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ICGLR Regional Certification Mechanism

Third-Party Audit Report EXECUTIVE SUMMARY

Raw Minerals Resources

(RMR)

Republic of Burundi

Publication date: 1st October 2019

Validity: 3 years

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1. Introduction

a. Audit objective (reference to Regional Initiative, RCM)

As part of the Regional Initiative Against the Illegal Exploitation of Natural Resources (RINR) the

International Conference on the Great Lakes Region (ICGLR) is in the process of implementing the

Regional Certification Mechanism (RCM).

The RCM aims at providing assurance to buyers of tin, tantalum, tungsten and gold extracted in ICGLR

Member States (MS) that minerals were produced, transported and exported legally and in accordance with

minimum standards related to conflict free sourcing, social and environmental practices. In order to provide

credible assurance, the RCM requires an independent third-party audit of the mineral exporter to verify

compliance with applicable requirements. The third-party audit process includes the verification of systems,

processes and practices at the exporter, as well as at a representative sample of its supply chains up to and

including mine sites.

The third-party audit process is managed by the ICGLR Audit Committee (the Committee), a tripartite

forum representing government, industry as well as civil society. The Committee accredits auditors and sets

the standards and terms of reference for the audits. According to the ICGLR Certification Manual (Version

July 2019), the Committee is further responsible to review the audit reports submitted by the accredited

auditors.

The specific objective of this audit is to verify the level of conformance of Raw Minerals Resources’ (RMR)

systems, processes and practices, up to and including mineral supply chains and mine sites of origin with

the audit criteria with a view to obtain certification of RMR under the ICGLR RCM.

b. Auditee

i. General Information

RMR was awarded its license to operate as a buyer and exporter of cassiterite, colombo-tantalite and

wolframite by ministerial ordnance 760/745/2018 on 12 July 2018.

The Head Office of Raw Minerals Resources is located at 22 Swahili Avenue, Quartier Asiatique, Rohero,

Bujumbura, Burundi. The RMR Head Office is a secure comptoir comprising of office space for

management and administrative staff as well as secure warehousing for bagged and tagged minerals prior

to production. There are also separation and processing facilities on site. The auditor was given full access

to all the quantitative data and qualitative data necessary for this audit.

RMR is a participant of the International Tin Association iTSCi traceability scheme. The RMR comptoir

receives both separated and mixed rough ore from a number of small co-operative run mines in the north

of Burundi. In line with Burundian legal requirements and ICGLR RCM requirements minerals arrive from

suppliers in iTSCi tagged sacks. Samples are taken by both RMR and OBM for grade analysis to assess

payment for the relevant supplier. RMR has a sample lab on site. The sacks, depending on their contents,

are then emptied, dried, crushed and then further processed. The production information is logged into a

voucher book in triplicate, a white copy going to iTSCi, a yellow copy going to RMR, and a pink copy

going to OBM.

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Shipping is handled by Bollore and accompanying security.Ore is transported in 500 kg sacks with

accompanying documentation and tags. RMR’s production is sold directly to iTSCi participating clients in

Malaysia and Singapore. When sufficient mineral is ready for export, all tags are placed in a packet, which

is inserted inside the relevant sacks, and they are then taken by road to Dar-es-Salaam for onward shipping

by sea.

Each shipment is accompanied by an iTSCi ‘C2’ Exporter Declaration Form which includes data

concerning the shipper, the trader, the end smelter, company lot numbers, iTSCi shipment numbers, taxation

payments, bills of lading and invoices.

ii. Business Information (includes type of mines sourced from LSM and/or ASM)

The supply chain for cassiterite and colombo-tantalite to RMR consists of X mine sites controlled by

cooperatives in northern Burundi. The auditor was able to inspect five of the co-operative run sites as well

as Kivuvu.

The audited, cooperative-run mine sites that supply RMR were:

1.

Date of

visit

Site Cooperative Mineral Comptoir

d’achat

Province Commune Telephone

19/7/2019 TABA GIRUMWETE

NTEGA

Coltan RMR Kirundo

Ntega 69090128

2.

Date of

visit

Site Cooperative Mineral Comptoir

d’achat

Province Commune Telephone

22/7/2019 RUNYINYA GATETE

DUSHIREHAMWE

Wolframite RMR Kirundo

Busoni 69171153

3.

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Date of

visit

Site Cooperative Mineral Comptoir

d’achat

Province Commune Telephone

22/7/2019 MPINGA PAMBU Cassiterite RMR Kirundo

Busoni 69171355/ 71959266

4.

Date of

visit

Site Cooperative Mineral Comptoir

d’achat

Province Commune Telephone

22/7/2019 GATARE PAMBU Cassiterite/

Tantalite

RMR Kirundo

Busoni 69171355/ 71959266

5.

Date of

visit

Site Cooperative Mineral Comptoir

d’achat

Province Commune Telephone

24/7/2019 KASENYAMISANGE

II

BUCOMI Coltan/

Cassiterite

RMR Ngozi

Busiga 69160000

c. Auditor

i. Audit Firm

Martello Risk Ltd

ii. Lead Auditor

Dr Caspar Fithen

2. Scope of audit

a. Methodology

Martello Risk conducted a thorough literature review of existing, open-source material concerning

RMR. A total of 5 documents were examined as part of the pre-audit planning process. The were

no iTSCi incident reports on the TIA website. The reviewed literature concerned broader policy

documents covering gold and 3T supply chain control for the Great Lakes Region. This review

underpinned a comprehensive risk assessment which formed the foundation of the mine site

inspection strategy and qualitative and quantitative data collection for the purpose of assessing

conformance to ICGLR status and progress criteria.

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This audit was the first ICGLR audit for RMR. The timeframe to schedule the audit was fully

respected by the company. The audit was undertaken from 17/07/2019 – 26/07/2019. All

production and export records for the past 12 months were inspected.

b. Provide a short overview of what was actually reviewed including: records, operations,

mine sites, and other entities that were part of the audit.

QUALITATIVE DATA GATHERING

Supply Chain Site Inspections

In line with the requirements of the OECD Due Diligence Guidance for Responsible Supply Chains

of Minerals from Conflict-Affected and High-Risk Areas and the ICGLR Regional Certification

Mechanism Martello Risk gathered qualitative data pertinent to the audit of the supply chain of RMR

through interviews with individuals at the following points:

1. EXPORTER

2. TRADE AND TRANSPORTATION

3. MINING

QUANTITATIVE DATA GATHERING

In line with the ICGLR Certification Manual, that “auditors shall inspect a large enough percentage of the records in order to justify general conclusions about the totality of the record set”. Specifically, Martello Risk inspected the entire data set for production, tagging and shipping for the 12 months prior to the audit. Martello Risk conducted representative sampling of records at the following points along the supply chain: 1. EXPORTER

a. Operations

b. Personnel

c. Contracts

d. Authorities

e. Material & Financial Accounting 2. MINE SITES

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a. Mine-site Operator

b. Due Diligence

c. Personnel

d. Contracts

e. Authorities

f. Financial and Material Accounting

3. Findings (flag status)

a. Supply Chain Actors (from Mine(s) to Exporter)

Summary Table of conformance to RCM status criteria

CONFLICT HUMAN RIGHTS

FORMALITY / TRANSPARENCY

Summary Table of conformance to RCM progress criteria

CONFLICT HUMAN RIGHTS

ENVIRONMENT FORMALITY / TRANSPARENCY

COMMUNITY DEVELOPMENT

b. Exporter

Summary Table of conformance to RCM progress criteria

CONFLICT HUMAN RIGHTS

FORMALITY/ TRANSPARENCY

MANAGEMENT SYSTEM

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4. Summary of Non-Conformances (all red and yellow flag issues)

SUMMARY OF NON-CONFORMANCES

Number: Non-Conformance related to

what requirement Description of non-conformance:

Auditee’s Proposed Corrective

Action:

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Add or delete lines as needed

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5. Conclusion

Based on the evidence made available to the auditor, RMR has undertaken best efforts to comply with all

audit criteria.

Therefore, based on the scope and findings of the audit, the locations visited, the actors consulted, and the

processes reviewed, RMR has demonstrated a level of conformance with the Audit Criteria that is consistent

with a green flag.