home office, to manage on the ground activities.

The implementing partner should collaborate with IOM to ensure that development of the

planned pointe de vente in the environs of Matete, and the associated point of sale equipment,

is designed in accordance to the needs of the local community. The implementing partner’s

technical expert should provide advice to IOM during the development and construction

stages of the Pointe de Vente (planned for Summer 2015), which should be described in detail

as part of the Baseline Assessment deliverable.

The partner will collaborate closely with Banro technical staff to ensure pilot project

planning, implementation and success. The implementing partner should become a member

of a planned task force (with IOM, Banro, and CBRMT) that is in the early stages of

development. The implementing partner will integrate civil society engagement and

partnerships into their pilot approach in Maniema.


Capacity Development and Training:

Articulate an approach to all Training and Capacity Building, as outlined in Section 3.3, including

developing a business plan for COMICA that covers cooperative operating costs, creates profits

for coop members, allows for future investment in technical upgrades for the cooperative, and

enables sustainability of operations at the site.

The implementing partner will coordinate with IOM and CBRMT on the Business Administration

training module. The implementing partner should develop an approach that incorporates and

maintains the training and capacity building that IOM has begun, as IOM has a limited time

frame for their intervention at Banro.

The partner should work with COMICA to develop a standard set of forms and templates that

cooperatives can use to collect statistics on such key elements as cooperative members, pit or

tunnel staffing, gross production per pit, and division of that ore among workers, pit boss, and

financial backers, gold yield per bag of ore per miner/pit boss; and disposition of that gold. The

implementing partners (and civil society partners) should train targeted cooperatives on how to

use these forms.

Due Diligence:

Matete has been validated as green by the multi-stakeholder validation team, and verified by as

being free of conflict minerals, free of human rights abuse indicators, and demonstrating

acceptable safety and environmental practices according the multi-stakeholder joint validation

mission. The pilot project team must ensure that site is green validated at the time of gold export

and follows the prescribed timelines established by GDRC regulations.

The implementing partner must engage with the Provincial oversight committee (Comités

Provincaux de Suivi) to monitor conditions in and around targeted mine sites, and report on any

issues of concern. This will require an upfront commitment in training, and ongoing capacity

building support which could be provided by local NGOs who have experience in developing

local monitoring networks.

The implementing partner should explore the prospect of working with SAESSCAM, Division of

Mines, and CEEC as due diligence partners, and should gather input from IOM to develop a plan

to build the capacity of local government and civil society stakeholders to conduct due diligence.

Traceability:

Traceability should be funded by the exporter of the gold, or an alternative and sustainable model

must be proposed by the implementing partner.

The implementing partner will develop a traceability plan for artisanal gold to be approved by

CBRMT and USAID. This plan should ensure that roles and responsibilities of all traceability

service providers are clearly defined, accepted, and monitored.

The implementing partner needs to manage the reliable and rigorous monitoring of production

and collection of production statistics.

Pilot Model Incentives:

The implementing partner should work closely with Banro to identify what forms of assistance,

either financial or technical, can be provided to the cooperative and/or surrounding communities.


Cost sharing for technical interventions may be financed by Banro, COMICA, or other supply

chain stakeholders in collaboration with CBRMT. The technical intervention approach should be

developed in coordination with Banro and with feedback, engagement, and input from COMICA.

The pilot project should engage with Maniema (and South Kivu if necessary) Government

officials to convey the importance of a favorable tax structure to the pilot projects success, and

work towards reduced tax rates for the pilot project.

Potential incentives could include:

The creation of a local development fund, with appropriate additional funding.

Any of the technical interventions mentions in Section 3.3 designed to increase the efficiency

and quality, as well as health and safety of ASM activities.

The funding of a specific community project, such as sanitation upgrades or village level

health care.

3.4.2 PILOT AREA TWO: ORIENTALE

Proposed Total Subcontract Budget: $400,000 Subcontract for pilot project staff, office, and activities

in Orientale. This budget includes $50,000 for the purchase of technical interventions and equipment.

Additional funding should be leveraged if possible from LSM stakeholders operating in Orientale.

Anticipated Staff Resources: During the RFP phase, subcontractors will propose their approach to

staffing and office location. Subcontractors will be expected to update this approach based on CBRMT

input, and deliver a Staff and Resource Report in the first month of pilot site implementation, which must

be approved prior to mobilization. It will be strongly recommended that the office be located as closely to

mine sites as possible to bolster the efficacy and monitoring of chain of custody initiatives. CBRMT

anticipates that the pilot site implementer should provide: 1 Project Manager, 1 Due Diligence and

Traceability Manager, 1 Capacity Building and Communications Manager, 1 Short Term Technical

Expert. Full-time staff may be co-located at a local NGO, or at a location determined by the CBRMT

subcontractor.

Pilot Model Background: There are numerous opportunities for pilot activities in Orientale Province.

Areas for subcontractors to consider include Concessions 38 and 39, and Concession 40 in Ituri, as well

as regions in North-West Orientale (near Bondo). Although no current ZEAs are designated in Province

Orientale, there is strong political will for the export of legal ASM gold from Orientale. Governor

Bamanisa has made support for pilot projects clear, including public commitments to establish tax free

zones in order to stimulate legal artisanal mining zones. Governor Bamanisa has publically requested

mine site validations to begin as soon as possible in the province. Subcontractors must work in

collaboration with downstream partners during site selection.

Concession 40: The basin that lies north-west of Bunia in Province Orientale is dense in productive

artisanal gold sites and active mining populations. Mining activity in Orientale is less thinly spread here

in other regions of the country, with a large amount of the ASM gold activity occurring near Mongbwalu

in Ituri. The city of Mongbwalu is located approximately 80 kilometers from Bunia, and has been called

“the Lungs of Ituri” because of gold’s importance to the region. The economy of Mongbwalu is centered

on gold mining, with estimates that up to 72 percent of the population partake in ASM activities.

Approximately 300–350 kilograms of ASM gold per month (roughly 800 lbs. a year) leaves the


Mongbwalu region.7 In 1966, the Office des Mines d’Or de Kilo-Moto (OKIMO or Kilo-Moto) was

granted exclusive mining rights to 83,000 km² in the Ituri districts of Province Orientale. OKIMO divided

its gold reserves into three concessions (38, 39, and 40) in order to spur industrial development.

Concession 40 comprises 8,191 km² around Mongbwalu, including the Adidi, Makala, and Senzere

underground mines. During the 1990s, OKIMO leased its concessions to ASM and Small-scale Miners,

where OKIMO collected taxes on the sites. After major battles during the Second Congo War for control

of Mongbwalu in 2002 and 2003, a joint venture was negotiated in 2003 for the exploitation of

Concession 40, which covered 8,191 sq. km around Mongbwalu. AGK (AngloGold Ashanti Kilo) was the

partnership of OKIMO (13.79 percent) and Anglo-Gold (86.21 percent).8 According to International

Alert, there are an estimated 365 sites at Concession 40, with 33 in the Mongbwalu area. Sites are often in

riparian areas, flood plains, or at tailings sites. Each site has up to 10 holes, and up to 15 people working

in each hole. There are approximately 250 negociants buying gold in Mongbwalu and its surrounding

villages and camps. Two types of gold are mined in Mongbwalu: dry gold (90–95 percent purity) and

amalgam gold (82–90 percent purity). Several mining methods are used:

Underground: At the three closed industrial mines of Adidi, Senzere and Makala.

Pit mining.

Alluvial mining–often with dredges.

In August 2007, the Cadre de Concertation (CDC), conducted a survey of miners in Mongbwalu and

nearby mining communities which showed that ASM communities were faced with health risks due to

exposure from rock dust, mercury, cyanide, and acid, as well as health and safety risks from mine

collapses and slides. 9 In February 2015, AngloGold Ashanti sold its shares in AGK, which were acquired

by Mongbwalu Gold Investments (MGI). CBRMT has reached out to the Managing Director at MGI to

inquire about participation and collaboration on the pilot projects.

Kibali Goldmines: Kibali Goldmines are a joint venture with AngloGold Ashanti, Randgold, and

SOKIMO, which began its first full year of operation in 2014. Kibali Goldmines hold 10 permits on

Concession 38 (near Durba and Watsa) with Randgold acting as the operator. Kibali produced 526,627

oz. of gold in 201410, causing a dramatic increase in the amount of gold produced in the DRC. Kibali is

critically important to the economy of the DRC, with the Kibali Goldmines ranking as one of the largest

gold mines in Africa. In 2014, as stated on the Randgold website “the main project RAP was completed

and infrastructure handed over to community,” with a target to increase local economic development

activities in 2015. In conversations with CBRMT, Randgold has stated their tentative interest in

contributing to a pilot model, should a ZEA be designated for ASM communities, in order for ASM

communities to legally operate near the Kibali.

Other Areas: Other promising areas in Orientale for pilot projects can be proposed by subcontractors.

Conversations with Emeko RDC SARL highlighted that the areas near Bondo should be considered as an

area with high prospect for success, due to its safe and secure location, and the economics of gold being

favorable for such a project (low price of gold paid to miners by area negociants). In the area near Kibali

Goldmines there are additional industrial exploitation permits held by Moku-Beverendi, a joint venture

7 Van Puijenbroek, J.; Mongo Malolo, E., and Bakker, J. 2012. A Golden Future in Ituti? Which Perspective for Gold Exploitation

in Ituri, DR Congo? IKV Pax Christi and Reseau HAKI NA AMANI (RHA).

8 Fahey, Dan (2008). "LE FLEUVE D’OR: THE PRODUCTION AND TRADE OF GOLD FROM MONGBWALU, DRC". L’AFRIQUE DES GRANDS LACS. ANNUAIRE 2007-2008.

9 The Role of the Exploitation of Natural Resources in Fuelling and Prolonging Crises in the Eastern DRC, January 2010, International Alert.

10 Randgold Resources: Kibali Gold Mine. http://www.randgoldresources.com/kibali-gold-mine

http://www.ua.ac.be/objs/00210788.pdf

http://www.randgoldresources.com/kibali-gold-mine


between SOKIMO and Moku Goldmines, which could also potentially be a partner in ASM Gold

Traceability efforts. The zone from Bunia to Watsa is rich in gold and artisanal mine sites, which may be

proposed by implementing partners in their response to CBRMT RFP.

Rationale for a Pilot Site in Orientale:

Orientale is an important region from the perspective of ASM gold production, and CBRMT has

no other major presence in Orientale.

Strong political will and interest in the launch of traceability initiatives

Working on a concession in Orientale could prove the efficacy of a concessionaire supporting

artisanal mining on their concession, and could prove to be an interesting comparison with the

Matete ZEA pilot.

Concession 40 Rationale: Stakeholders on Concession 40 have historical precedent of

engagement between the LSM concession holder and the ASM communities. The CEMAO

cooperative has been open to conversations and partnerships in the past. Civil society in Ituri has

advanced capacity and understanding of issues key to the establishment of due diligence systems,

and maintain an active presence in and around Concession 40 that can be utilized on a pilot

project.

While security remains a concern in the area, Concession 40 is free of militia and has a reduced

DRC military presence compared to times in the recent past. Traceability and due diligence

mechanisms can help support lasting peace and sustainable development in the region.

OECD is focused on bringing responsible ASM gold to market from the two main mines

identified as ripe for such projects in their baselines, one being Mongbwalu.

Kibali Gold Mines Partnership Rationale: Kibali Gold Mines have stated their initial interest

to CBRMT pilot activities, under the strict condition that a ZEA be established for all ASM

activities. Kibali Goldmines is important to the economy of the DRC, and mitigating social

conflict near the area is important for all mining stakeholders. It should be noted that a

Resettlement Action Plan was completed by Kibali in 2014 with a target to increase local

economic development activities in 2015. Dissatisfaction with the resettlement plan could create

a difficult working environment.

Tenure: CBRMT recommends that the implementing partner, with support from USAID, Ministry of

Mines, and CBRMT, work to establish an MOU (using the example from the protocole d’accord

developed in 2013 between civil society and AGK on Concession 40) in order to establish the working

conditions for a pilot site on a concession in Orientale. CBRMT has been coordinating with LSM and

mining stakeholders in Orientale to lay the groundwork for the establishment of a pilot project, which

highlight that it may be necessary to facilitate the establishment of a ZEA.

MGI, Randgold, Emeko, and SOKIMO should be extensively engaged by the pilot site implementing

partnering in order to explore the opportunity for collaboration. The terms of the MOU should dictate

what percentage of profits will be given to the concession holder for pilot model participation. There may

be other opportunities to establish similar arrangements on other Société minière de Kilomoto (SOKIMO)

sites in Orientale, as agreements between cooperative and SOKIMO have already been established in the

past.


Key Roles of Subcontractor:

Establish a formal MOU with a well-respected private sector entity (for example Emeko, INTL

FCStone, or Brinks) who is familiar with supply chain and market dynamics and is interested in

partnering with CBRMT to purchase from the pilot sites.

Conduct a baseline assessment to confirm a suitable pilot site. The assessment should collect data

related to site location, access, trade routes, security, governance, estimated number and type of

state actors present, mine title and tenurial arrangements, organization of mining activities

(including active cooperatives, comptoirs, and negociants) and production/pricing data (estimated

production capacity, pre-financing, and pricing).

Ensure that the pilot criteria described above is implemented during the pilot programs.

Submit all deliverables described above in a timely fashion as to the

The implementing partner is responsible for Capacity Development, Due Diligence, Traceability,

and the development of a strategy for the financing and export of artisanal gold as described in

previous sections.

The implementing partner should work with CBRMT staff to ensure that the monitoring and

evaluation plan is implemented. Key indicators should capture information relevant to

environmental impacts such as mercury and cyanide use (in both artisanal and small-scale mining

operations on Concession 40), number and type of cooperative members trained, pricing both at

the mine site and at export and production figures.

Lead Stakeholder Coordination for the pilot project. Stakeholder coordination would require

engagement with a variety of different stakeholders including, but not limited to:

Association des Négociants et des Exploitants d’Or (Association of Gold Traders and Miners

[ANORI]);

Association des sous-traitants miniers (Association of mining subcontractors

[ASTRAMINES]);

CEMAO (Cooperative with the authority over the Senzere and Makala sites on Concession

40);

Association des Orpailleurs pour le Développement, la Reconstruction et la Paix

(Association of Artisanal Gold Miners for Development, Reconstruction and Peace

[AODERPI]);

Association des exploitants miniers artisanaux pour la pacification et la reconstruction de

l’ituri (AOMARPI);

Association de défense des intérêts des négociants et orpailleurs de Mambasa (ADINOM);

Association des Tenanciers des Dragues de la Province Orientale (ATEDRAPO);

SOKIMO;

The Comité de Pilotage d’Orpaillage;

Bunia civil society organizations;

Cadre de Concertation de la Société Civile sur les Ressources Naturelles (CdCRN); and

Haki na Amani.


Capacity Development:

Articulate an approach to all Training and Capacity Building as outlined in Section 3.3.

The partner should work with cooperatives to develop a standard set of forms and templates that

cooperatives can use to collect statistics on such key elements as cooperative members, pit or

tunnel staffing, gross production per pit, and division of that ore among workers, pit boss, and

financial backers, gold yield per bag of ore per miner/pit boss; and disposition of that gold. The

implementing partners (and civil society partners) should train targeted cooperatives on how to

use these forms.

Due Diligence:

The pilot project should work towards building relationships in Orientale with the local

community to promote self-enforcement. It is expected that a pilot project with an office in Bunia

will collaborate with CdCRN and the established Comité de Pilotage d’Orpaillage for due

diligence monitoring.

The implementing partner should explore the prospect of working with SAESSCAM, Division of

Mines, and CEEC as due diligence partners, and should gather input from IOM to develop a plan

to build the capacity of local government stakeholders to conduct due diligence.

Traceability:

The traceability approach for the Orientale Pilot Area will be at the discretion of the

implementing partner, however it must be compatible with OECD Due Diligence, should be cost

effective, and meet the assurance needs of downstream buyers.

Traceability should be funded by the exporter of the gold, or an alternative and sustainable model

must be proposed by the implementing partner.

Traceability goals and requirements needs to be included the broader pilot project communication

plan to project stakeholders.

Export:

Currently no artisanally mined gold from Orientale can be legally certified by the ICGLR because

none of the sites have been validated. Most gold is smuggled to Uganda, and those who do

attempt to follow DRC regulations must transit the gold through the CEEC office in Kinshasa

where the source of the gold is changed to South Kivu. The Governor of Orientale Province has

clearly stated his desire that all artisanal gold from the province be exported directly from the

provincial capital, Kisangani.

The implementing partner can explore opportunities and challenges for the concession holder to

act as the buying agent for either all or a proportion of the ASM site’s production.

The partner can explore the establishment of an export company capable of legal gold exports, or

using established comptoirs.

Pilot project implementer should explore the prospect of working with Emeko, and established

gold buyer with a presence in Orientale.

Finance Needs:

Explore the use of establishing partnership with trading companies to implementing alternative

financing mechanisms through legal channels.


The implementing partner will develop a clear agreement with exporters on buying arrangements

that define the roles of a buying office and/or negociants.

Incentives:

The pilot project should engage with Orientale Government officials to seek reduced tax rates for

the pilot project, and convey the importance of a favorable tax structure to ASM gold success.

Technical interventions may be financed by an LSM partner, SOKIMO, or other supply chain

partners, with feedback, engagement, and input from the cooperatives active in the pilot project.

Potential incentives should be described in the Technical Intervention Report, and could include

any of the technical interventions mentions in Section 3.3 designed to increase the efficiency and

quality, as well as health and safety of ASM activities; the creation of a local development fund

or funding of a specific development project.

3.5 PILOT SCALING-UP PHASE

Pilot projects need to demonstrate that the export of legal, conflict-free ASM gold is possible before a

major effort of scaling-up can occur. Without any proven traceability provider in the DRC for ASM gold,

the infrastructure for traceability and due diligence must be established, and is an important step in the

path toward legal ASM gold form the DRC. Once the proof of concept has been established at Matete and

in Orientale, it is expected that scaling-up can occur with additional time and resources at sites in South

Kivu, Katanga, and Orientale. Scaling-up activities can be sole-sourced to the implementing partner who

has shown the most success under their pilot approach, or could be competitively bid again in a new RFP.

An overview of potential sites where scaling up could occur are described below.

3.5.1 SCALING-UP PILOT SITE OPTION: BANRO CONCESSION –

TWANGIZA/MUKUNGWE

Pilot Model Background: For Banro, the challenges presented by artisanal miners on their concessions

include corporate liability, reputational risk, security, and economics (when artisanal miners exploit

deposits that the company had planned on exploiting itself in due time). However, Banro has concluded it

is better to proactively engage with artisanal mining communities, and can be credited for taking the lead

among LSM actors in stating their commitment to identifying and supporting suitable sites for ASM gold

production on their concession. In addition, they have been working with a local cooperative to build their

capacity to manage and oversee a more formalized ASM gold sector on their concession. The company

awaits clarification from the GDRC, and permission of its board and shareholders to continue on this

course

In 2011, Banro began operations at the Twangiza gold mine, which was the first commercial gold mine

built in the DRC in over 50 years. Twangiza can potentially produce up to 100,000 ounces of gold per

year once fully operational. Prior to opening of Twangiza, Banro repositioned approximately 1,300

artisanal miners from the Twangiza south pit. Banro then engaged in a second round of consultative

discussions with artisanal miners regarding the repositioning of an additional 2,000 recently-arrived

illegal miners from the Twangiza north pit, where mining is planned for the future. Banro seeks to

develop the capacity of artisanal miners to partake in more sustainable small-scale mining at designated

mining sites on the Banro concession. 11

Mukungwe is within Banro’s PE permit 43, which and has not yet begun to exploit the gold in this area.

The mine was validated as ‘Red’ by the multi-stakeholder validation missions because of FDLR and

11 Banro 2014 Corporate Sustainability Report.


FARDC activity. There have been recent cases of family feuding at Mukungwe between the land-title

holders and the groupement chief. In 2014, an Acte d’Engagement was signed by land-title holders,

traditional authorities, and Banro that stated that Mukungwe was part of Banro’s permit, that Banro would

compensate the land-title holders for surface right disruption (disturbance to structures and agriculture

activities), and that Banro would help establish alternative livelihoods for the ASM communities. Banro

has also stated their willingness to consider the establishment of a ZEA on the industrial permit, should

this be legally permitted.12

Rationale for a Pilot Site on Twangiza or Mukungwe:

Working on the Twangiza or Mukungwe could prove the efficacy of a concessionaire supporting

artisanal mining on their concession. If it is necessary to establish a ZEA for legal ASM mining

on these sites, it would further prove the validity of this approach as well.

Banro has indicated an interest in collaborating with CBRMT on a pilot project in Twangiza, and

the site could represent an ideal follow-on to the pilot in Matete after testing the proof of concept

and capturing lessons learned.

OECD is focused on bringing responsible ASM gold to market from the two main mines

identified as ripe for such projects in their baselines, one being Mukungwe.

Some of these positions could overlap with the Matete staff members (if one implementing

partner if chosen), however it would be valuable to compare different traceability and due

diligence approaches if both Matete and a South Kivu pilot sites are selected.

Banro is working with GDRC stakeholders to legally make available alternative gold deposits on

its Twangiza project area for artisanal miners. These designated sites are suitable for small scale

mining and are sufficiently far enough away from Banro’s industrial operations.

Challenges for Pilot Site at Twangiza/Mukungwe:

Owing largely to shareholder concerns and reputational risks Banro is not currently interested in

serving as the buying agent for either all or a proportion of the ASM site’s production. This

position may change over time, particularly if the original pilot at Matete is successful. However,

be subject to change after the pilot has been operational for at least six months and demonstrated

some evidence of success and the ability work collaboratively with the ASM sector.

Additional resources would need to be made available to address the myriad of issues that are

likely to arise from the reposition of miners to a new location, and the widespread expectation

and conflicts that often accompany repositioning.

Conclusion: Should additional resources become available, for example from a partnership between

USAID and Banro,13 a portion of these funds money could be utilized for the expansion of traceability to

Twangiza or Mukungwe. Success at these areas will require significant stakeholder engagement, capacity

building and communication efforts, but are promising pilot locations.

12 Mthembu-Salter, G. OECD Baseline Report on Mukungwe

13 USAID. U.S. Government and Banro Corporation Announce Partnership for Responsible Minerals Trade in the Democratic Republic of the Congo. December 2013. http://www.usaid.gov/news-information/press-releases/dec-17-2013-us-government-and-banro-corporation-partnership-responsible-minerals-trade


3.5.2 SCALING-UP PILOT SITE OPTION: MUSEBE/KATANGA

Pilot Model Background: Musebe, Katanga was the location for the first of five OECD Baseline studies

conducted by Gregory Mthembu-Salter.14 According to the Baseline study, ASM gold mining began at

Musebe in 2013, with gold being the only mineral mined. There are currently approximately 6,000 miners

active at Musebe, and the VIMATED cooperative. The title for the Musebe concession (Concession 4162)

is currently held by Afrimines Resources as a Permis de Recherche. Afrimines is a DRC-based company

established in 2003, with rights to mining rights throughout the DRC. Production volumes at Musebe are

not known as there has been no attempt to track the amount of gold produced.

Rationale for a Pilot Site on Musebe:

There is an organized cooperative in the area (VIMATED). Gold production volume is high enough

to support a large (> 5,000) population of miners.

The VIMATED cooperative, SAESSCAM, and Division des Mines intend to establish a central gold

processing and buying center in Musebe that could help to drive due diligence and traceability in the

area.

There is an absence of non-state armed groups. There is no evidence of forced labor on the site.

Political will to introduce traceability is high in Katanga, including from Governor Moise Katumbi.

There is the proven capacity to use a variety of technical interventions at Musebe. Diesel powered

rock crushers are utilized on site.

Challenges for a Pilot Site on Musebe:

Numerous illegal taxes are levied by state officials in Musebe, and mining officials may resist a

central site for processing and buying gold as it threatens their ability to collect illegal taxes.

Musebe is a challenging site to access (40 km of 120 km trip from Nyunzu must be conducted by

motorbike). There is no mobile phone reception at Musebe. Mudslides and cave-ins are regularly

reported during the rainy season.

There is a lack of knowledge among civil society and government officials in Musebe on OECD Due

Diligence Guidance requirements or purpose.

Title details remain murky at the site, particularly in the light the title for Musebe is only valid until

2015. There has been reported uncertainties about the future of Afrimines involvement at Musebe

post-2015.

Mercury use is reportedly high throughout the area.

FADRC has apparently announced their “ownership” of the pits at Musebe. There have been reports

that FADRC has established a detention center at Musebe.

There is some level of conflict between FADRC and the VIMATED cooperative, including reports

that FADRC has entered VIMATED mines to steal gold.

The political environment in Katanga will make garnering support for pilot activities from the

national government challenging. Governor Katumbi has become a recognized opponent to President

Joseph Kabila in recent months, and was recently removed as regional head of the ruling party.

14 Mthembu-Salter, G. (April 2014) OECD Baseline Study One


Conclusion: Musebe is potentially a viable area for a pilot site, with the right amount of time and

resources dedicated to overcoming the challenges listed above. Most critical would be to ensure that there

are sufficient incentives in place and political support for the introduction of a traceability provider, this is

especially true for government mining officials, negociants and comptoirs who are profit from the status

quo. This pilot would require a full-time project team in order to establish the export of legal ASM gold,

at the same scale and resource level as the original Orientale Pilot Area described above.

3.6 SUMMARY OF PILOT SITE RECOMMENDATIONS FROM CBRMT

CBRMT is committed to supporting pilot approaches that align with and contribute to regular and

transparent information and data sharing. Data will be submitted to national (DRC) and regional

(ICGLR) databases for monitoring and review.

CBRMT recommends launching Pilot Project activity in Maniema and Orientale Provinces. This

would give us the opportunity to work on both a ZEA (Matete) and a concession. Due to the need to

test the efficacy of multiple models, in multiple locations, we strongly believe this is the best

approach. Both of these areas have been chosen because of their likelihood for success.

The precise number of actual mine sites covered by these pilots will be determined by the

implementing partner in coordination with CBRMT, USAID, and the Government of the DRC.

CBRMT strongly recommends having formal written support (such as an MOU) between the

provincial government and the subcontractor before putting any system in place. This should occur in

both Maniema and Orientale.

Likewise, CBRMT strongly recommends having formal agreement between the subcontractor and

buyer/exporter and refiner before putting any system in place. This should occur in both Maniema

and Orientale.

CBRMT will continue to coordinate regularly with BGR and PAC and others to share best practices

and harvest lessons as we collectively scale up legal exports of ASM gold.

The current CBRMT budget will allow Tetra Tech to launch two pilot regions, based on estimates of

staff, interventions and other costs. Providing adequate resources to fund two pilot projects is

preferred to spreading resources thin and launching three project areas at the onset, or only launching

in one pilot area. Scaling-up areas have been identified in South Kivu, Katanga, and Orientale.

CBRMT recommends utilizing multiple partners at each pilot area in order to pair different

traceability and due diligence partners, and to test different models (for example pairing an ITOA

traceability system with an international NGO in one area, and pairing an alternative traceability

system such as GeoTraceability, MineralCare or MetTrak, with a due diligence provider in one area).

CBRMT recommends working with CEEC to test the ITOA model in one pilot area. It should be

noted that CBRMT cannot provide direct funding to CEEC for the ITOA system and should be

expected to sustainably fund their own operations.

CBRMT is cognizant that it is necessary to leave sufficient room to our subcontractors, under the

approval of the GDRC, for unique approaches in the implementation of the pilot models. We believe

that we should not be overly prescriptive in the approach for the pilots in order to leave room for

innovation in the design of pilot approaches from our subcontractors.

CBRMT recommends the use of local monitoring mechanisms to ensure credible, accurate reporting

at pilot mine sites.


To ensure the long term success and scaling of legal artisanal gold sourced from the DRC, CBRMT

strongly supports the establishment of tax incentives and harmonization of tax rates for artisanal gold.

CBRMT recommends working closely with BGR to submit a joint roadmap to the Government of the

DRC that outlines the different models, locations and approaches to be tested.


4.0 ENVIRONMENTAL MITIGATION AND MONITORING

4.1 BACKGROUND

The extraction of mineral resources can have severe environmental repercussions and impacts including

but not limited to deforestation, soil, water and air pollution, soil erosion, loss of biodiversity and long

term damage to critical ecosystem services. Artisanal and small scale mining has a particular set of

challenges given the potential impact on the surrounding environment, the poverty and conditions in

which ASM occurs, and its importance to supporting millions of livelihoods. ASM often provides more

immediate and higher returns for labor investments than agriculture. However, ASM typically occurs in

or near riverbeds and degrades riparian zones, creates erosion, and causes significant silting of water.

Contamination from extractive techniques and dumping of tailings into rivers can also create

environmental and health risks to human and wildlife populations. In the DRC, many artisanal mines are

also located adjacent to or within protected areas (including National Parks), or other critical ecosystems.

Increased deforestation for fuelwood and construction supplies due to human populations moving to ASM

mine sites, site clearing, and miner’s need for water, food and other natural resources have also had

detrimental impacts.. This situation is aggravated by the number of displaced peoples in Eastern Congo as

a result of the many years of conflict. Exploitation of natural resources through illegal mining activities

also stem in part from an increase in international mineral demand that perpetuates degradation and stress

on sensitive DRC environments, and increases conflict and human rights violations in the region.

Gold in particular poses particular environmental impacts and risks when mined using artisanal methods.

The use of mercury and cyanide to extract gold from the ore is a preferred recovery method employed by

artisanal gold miners in the DRC, and globally. The release of vapors and the subsequent contamination

of surrounding watersheds and soils poses serious health hazards for miners and mining communities,

who may be exposed to mercury via the food chain. According to the United Nations Environment

Program (2011), approximately 15 tons of mercury are used annually in the DRC's artisanal gold mining

operations, making it the second largest source of mercury emissions in Africa. At the same time, the

DRC has one of the highest levels of biodiversity in the world, and one of Africa’s largest and growing

artisanal mining workforces.

While there are growing efforts among large and small-scale mining companies to address environmental

and social due diligence, ASM lacks much in the way of guidance in this regard because of the many and

varied definitions of artisanal mining, artisanal mining methods, and associated social and environmental

impacts. These can vary dramatically from country-to-country and from mineral-to-mineral. It is worth

noting that environmental impacts are also compounded during a mining “rush,” which can occur when a

productive new gold site is discovered.

In the DRC, traceability schemes driven by the private sector have endeavored to meet the conflict-free

requirements of US legislation, OECD guidance, and emerging best practice for conflict free minerals

sources. The majority of these systems, however do not include, nor are they required to include, social

and environmental due diligence. According to DRC law the use of mercury and explosives is illegal but


enforcement is negligible, and the degree to which the new ASM mining policy and legislation in the

DRC can address and enforce environmental concerns remains to be seen.

Given the short implementation period, narrow focus and limited resources of this project, CBRMT

cannot directly address the myriad of environmental impacts associated with artisanal gold mining in the

DRC. What the project can and will do, however, is monitor the environmental impacts associated with

establishing CBRMT pilot sites for legal artisanal gold and conduct trainings on the health and safety

implications of using mercury. The project will use this information not only for internal reporting

purposes but to contribute to a growing body of information on mine site performance relative to priority

social and environmental impacts. The collection of baseline data alone regarding mercury use would be

of great value, given the current paucity of information on the issue in the DRC. Understanding the

potential environmental impacts during the design of the pilot projects, and having pragmatic plans in

place before impacts occur is critical. CBRMT will require all implementing partners to comply with

CBRMT’s Environmental Management and Mitigation Plan (EMMP) as part of their proposal; conduct

regular monitoring relative to specific indicators; and submit baseline, mid-term, and final reports of

monitoring and education activities.

4.1.1 MONITORING AND MITIGATION

The goals and processes for environmental mitigation and monitoring were not initially clearly defined by

USAID for this project. CBRMT subsequently drafted and submitted an Environmental Management and

Mitigation Plan (EMMP), which includes definitions that build directly upon USAID’s most up-to-date

guidance on the development and implementation of EMMPs. The EMMP will serve to inform and guide

the monitoring and mitigation of environmental impacts associated with CBRMT gold pilot sites.

Environmental mitigation is defined as “the implementation of measures designed to reduce the

undesirable effects of a proposed action on the environment”. Mitigation is central to the environmental

compliance process, and achieving environmentally sound activity design and implementation. Prevention

of impacts by changes to activity design, site, or technique, is the most reliable approach to mitigation.

Mitigation can reduce impacts in three ways:

1. Prevention and control measures, which fully or partially prevent an impact/reduce a risk by:

a. Changing means or technique;

b. Changing the site; or

c. Specifying operating practices.

2. Compensatory measures which offset adverse impacts in one area by improvements elsewhere; and

3. Remediation measures, which repair or restore the environment after damage is done

Environmental monitoring is a necessary complement to mitigation, and should be a regular part of

CBRMT’s pilot approach to ASM gold. Environmental monitoring is defined as:

The systematic measurement of key environmental indicators over time, within a particular

geographic area; and

The systematic evaluation of the implementation of mitigation measures.

To be effective, mitigation and monitoring must be:

Realistic: mitigation and monitoring must be achievable within time, resources, and capabilities.


Targeted: mitigation measures and indicators must correspond to impacts.

Funded: funding for mitigation and monitoring must be adequate over the life of the activity.

Considered Early: preventive mitigation is usually the cheapest and most effective form of

mitigation, but prevention must be built in at the design stage.

4.2 POTENTIAL ENVIRONMENTAL IMPACTS

CBRMT identified a subset of potential environmental impacts in the EMMP that may arise during the

implementation of the pilot sites. These include:

Mercury and cyanide use, and the subsequent impacts on both ecosystems and human health;

Mine site activities threaten the status and conservation capacity of protected areas;

The structural integrity of ASM gold mining activities—including open pit and tunneling, and

combinations of excavation types on site—that can result in death and injury;

Site abandonment, which can result in permanent damage to biological and ecological functions.

These potential impacts will form the essence of each ASM site’s baseline, monitoring and reporting plan,

and will be included in the baseline and reporting structure of each implementing partner at pilot mine

sites. In order to ensure the efficacy of mitigation efforts to address these impact categories, we will

encourage our implementing partners to undertake the following activities:

Conduct a baseline survey and regular monitoring to determine the availability and use of mercury

and cyanide at or near CBRMT pilot mine sites;

Development/adoption of appropriate training curricula to use with implementing partners (local civil

society and others) to address potential impacts of mercury/cyanide use;

Conduct regular assessments of mine sites to ensure they comply with DRC health and safety

regulations;

Conduct baseline, mid-term and final assessment to assess if and how mine sites are negatively

impacting critical or protected ecosystems;

Training of civil society, government, mining cooperatives, and others in rationale behind these

mitigation and management efforts so that they are held accountable for appropriate mitigation and

management measures;

Inclusion of relevant DRC authorities into ASM monitoring activities;

A referral system by which the CBRMT Project assists site management teams to obtain necessary

and/or additional technical support/intervention from others; and

Maintenance of a strong and transparent monitoring and evaluation system by the CBRMT project for

use by the Government of the DRC and traceability schemes.

In cases where mercury is readily available, and/or already being used by miners near the proposed pilot

site, the intervention of simple technologies in collaboration with technical experts will be strongly

encouraged. Retorts, for example, when properly introduced and used can serve as both as an incentive

for miners to increase the quality of their yields, while reducing their exposure to mercury. Retorts are not

however a silver bullet. Without careful understanding of the costs and benefits from a miner’s

perspective (relative to cost, time, health, education, risk and cultural norms) the introduction of a


technology such as a retort can in fact increase exposure to mercury. For this reason, any intervention

would need to be carefully aligned with expert technical support.

Table 4.1 (next page) provides an overview of the potential impacts, mitigation and monitoring measures

and indicators and the parties responsible for conducting monitoring and mitigation

4.3 REPORTING

CBRMT implementing partners will be responsible for field baseline collection of data from mining sites.

This includes quarterly reporting on EMMP indicators and the CBRMT performance milestone table.

Implementing partners will also be responsible for building-in environmental mitigation measures as part

of their mine-site implementation activities.

CBRMT’s M&E Specialist, Jean Pierre Lueteta, will be responsible for collaborating with subcontractors

to review the design and implementation of baseline forms to gather information against which field

monitoring reports that correspond to the EMMP indicators are reported. He will supervise data

collection, management, analysis and storage relative to the EMMP indicators, and will also be

responsible for the collection of information on these same indicators at quarterly intervals.

Reporting will be collected using paper formats. These will be collected and collated at regular intervals

by the implementing partner with supervision and review by the M&E specialist, or their designees. All

ASM sites receiving CBRMT support will have a baseline, mid-term, and final review of mitigation and

management activities employed by the project. The results of these reports will be included at

appropriate intervals in the project’s quarterly reporting. Data entry from paper to digital formats will be

completed by the project’s subcontractors associated with the scaling-up and piloting of ASM sites. Their

electronic submission to the CBRMT Project will be supported by paper copies. An audit by the project’s

M&E specialist(s) can be conducted at any time to verify that data collection is being supported by proper

field records and that these records support the electronic record


TABLE 4.1: ENVIRONMENTAL MITIGATION AND MONITORING MEASURES15

POTENTIAL MAJOR NEGATIVE ENVIRONMENTAL

IMPACTS

MITIGATION MEASURES MONITORING INDICATOR RESPONSIBLE

Mercury and cyanide use, and the subsequent impacts on both ecosystems and human health

Baseline measurement of availability and use of mercury and cyanide Technical interventions such as retorts, including training Education campaigns about the health hazards

Availability and price of mercury and cyanide at mine sites and nearby towns Qualitative interviews with miners to determine who and how much mercury/cyanide is used, and how frequently. Regular reporting on use and availability of mercury/cyanide including availability, use and impact on women and youth

Implementing Subcontractors Eastern Congo Coordinator CBRMT Monitoring and Evaluation Specialist Technical Experts

Mine site activities threaten the status and conservation capacity of protected areas Direct threats – illegal ASM operations within protected areas Indirect threats – impacts of mine operations in proximity to protected areas threatens integrity of conservation capacity

Withdraw of CBRMT support for ASM activities within designated national parks. Assess the dependency of ASM sites outside PAs on resources found within the Protected Areas (PAs), e.g. bush meat, fuel, building materials, NTFPs. Communication materials and training modules to underscore potential impacts of mining on environmental and human health.

Number of CBRMT sites located within a designated PA Reported use and dependency on PA resources declines or is eliminated Coordinate/leverage international and local civil society actors and DRC Protected Area authorities to track negative impacts on biodiversity related to CBRMT pilot sites and coordinate mitigation measures

Implementing Subcontractors CBRMT Monitoring and Evaluation Specialist DRC Protected Area authorities International and local NGOs focused on environmental protection and biodiversity (e.g., WWF)

Degraded mine sites after abandonment, result in permanent damage to biological and ecological functions

Refilling abandoned mine pits with top soil Replanting abandoned sites with native species to retain soils and boost water retention Re-purposing of pits for livelihoods including vegetable gardens

Number of sites re-filled after abandonment Number of sites replanted with native vegetation Number of sites introducing alternative uses

Implementing Subcontractors CBRMT Monitoring and Evaluation Specialist

Illegal and poorly constructed mining pits, tunnels or galleries that can result in death and injury

Closing of pits that exceed legal depth, or are deemed unsafe due to surrounding environmental hazards such as mudslides. Training to clarify the hazards of deep pits and DRC law

Number of tunnels/pits/galleries that exceed legal depth Number of training sessions convened regarding mine safety

Implementing Subcontractors CBRMT Monitoring and Evaluation Specialist

15 Source: CBRMT Environmental Management and Mitigation Plan


5.0 GENDER

5.1 BACKGROUND

Formalization, regulation, and reform of DRC’s artisanal gold sector cannot be achieved without

consideration of the gender dimensions within the sector, and how access and control over resources are

inequitably distributed between men and women. Targeting women and men in this fashion will improve

understanding of gender roles, barriers to access, and opportunities for empowerment in light of the

desired project results. The different roles of men and women throughout the ASM value chain have been

summarized in the CBRMT Gender Assessment. Implementing partners will draw on the conclusion and

recommendations from this analysis, to develop and implement activities and monitoring mechanisms to

ensure that gender dynamics are monitored and mainstreamed throughout all CBRMT gold pilot sites.

Mining-related activities in the DRC, and in sub-Saharan Africa more broadly, are typically controlled by

men, yet it is estimated that women and youth constitute up to 50 percent of the current ASM labor sector.

Although everyone in the ASM sector faces challenges, the security, health, and social risks posed to

women and girls are particularly acute. Men typically do the digging in mines, engage in negotiating and

trading and serve as pit bosses or other oversight positions. Women however also manually remove soil

and other materials from mine pits, crush rocks, wash and sort minerals, transport ore, and conduct

mineral processing (in the case of gold this often involves the use of mercury to separate the gold from

the ore). Outside the mines, they provide a wide range of services from selling equipment and food to

laundering clothes.

There are examples of women serving as negotiators, mine managers, or traders. In the artisanal gold

sector, there are examples of women traders who are more trusted and successful than their male

counterparts. While some women have managed to gain respect and recognition for these roles, most

women in the ASM sector are given lower status tasks that are physically difficult, but pay much less than

their male counterparts. In situations where they either are victims of sexual exploitation or work in the

sex industry, women are often socially ostracized, making it untenable to return to their homes and

rendering them more vulnerable to exploitation by male miners. Children are similarly underpaid for their

work and are of a lower social standing than adult miners. Some boys have sought to gain social status as

a miner by the material goods they can acquire with money earned working in mines. Importantly, most

miners are migrants to the mining site, and do not have the social systems and networks to rely on in

difficult financial times.

At the governmental level, meetings and trainings in the ASM sector are overwhelmingly male.

Cooperative members and leaders are also primarily male. This is in part explained by their

disproportionate representation in the sector, but moreover it is a function of the perception of women’s

legitimacy to be working in the mines. In contrast, some women may shy away from meetings as they

fear backlash if they speak out about the issues they face at the mines. Boys and girls are also likely to be

hidden by the adults at the mine sites for fear of consequences of violation of labor laws. Women are also

less likely to accept or seek out services than men due to the fears of exploitation or retribution. Services

may also be based on assumptions viewing women as victims forced into mining or exploitative sexual

behavior rather than as agents capable of earning a living from mining.

The use of mercury in recovering artisanal gold can disproportionally impact women and children, who

are often exposed to the dangerous neurotoxin. Mercury is particularly harmful to pregnant woman and

young children; repeated and long term exposure can lead to mental retardation, deafness and blindness.

Furthermore mercury does not degrade and the related impacts of mercury entering watersheds and other


water sources disproportionally impact women and girls who are the primary collectors, transporters and

users of water, and suffer the reproductive impacts of consuming fish and other aquatic species in which

the mercury has bio accumulated.

Children working at artisanal gold mining sites is another issue that CBRMT will need to monitor closely.

While Congolese law sets the minimum age of employment at 15 years of age, the reality is that in the

absence of any official, government-issued identity documents, it is difficult to determine the age of

miners at times, and CBRMT will have to rely on the community to verify age. In some instances, boys

and girls accompany their mothers to mine sites and may be encouraged to assist in cleaning, sifting, or—

in the case of girls—assisting with cooking or commerce. In other cases, without their parents’

knowledge, boys have sought work in the mining site in order to attain money or the associated

status/recognition. Boys may be asked to enter tunnels and galleries that cannot be reached by adult

males, for example. Boys also engage in digging, sifting washing and panning as well as selling food.

Girls often engage in petty commerce and may in some cases engage in hauling tailings, washing or

sifting. Some girls also are forced into prostitution at mine sites by their parents and find themselves with

few alternatives due to the stigma attached to the industry.

5.2 ACTIONS

In order to achieve CBRMT’s goal of scaling up conflict-free artisanal gold supply chains, the project will

address barriers and opportunities to women’s and men’s participation in a responsible minerals trade.

CBRMT aims to ensure women have the opportunity, if they wish, to benefit and participate equally in

artisanal gold mining as well as in CBRMT interventions, including trainings, communication campaigns

and formalization activities related to the establishment up of gold pilots We will encourage our

implementing partners to make specific efforts at the start of the pilot to meet with women miners,

washers, transporters, traders, and business operators to understand their roles in the ASM sector and how

CBRMT activities can be developed to be more gender responsive.

Our activities will address barriers to participation and strategies for including women and youth

throughout the minerals value chain. Our approach will draw on best practices identified by the World

Bank, the International Council on Mining and Metals (ICCM) and others to understand and ensure men

and women have equitable opportunities for participation in all levels of the ASM value chain.


TABLE 5.1: KEY CONSIDERATION AND RECOMMENDATIONS TO ADDRESS GENDER DYNAMICS AT CBRMT PILOT SITES16

Domain Key Considerations Recommendations

Access

Women have unequal access to capital. This restriction to access can be a barrier and a vulnerability.

Ensure existing and alternate gold traceability and due diligence schemes which support women’s access.

Knowledge, Beliefs & Perceptions

Women continue to be kept out of mine sites based on cultural beliefs, perceived legal rules and for their own security, rather than considering the broader socio-economic needs, circumstances, and roles that women play in the ASM gold sector.

Integrate lessons learned from partners involved in supporting women’s roles in mining.

Target women for training so that an increased number can serve as official auditors or mine site inspectors.

Practices & Participation

Traceability, due diligence, and certification systems are often implemented and monitored by external (state and non-state) actors that are typically male-dominated. This factor could risk excluding or minimizing the voices and concerns of women and youth.

Youth in particular are more vulnerable to exposure to harmful practices (e.g., early pregnancy, prostitution, and exposure to mercury). They often represent a hugely disenfranchised part of the ASM universe and are most susceptible to provocation with political and armed conflict resulting.

While women are often restricted to lower paid work in mining sites, there are examples of women serving as negotiators, mine managers, and traders.

Include potential impacts on women and youth of scaling up.

In conducting due diligence at mines, include criteria regarding access to mines for women and women’s roles in decision-making.

Be sure women have the opportunity to benefit from and participate in CBRMT interventions—including trainings, communication campaigns, and formalization activities.

Conduct regular monitoring of mercury use to determine if and how women and youth are being impacted.

Ensure that activities address barriers to participation and strategies for including women and youth throughout the minerals value chain.

Connect women serving in substantial/leadership roles with other women in ASM, possibly through RENAFEM.

Time & Space

Including women and boys and girls in project activities may be challenging. Children may be hidden in order to appear that a mine is in compliance.

ASM is viewed as a critical livelihood strategy and may be used to help pay for school fees, for example.

Identify a partner to complement its efforts and to bring child labor expertise to the project (e.g. the Women and Child Services in Kisangani)

Monitor the social and economic effects gold pilot projects on men, women, boys, girls, and families.

Legal Rights & Status

In order for a mine to be meet responsible minerals standards, the mine needs to be in compliance with human rights laws, including child labor and sexual exploitation—both issues in many mine sites.

Promote increased awareness and understanding among women about their legal rights, and recourses when their rights are violated.

16 Based on the CBRMT Gender Assessment


APPENDIX A: PROPOSED IMPLEMENTATION SCHEDULE


Deliverables Months Responsible Party Pre-Implementation Pilot Implementation Period

Current CBRMT Contract Period CBRMT Extension Needed

M 15 A 15 M 15 J 15 J 15 A 15 S 15 O 15 N 15 D 15 J 16 F 16 M 16 A 16 M 16 J 16

Scaling Up-Plan and Pilot Site Preparation

Submit Draft Scaling-Up Plan CBRMT

Scaling-Up Report Comments provided by USAID

USAID

Final Scaling-Up Report Submitted CBRMT

Submit CBRMT/BGR Collaborative Pilot Approach to GDRC

USAID and PROMINES

Letter of Support from Orientale Government Officials

CBRMT

Obtain Banro Technical Intervention Commitment for Matete

CBRMT

Final Scaling-Up Plan approved by USAID

USAID

Release RFPs for Pilot Project Subcontracts

CBRMT

Proposal Development by Potential Subcontractors

SUB

Review Proposals and Select Subcontractors

CBRMT

Pilot Model One – Maniema

Banro and IOM Feedback to Implementation Plan

BANRO/ IOM

Work with IOM to ensure support for pilot sites including validation missions

CBRMT/ IOM

Gathering of baseline production, social and environmental data

SUB

Matete Pilot Kick-Off Meeting SUB

Staff and Resource Report SUB

Conduct review of Banro technical assistance provided to the cooperative

SUB

Identify alternate and sustainable sources of funding and investment

SUB

Develop plan for local oversight committees (comites de suivi)

SUB

Baseline Assessment Report SUB

Training and Capacity Building Plan SUB

Communication and Stakeholder Coordination Plan

SUB

Traceability and Due Diligence Plan SUB





Technical Intervention Report SUB

Environmental Baseline Report SUB

Deploy Training Modules

Downstream Acceptance Report SUB

Comites de Suivi Launch SUB

Cooperative Business Plan SUB

Ongoing Implementation of Traceability, Due Diligence, Communication, and Incentive Plans

SUB

Initiate conflict-free exports of gold with national, regional (ICGLR) and OECD guidance

SUB

Third party audit once operational Independent auditor and

SUB

Pilot Model Two – Orientale

Identify downstream buyer and sign MOU that specifies production amounts and delivery of goods

SUB

Establish MOU from GDRC Officials for Pilot Site Support

SUB

Identify Secure Trade Routes SUB

Baseline Capacity Assessment of Local Cooperatives and Pilot Stakeholders

SUB

Establish MOU with Concession Holder SUB USAID CBRMT

Develop plan for local oversight committees (comites de suivi)

SUB

Baseline Assessment Report SUB

Training and Capacity Building Plan SUB

Communication and Stakeholder Coordination Plan

SUB

Technical Intervention Report SUB

Environmental Baseline Report SUB

Downstream Acceptance Report SUB

Deploy Training Modules SUB

Comites de Suivi Launch SUB

Cooperative Business Plan SUB





Ongoing Implementation of Traceability, Due Diligence, Communication, and Incentive Plans

SUB

Initiate conflict-free exports of gold with national, regional (ICGLR) and OECD guidance

SUB

Third party audit once operational Independent auditor and

SUB


APPENDIX B: ASM GOLD WORKSHOP

On February 18 and 19, 2015, CBRMT, in collaboration with the MoM and Bundesanstalt fur

Geowissenschaften und Rohstoffe ([BGR] Federal Institute for Geosciences and Natural Resources),

convened a two-day workshop in Kinshasa, DRC with approximately 90 stakeholders (see Appendix B)

from the ASM Gold sector in attendance. Representatives from large scale mining, senior GDRC

officials, technical experts, comptoirs, donors, and traceability providers were gathered to discuss the

barriers and opportunities for responsibly sourced artisanal gold from the DRC. The workshop was

facilitated by Paul Mabolia Yenga, the Program Coordinator of World Bank’s Growth with Governance

in the Mining Sector Program (PROMINES), and advisor to the Minister of Mines. Following this, on

February 20, CBRMT convened a smaller working group comprised of civil society, traceability

providers, the private sector and potential implementing partners to explicitly focus on CBRMT’s pilot

model approach, principals, and design. The following section details and captures objectives and

discussion from both the workshop and the working group.

WORKSHOP OBJECTIVES

KEY OBJECTIVES FOR CBRMT AND BGR WORKSHOP FEBRUARY 18 AND 19

Advance Roadmap for ASM Gold: The workshop was an opportunity to convey that donors and

implementing partners (including BGR, USAID, Department for International Development [DFID],

German International Cooperation [GIZ], and PROMINES) are working together, in collaboration

with the GDRC, to develop a roadmap for the formalization and legalization of the sector. The

workshop represented the first time that such a varied and senior group of stakeholders were able to

sit together to collaboratively plan the development of artisanal gold efforts, in order to maximize and

synergize donor efforts.

Highlight Major Impediments to Sector Growth: A key CBRMT goal was to convey the

conviction that DRC artisanal gold is an industry with the potential to be an engine for development.

While the opinion that ASM Gold is an industry, rather than a nuisance, is growing in acceptance, it is

still far from guaranteed that a formalized sector will be established. The workshop was designed to

highlight the impediments for industry success that must be tackled for sustained growth. The

artisanal industry requires an encouraging policy framework, including security of mining tenure and

reasonable levels of taxation in order to prosper. It was also made clear that DRC officials must

implement a transparent process for creating new ZEAs, and must develop a formal process for LSM

concession holders to allow ASM operations on their concessions.

Obtain Input and Buy-in for Pilot Projects: Another objective of the workshop was to obtain

critical buy-in and input from stakeholders on CBRMT and BGR activities. The workshop had active

participation from GDRC, civil society, and implementing partners, and was an important first step in

making sure that stakeholders, particularly GDRC and MoM officials and technical staff, felt that

they had an understanding of the pilot projects, and that their input was included in the design of the

pilot projects.


Information Sharing: The workshop was an opportunity for stakeholders to digest and discuss the

latest research and experiences in advancing the ASM Gold sector in the DRC. Our belief was that all

of the decision makers in the room should be working from the same baseline of information. The

agenda included a participatory review of existing gold pilot traceability initiatives, and a report out

on recent studies conducted by international consultants on responsible artisanal gold sourcing in the

DRC. The agenda led to collaborative discussions on the appropriateness of different approaches on

artisanal gold sourcing and to overcoming barriers for industry development.

WORKSHOP DISCUSSION AND OUTCOMES

KEY DISCUSSION POINTS AND OUTCOMES FROM CBRMT AND BGR WORKSHOP

FEBRUARY 18 AND 19

Government Support to Pilot Programs: The Ministry of Mines stated their openness to

developing a plan of action for ASM gold sourcing that builds on the expertise of all organizations in

the room in a synergistic manner. The MoM encouraged BGR, USAID, and the donor community to

work together to establish a responsible trade in artisanal gold, rather than to launch a disjointed

effort. The importance of political will as a necessary facilitating condition to make meaningful

change was restated throughout the conference by numerous participants.

Title and Tenure: There was agreement on the need to increase, and the commitment to advance, the

number of validated sites and ZEAs. The GDRC stated that they are working to develop and establish

legality for artisanal mining sites. Discussion points related to advancing tenure security and the

formalization of ASM mining zones included:

A Zone d’Exploitation Artisanale (ZEA) must be requested by a provincial governor, declared by

the national Minister of Mines, and can be dissolved with 60 days’ notice at the sole discretion of

the minister.

It was stated that there have been challenges to arrive at a protocole agreement with title holders,

but that this is progressing, and work is being done to develop the contractual arrangement

between LSM and ASM in a protocole. It was stated that a protocole d’accord has been

successfully implemented in the past, including by Société Aurifère du Kivu et du Maniema,

SARL (SAKIMA). This is till gray and legal under the Mining Code.

Two barriers were raised in regards to title holders and ASM miners: 1) Title holders are often

absent and difficult to track down, and 2) There is a certainty from many stakeholders that ASM

miners will move outside of ZEAs to more resource rich areas nearby.

Regional Certification: The workshop highlighted the urgent need to review (and perhaps change)

the mechanism for regional certification in order to urgently respond to the situation on the ground.

There was a call from some of the participants to suspend the ICGLR RCM Certification requirement

until there is more gold that that can claim these certifications, since smuggling has increased with the

introduction of the ICGLR requirement instead of the certificate of origin. The suggested approach

was to reintroduce the certificate of origin certification for a period of time, which had been

abandoned previously, for the exports of gold, while still introducing the RCM Certification wherever

possible. This led to debate about the rationale of the ICGLR certification, the roles that it already

plays, whether this would lead to a regressive behavior from stakeholders, and whether a return to the

certificate of origin was worthwhile. It was raised that the ICGLR certificate was introduced to fight

against armed conflict, and if removed could create more confusion and harm. It was also noted that

Rwanda uses both the certificate of origin and the ICGLR Certification.


Conflict Free Areas: The focus of conversation on ASM gold is often centered on conflict areas in

the Eastern Congo, but the reality is that the entire country is covered by Dodd-Frank, and this

includes areas that are non-conflict areas like, among others, the provinces of Bas-Congo or Bandudu.

These areas should be looked at for pilot programs and as focal points for the scaling-up of

traceability systems. Traceability needs to expand to these non-conflict areas as well to prove the

efficacy of the systems, and to source legal ASM gold from these areas. The perception outside of the

DRC is that all of DRC is a conflict area, so these areas are being unfairly castigated, and this needs

to be corrected as quickly as possible. In fact, it may be easier to implement certification in these

areas, so for purpose of pilot coverage, it could be more helpful to include these.

Donor Collaboration: The workshop highlighted that there is a growing amount of collaboration

occurring between USAID, IOM, PROMINES, BGR, GIZ and DFID. Each party focusing on a

different area critical to the growth of the ASM Gold trade.

IOM: Supporting validation missions; capacity development for co-operatives, and in the

construction of points of sales and trading centers. They will also be taking ownership over

MONUSCOs responsibility related to mine site security.

GIZ: Supporting the ICGLR in a regional 3-year 3mEuros project, with 80 percent of funding

used to strengthen the capacity of the ICGLR.

BGR: Working to expand the CTC Mine Site Certification system for 3Ts and Gold.

USAID: Supporting systems for the responsible sourcing of 3Ts and artisanal gold, and

strengthening the capacity of the ICGLR with the CBRMT program.

DFID: Advancing a public-private sector alliance for mining as a source of development in

Katanga, which will extend to all extractive industries, and beyond gold.

PROMINES: Multifaceted program funded by the World Bank (and formerly DFID) to support

mining governance, improve the conditions for increased investments in and revenues from

mining, and help increase the socio-economic benefits from artisanal and industrial mining.

Traceability: Presentations by several traceability solution providers highlighted the different

approaches available as well as differing perspectives and expectations regarding the need for

traceability in the ASM gold sector. Many stakeholders, particularly those from the GDRC, believe

that it is preferable to develop a Congolese-managed traceability system. It was agreed that each

traceability system discussed during the workshop had both positives and negatives, and that

synergies could exist between the different systems. Other participants clarified that traceability is

only one aspect of a much larger system of supply chain assurance, and does not equate to due

diligence. There was agreement among stakeholders that CBRMT pilot projects can and should be

used to test different approaches to traceability. Traceability systems should be implemented with the

consultation of all stakeholders in order to develop a sustainable solution. It was agreed that any

traceability systems implemented must be compatible with GDRC/CEEC requirements (transparency

and management) and be cost effective, as they should ultimately fall under their responsibility of the

GDRC once external assistance is no longer available. Traceability providers who spoke at the

workshop included ITOA, GeoTraceability, and MineralCare. The functionality of each of these

traceability solutions has been detailed in this report in Section 2.2.

Capacity Gaps: It was reiterated by many participants that the capacity challenges are much more

complex than traceability. There is a need for political will at national, provincial and regional levels,

and a need to develop the capacity for DRC Officials in order for legal traceable ASM gold systems

to propagate. Capacity gaps exist across all GDRC bodies, including SAESSCAM, CEEC, Division

of Mines, and CAMI. SAESSCAM is not yet sufficiently deployed at all mines and must build


capacity to meet their mandate, but there is a lack of funding to do this. Validation teams also need

better coordination and better resources.

Taxes: The workshop had a considerable amount of debate surrounding legal and illegal taxation of

artisanal gold. It was regularly stated by the international workshop experts that they believed that a

major driver pushing DRC artisanal gold into illegal channels are the plethora of (illegal) provincial

taxes, in addition to legal tax rates that are much higher than neighboring countries. It was stated that

it is not the jurisdiction of the MoM to control provincial taxes, but there have been some discussions

with provincial governors who may be willing to reduce provincial taxes. This does not however

address the illegal taxes charged by authorities. It was highlighted that perhaps tax collection should

occur in a single spot to attempt to stop smuggling and illegal taxation by authorities.

Constraints with Cooperatives- Co-operatives operating in the DRC are often not registered or

suffer from capture by elites or other powerful interest groups and do not function transparently or in

the interest of their members. It was agreed that cooperatives need to be prioritized as key partners in

the formalization of the ASM sector. Cooperatives should serve not only as actors within the supply

chain, but also within local societies and communities, as protectors and representatives of their

members.

Group Design Session Participants broke into two groups, one focused on designing a pilot model with

gold mined on a ZEA, and one pilot model with gold mined on an LSM concession. The groups were

asked to brainstorm and collaboratively design elements of a novel pilot model, paying particular

attention to the following issues: Incentives for Participation, Chain of Custody or Traceability,

Certification Standards, Due Diligence Mechanisms, the Role of Negociants, Environmental Impact

Reduction, CEEC’s Role, SEAESSCAM’s Role, the Provincial Division of Mines Role, Downstream

Engagement (Comptoirs, Refiners, and End Users) and Local Governance Structure (Cooperatives and

other authorities). It is interesting to note that both groups came up with a similar concept to improve the

efficiency of the system, by redefining the role of negociants and creating more direct connections

between cooperatives and comptoirs (see image below).

The ZEA Design group started by looking at the current supply chain for ASM Gold and redesigning

towards a more efficient and governable state. The group came to the consensus that there should be an

opportunity for direct contract between comptoirs and cooperatives. At the same time, this model also

allows for a traditional supply chain system, including the role of negociants to act as middle men

between the diggers and comptoir. In this model however, negociants are re-defined in their role, and are

re-tasked to act as “comptoirs’ agents”. It was hypothesized that the direct contract between the comptoir

and the cooperative should develop more clarity in the supply chain. The contract should detail the

minimum amount of gold to be provided, and the pricing details. It was also discussed that there should

be an electronic balance for the diggers kept at the cooperative. The idea of cooperatives as federations of

smaller cooperatives was also brought forward.

The group stated that the location of the pilot model needed to be in place where there is strong political

will and sufficient gold production. The group believed that national and provincial government with

support from IOM and BGR should prioritize the identification and validation of gold sites. USAID

would also be needed in order to help leverage GDRC support at national and provincial levels for an

agreement between the cooperative and the title holder. The Provincial Governor must request a ZEA to a

registered cooperative, which would then need to be confirmed by the National Minister. In order to

clarify roles and responsibilities, the design team also suggested the signing of an MOU between the

implementing partner and the Mining Minister to clarify the role of SAESSCAM and CEEC at the site.

The group’s discussion on environmental impact reduction was focused on ways to monitor and reduce

the use of mercury and cyanide during mining. There was agreement on using the incentive of technical

equipment that could reduce mercury use while increasing the quantity and quality of artisanal gold


produced, as well as offer trainings on mercury reduction. Opportunities for financing for mercury

free/reduced equipment could be originally financed through donors, but eventually sustained through

loaner programs managed by the cooperative as well as increased quality and quantity of gold production.

At a minimum, it was suggested that the model should include a baseline to see how much mercury and

cyanide is in use. Environmental remediation of damaged sites was also discussed, with opportunities for

reprocessing tailings during remediation. Traceability discussions in this group highlighted the need for a

cost effective and practicable traceability system that is adapted to the local context. The system should

help the miners better understand their true production level. There were disagreements in the group about

the use of logbooks versus electronic databases.

Risks highlighted during this group conversation included:

Inability to secure an agreement between a suitable cooperative and government authorities.

ZEA rights being rescinded during the pilot program.

A change in the supply chain upsetting existing power dynamics.

The ability of negociants to continue trading inside and outside the system, and thus possibly

threatening the chain of custody.

Cooperatives not sufficiently representing the miners interests, as they develop business relationships

directly with comptoirs.

Data privacy and security concerns regarding commercial confidentiality.

FIGURE B.1: ZEA CONCEPTUAL MODEL

The Concession Design Group used the session as a group brainstorm to discuss the viability of

different components of a model operating on an LSM concession. Incentives discussed included

technical interventions for miners that increase production and transparency, such as portable gold

weighing scales and retorts, the opportunity to develop better community relations between ASM/LSM,

and the opportunity and challenges for a concession holder to act as the comptoir if traceability and due


diligence were advanced. For a pilot model on a concession of a large-scale mining company, it was

agreed that there needs to be watertight traceability in order to manage the reputational risks of working

on a company’s concession. Technology transfer was highlighted as having high potential on a

concession model, where production could increase, and ultimately provide benefits for all members of

the supply chain. There was consensus that the cooperative needs to be independent, from a management

perspective, from other members of the supply chain, including the concession holder, and not directly

report to any other stakeholder.

The group determined that local oversight committees “comites local de suivi” can play a huge role in

monitoring and due diligence. As with the other group, the discussion of changing the negociants role in

the system was highlighted as potentially viable. CEEC and SAESSCAM roles on the site were discussed,

as well as the need to design a system that does not perpetuate smuggling. It was discussed that

SAESSCAM can be a channel for training, due diligence, and the chain of custody support, but that their

capacity needs to be developed. It was discussed that there is a need to reduce the number of rent seeking

parties in the system in order to find success. The role of the “Division des Mines” need to be clear and

defined in the system to avoid overlap of services. It was discussed that in order to gather production

there needs to be a central hub point that has a buying office and crushing in the same location.

The group suggested that ITOA would need to be reduced to “ITOA Light” in order to reduce the costs,

should they not be covered by the exporter and passed down throughout the supply chain, or else gold

will still be smuggled, due to the perceived high costs of managing and operating the system. It was

discussed that the cost of the traceability solution need to be low (around 1 percent) for the system to be

viable. There could be an opportunity for alternative traceability services to work only on the downstream

end of the supply chain, in order to provide those services that ITOA might not be able to do, while still

building the capacity of the CEEC initiative.

Risks highlighted during this group conversation included:

SAESSCAM could tax equipment, such as detectors and other machines meant to improve

production, given to miners under a technology transfer model in a manner that discourages the

cooperative, and leads them to sell the equipment.

The lack of a legal mechanism for ASM on LSM concession at this point in time is an obvious

barrier.

The number of government officials currently acting as rent seekers will be difficult to reduce.

By improving activities and increasing production, there could be an increase of illegal taxations.

The expense of traceability solutions.

The “negociant” acting as a barrier if smuggling occurs within their pre-established networks.

The involvement of FARDC can be a risk in the implementation of the system.


APPENDIX C: PARTICIPANTS ATTENDING L’ATELIER RELATIF A L’EXPLOITATION ARTISANALE DE L’OR (FEBRUARY 18–19, 2015)

# Name Organization

1 Jerry Kalume AESSCAM/P.Or

2 Thallo Shavatu AHPE

3 Laura Barreto ARM Fairmined

4 Crispin Mutuedu Banro

5 Thierry Ntumba Banro

6 Anne Marie IGIKWIYE BGR

7 Uwe Naeher BGR

8 Yasmine NZUMA BGR

9 Nicholas Garrett BSP

10 Joseph Ikoli Yombo Cabinet Adjoint

11 Armel Nganzi CBRMT

12 Cathérine Picard CBRMT

13 Denis Roumestan CBRMT

14 Jaebez Poudigou CBRMT

15 Jean Pierre Lueteta CBRMT

16 Jonathan Ellermann CBRMT

17 Nganzi Armel CBRMT

18 Polycarpe Kumasamba CBRMT

19 Freddy Mwamba CEEC

20 Baudouin Hamuli CIRGL

21 Simon Nbizi CIRGL

22 Genevieve Kizekele COCERTI GT

23 Gregory Mthembu-Salter Consultant Indépendant

24 Shawn Blore Consultant Indépendant

25 N/A DFID

26 N/A DFID

27 Emmanuel Ndimubanzi Division des Mines Nord Kivu

28 Michel Liete Division des Mines Sud Kivu

29 Laurent Duplat EMEKO


# Name Organization

30 Me Belade Douce EMEKO

31 Fidel Bafilemba ENOUGH

32 Sasha Lezhnev ENOUGH

33 Rupert Cook Estelle Levin

34 Gerard Beaulieu Géotraçabilité

35 Magali Mander GM

36 N/A GIZ

37 Martin Balegamire GTC

38 Michel Ndete GTC

39 Oscar Mukenge GTC

40 Patrick Iheta Musombo GTC

41 Diane bwebwe IOM

42 Maxie Muwonge IOM

43 Paul Motmans MineralCare

44 Banuusomeye J. MoM

45 Bellarmin Mwadiza MoM

46 Eve Ikoli MoM

47 Ibongo Awa MoM

48 Jean Paul Olua MoM

49 Jhon Tshonga MoM

50 Luc Pongo MoM

51 Martin Kabwelulu MoM

52 Matwika Mapass MoM

53 Mbuyu Wilfred MoM

54 Minzie Patricia MoM

55 Monga Kasonde MoM

56 Mungeya Nene MoM

57 Musiripu Arsene MoM

58 Ndimubanzi Emma MoM

59 Ngalamulume MoM

60 Patrick Kitembo MoM

61 Paulin Besa MoM

62 Prince Kashongwe MoM

63 Roger Kiena MoM

64 Roger Kienansatu MoM

65 Trudon Banza MoM

66 Vangu Musunda MoM

67 Eric Mukandila MONUSCO

68 Laure Gnassou MONUSCO

69 Drothée Bintu NA

70 Lagrange M-A OSESG

71 Joanne Lebert PAC

72 Victor Kangela PAC

73 Yves Bawa PACT

74 Mabolia Yenga PROMINES

75 Philippe UNGI PROMINES

76 Daly Ndala RDC/GTC

77 Fidele Kambembo RDC/GTC

78 Jean Ntoto RDC/GTC

79 Raymond Mananga RDC/GTC

80 Benjamin Yambawoto SAESSCAM Maniema

81 Julia Sofi SOKIMO

82 Mutombo Kalubi SOKIMO

83 Dix Noirand SRN Consultant

84 Delphin Tshinua UE

85 Aubert Mwilambwe USAID

86 Kim Thompson USAID

87 Richard Robinson USAID


# Name Organization

88 Golan Rami

89 Laure Grabou

90 Marcel Mubanga


BIBLIOGRAPHY

Alliance for Responsible Mining (September 2014). Conflict Minerals Assessment in the DRC. Prepared

for USAID/IOM Regional Office in the DRC.

Banro. 2014 Corporate Sustainability Report: A 360˚ Approach to Sustainability.

www.banro.com/i/pdf/Banro-9634-CSR-EN.pdf

Blore, S. (2012). The MetTrak System at Rutongo. A Preliminary Assessment. Prepared for Partnership

Africa Canada.

Blore, S. (2014). The 97% Solution. Working with Producers to Responsibly Source Artisanal Gold from

the Democratic Republic of the Congo. Prepared by Tetra Tech under USAID Contract No. AID-

OAA-I-12-00032/AID-660-TO-14-00002, under the STARR Indefinite Quantity Contract

CBRMT Environmental Management and Monitoring Plan (December 2014). Prepared by Tetra Tech for

the United States Agency for International Development, USAID Contract No. AID-OAA-I-12-

00032/AID-660-TO-14-00002, under the STARR Indefinite Quantity Contract).

CBRMT Gender Analysis (October 2014). Prepared by Tetra Tech for the United States Agency for

International Development, USAID Contract No. AID-OAA-I-12-00032/AID-660-TO-14-00002,

under the STARR Indefinite Quantity Contract.

Cuvulier, J. (2011). Men, mines and masculinities: The lives and practices of artisanal miners in Lwambo,

Katanga Province, DR Congo.

Fahey, Dan (2008). "LE FLEUVE D’OR: THE PRODUCTION AND TRADE OF GOLD FROM

MONGBWALU, DRC". L’AFRIQUE DES GRANDS LACS. ANNUAIRE 2007-2008.

Hayes, K., & R. Perks. (2012). Women in the artisanal and small-scale mining sector of the Democratic

Republic of the Congo in P. Lujala and S. A. Rustad. (eds.) In High-Value Natural Resources and

Peacebuilding. London: Earthscan.

Levin, E. and Cook, R. (2014). PROMINES. Etude comparative des systèmes de Certification et de

Traçabilité en cours en République Démocratique du Congo (RDC).

Mthembu-Salter, G. (2015) Baseline Study Two: An overview of provincial gold production, trade and

export, and a case study of the Mukungwe artisanal gold mine, in South Kivu, Democratic

Republic of Congo

Mthembu-Salter, G. (April 2014) Baseline Study One: An overview of provincial gold production, trade

and export, and a case study of the Musebe artisanal gold mine, in Orientale, Democratic

Republic of Congo.

Partnership Africa Canada (April 2014) Tracking, Certifying, and Exporting Artisanal Gold from Eastern

DRC. Summary Evaluation of the Pilot Project at Mangi.

Partnership Africa Canada (October 2014) Creation of legal sales chains for tracked & conflict-free ASM

gold in Orientale Province: Final Report.

Partnership Africa Canada (September 2014) Strategies and Possibilities for Intervention in Gold

Producing Co-operatives in the Democratic Republic of Congo.

http://www.banro.com/i/pdf/Banro-9634-CSR-EN.pdf




Randgold Resources: Kibali Gold Mine. http://www.randgoldresources.com/kibali-gold-mine

South African Resource Watch. (2011). From Conflict Gold to Criminal Gold.

The Role of the Exploitation of Natural Resources in Fuelling and Prolonging Crises in the Eastern DRC,

January 2010, International Alert.

UN Group of Experts Report. (2014a). Final report of the Group of Experts submitted in accordance with

paragraph 5 of Security Council resolution 2078 (2012). 23 January 2014.

http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-


Un Group of Expert Report. (2014b). Final report of the Group of Experts on the Democratic Republic of

Congo. http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-


United Nations Environment Program. (August 2011). Évaluation Environnementale Post-Conflit de la

République Démocratique du Congo.

USAID. U.S. Government and Banro Corporation Announce Partnership for Responsible Minerals Trade

in the Democratic Republic of the Congo. December 2013. http://www.usaid.gov/news-

information/press-releases/dec-17-2013-us-government-and-banro-corporation-partnership-

responsible-minerals-trade

http://www.randgoldresources.com/kibali-gold-mine





DEMOCRACY, HUMAN RIGHTS, AND GOVERNANCE ASSESSMENT OF NEPAL 57

Van Puijenbroek, J.; Mongo Malolo, E., and Bakker, J. 2012. A Golden Future in Ituti? Which

Perspective for Gold Exploitation in Ituri, DR Congo? IKV Pax Christi and Reseau HAKI NA

AMANI (RHA).

U.S. Agency for International Development 1300 Pennsylvania Avenue, NW

Washington, DC 20523 Tel: (202) 712-0000 Fax: (202) 216-3524

www.usaid.gov

Documents

CAPACITY BUILDING FOR A RESPONSIBLE MINERALS TRADE …