Author(s): Estelle Levin-Nally and Rupert Cook, with contributions from Alain Chishugi, Angela Jorns and Pascale Mulumeoderhwa
Client(s): PROMINES
Date: Apr 2015
From 2013-2015, Levin Sources provided guidance to PROMINES, the implementing body for the World Bank’s Project to Support the Mining Sector in DRC on building a robust fabric for good governance of its minerals sector through supply chain traceability and certification.
Levin Sources carried out a comparative analysis of the certification and traceability systems in place in the DRC and in the world, in order to propose a system that is appropriate to the needs of the country, coherent with the procedures of the ICGLR’s Regional Certification Mechanism (RCM), and responsive to international requirements. The results were used to propose how to govern Congolese mineral supply chains through private sector mechanisms that respond to the realities of the Congolese context and the expectations of the Congolese government in terms of efficacy and cost, whilst being in conformance with the demands of the ICGLR and the final consumers of relevant minerals in terms of conformance with the OECD Due Diligence Guidance.
Over the course of this research, over 200 Congolese and 50 international interlocutors representing a wide range of upstream and downstream conflict mineral supply chain stakeholders. Fieldwork covered sixteen mining and associated trading sites, ten of which were for gold. ELL also developed and used two analytical frameworks, keeping in mind the international, regional and national frameworks that such a system must align with. The first establishes the key elements of a conflict minerals assurance system and the second provides a framework for evaluating the sustainability performance of a traceability and due diligence system.
A comparative analysis was done on the following certification initiatives: the DRC’s Certified Trading Chains; iTSCi’s Tin Supply Chain Initiative; the Better Sourcing Program and MineralCare’s GoldCare & 3TCare. Furthermore, three additional traceability initiatives were compared: PWC’s GeoTraceability; MetTrak’s software solution and SERCAM. Other relevant standards not currently operational in the DRC were also considered as potentially of use for increasing the DRC’s conformance with the OECD Guidance and the ICGLR’s RCM, and special attention was given to the certification of gold due to its particularities that make it more prone to illegal trade.
The following general recommendations can be drawn from the comparative analysis:
- Mine site validation to be streamlined and accelerated.
- ASM miner cooperatives and small companies should be granted greater security of tenure and should be issued with an increased number of ASM permits.
- The DRC government needs to ensure that cooperatives bring tangible benefits to ASM miners.
- Any traceability system will depend upon government agents, so capacity-building of government agencies is a priority.
- There is a need to consider how the costs of upstream due diligence can be distributed more fairly so the burden is not placed disproportionately on the most vulnerable in the chain.
- In order for companies to be able to rely upon assurance systems operational in DRC, DRC must insist that any initiative with which it signs a Memorandum of Understanding has undergone an OECD DDG conformance check.
- DRC should aggregate and publish data, statistics and reports of relevance to downstream buyers of ‘conflict minerals’.
- As part of its consideration as to allowing new initiatives to operate in DRC, the government should demand that these initiatives present information on their business model including how they will be financed.
- The GDRC needs to establish and publish its procedure for vetting and approving a conflict minerals initiative or traceability service provider.
