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BGR Support to Mineral Certification in Rwanda 2008-2013

Early Works: The CTC Pilot Project

From late 2008 – mid 2011, the German Federal Institute for Geosciences and Natural Resources

(BGR) implemented the pilot project on Certified Trading Chains (CTC) in Rwanda, together with

the Rwanda Geology and Mines Authority (OGMR) and with further input by the Rwanda Bureau of

Standards (RBS). The project succeeded in demonstrating, for the first time, the feasibility of

mineral supply chain certification in the artisanal 3T mining sector of the central African Great

Lakes region. Certification was based on a voluntary approach targeting the principle areas of

“corporate social responsibility” (supply chain transparency, mine working conditions, security,

community engagement and environmental management) especially in the artisanal mining

context. BGR facilitated an independent baseline and compliance audit process at five major

Rwandan mines, and provided additional guidance to miners towards becoming compliant with

relevant standards. Out of the five mines participating in the pilot project, three were eventually

certified as CTC-compliant.

Fig. 1: CTC Audit results from Rwandan mineral producers participating in CTC pilot project. Companies

were audited by a third party between late 2009 and early 2011. Specific audit results are presented as

average for all 20 CTC audit standards (each differentiating performance through level descriptors from 0-4).

An average of level 3 (red line) is required to be certified as “CTC-compliant”. Note that significant

performance improvement is observed at all five CTC participants.

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The CTC concept was developed in 2007-2008 using, among others, the OECD (Organization for

Economic Development and Cooperation) Guidelines for Multinational Enterprises as a reference

standard. This was before the OECD Due Diligence Guidance1 had been developed as a reference

document for supply chain due diligence management in conflict-affected and high-risk areas, and

prior to intensified discussions on the conflict mineral provisions of the US Dodd-Frank Act, both

taking place mostly in 2010-2011 and directly affecting Rwanda as well as the DRC and its other

neighboring states. As a result, in 2010-2011, German International Cooperation (GIZ) and

Partnership Africa-Canada (PAC) supported the International Conference on the Great Lakes

Region (ICGLR) to develop a specific certification scheme, the Regional Certification Mechanism

(RCM), which was adopted by the ICGLR in late 2011. Due to its later inception, the RCM was able

to fully incorporate the OECD supply chain due diligence reference framework.

Fig. 2: Specific audit performance of CTC pilot participants in Rwanda in each of the five CTC principles

(under which 20 CTC standards are assembled). Results of the compliance audits indicate that, among the

five principles, responsible environmental management seems to be one of the major challenges in the

Rwandan ASM sector.

The RCM also integrated CTC standards (mostly as “progress criteria”) at the mine site level. The

RCM does not certify compliance against these progress criteria, however. The primary purpose of

the RCM is to provide a credible, multi-layer institutionalized certification framework with regards to

supply chain due diligence (see below). In that fashion, the RCM and CTC approaches work

1 Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-risk

Areas. It includes a five-step due diligence framework and provides additional recommendations to different supply chain stakeholders, e.g., not to use worst forms of child labor or forced labor for mining operations.

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complementary to each other: adherence to RCM standards aids companies to demonstrate they

comply with international due diligence expectations (e.g., managing conflict risks, the worst forms

of child labor, and chain of custody tracking), whereas participation in CTC allows companies to go

beyond pure supply chain due diligence as a market access requirement and demonstrate

responsible mining practice (e.g., work safety, fair prices, gender aspects, community engagement,

environmental management).

In parallel to the CTC project, BGR also developed and refined the Analytical Fingerprint (AFP)

method for 3T minerals, both scientifically and on-the-ground (through sampling in Rwanda). AFP

allows for independent verification of mineral origin by comparing the composition of 3T mineral

concentrate samples of a known origin with an unknown sample, much as a DNA test works. AFP

sampling and application is included in the CTC and RCM frameworks both.

The ICGLR Regional Certification Mechanism

The RCM represents a multi-layered approach to contribute to institutionalizing mineral supply

chain due diligence in the Great Lakes region. It relies on a combination of national- and regional-

level process standards (consulted and formalized under the auspices of the ICGLR) designed to

allow transparent tracking of mineral chains and conflict risks from the mine site level to the point of

export. This includes monitoring of the status of the involved supply chain actors through different

procedures such as mine site inspections, chain of custody verification checks, external risk

assessments, and independent audits. Additionally, the RCM defines the steps different

stakeholders (companies and government) are required to perform in response to a given risk or

violation of standards, and includes associated reporting procedures (using the ICGLR secretariat

as a publication platform). In this regard, it helps companies to comply with the five-step OECD

due diligence framework.

Individual RCM implementation responsibilities are sketched in Figure 3a & b.

Since its formalization in 2010/2011, imprecise communication has surrounded the RCM and

“ICGLR certification”. A common misunderstanding is that the ICGLR secretariat in Bujumbura

would be in charge of RCM implementation and certification. However, the main responsibility for

on-the-ground RCM implementation falls to ICGLR member states such as Rwanda (including

government authorities and private sector stakeholders). Aside from providing the coordination

platform to set RCM standards, ICGLR’s main role in the scheme refers to regionally monitoring

RCM implementation in the different member states, directly or through associated independent

bodies, by coordinating an audit and risk assessment process. The latter aims at comprehensively

verifying compliance of RCM implementation in the member states against the actual RCM

standards and procedures (note: this refers to the compliance of both the private sector and the

implementing government agencies in the member states).

Implementing the RCM overall thus relies on committed and coordinated implementation

management by the member states and the ICGLR secretariat both. Importantly, the RCM’s

credibility (and its compatibility with the OECD Due Diligence Guidance) hinges on successful

implementation at all design levels – if any party fails to implement their share in the process, the

overall credibility of the process is at risk. In Rwanda, all relevant RCM standards were included in

a comprehensive and enforceable regulation of the Ministry of Natural Resources (MINIRENA

regulation no. 2/2012), coming into force on 28 March 2012.

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Fig. 3a: Stakeholders participating in the implementation of the RCM. The RCM is integrated into the

Regional Initiative against the Illegal Exploitation of Natural Resources (RINR). The RINR is steered by a

Steering Committee (SCOM) composed of representatives from all ICGLR member states. The SCOM

provides recommendations to a regional ministerial forum (RIMC) which instructs the ICGLR secretariat on

the relevant processes. The whole RCM process thus derives its credibility and authority from being fully

owned by the ICGLR member states.

Present Works: The BGR Project Module in Rwanda since Mid-2011

Starting from January 2011 and running until June 2015, the German Federal Ministry for

Economic Cooperation and Development commissioned BGR and GIZ to jointly implement a

support program to the ICGLR. BGR’s module includes two components:

1. introducing AFP infrastructure and management concepts as a tool directly available in the

Great Lakes region, and

2. supporting the implementation of the RCM in Rwanda and Burundi.

Project partner in Rwanda is the successor of former OGMR, the Rwanda Natural Resources

Authority (RNRA), in particular, its Geology and Mines Department (GMD). RNRA/GMD is the lead

government authority in charge of RCM implementation in Rwanda, with additional support and

expertise provided by RBS.

As the first and most important step of the project, BGR is sensitizing its partners with regards to

the scope of their responsibilities within the RCM framework so as to allow full institutional

absorption and ownership of the different RCM processes, including appropriate integration of

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relevant processes into national action plans and associated budgets. While this process naturally

takes more time than direct third party-driven actions, it is a critical requirement in order to

establish a long-term, sustainable certification process on a broad scale in Rwanda.

Fig. 3b: Individual RCM implementation responsibilities. The member states are responsible for day-to-day

implementation of mine inspections, chain of custody (mineral traceability) management, and mineral export

certification, all in accordance with ICGLR RCM standards and procedures. The ICGLR audit committee is

entirely made up of delegates from member states and is independent from the ICGLR secretariat (the latter

merely playing a facilitating role in the process). The Independent Mineral Chain Auditor (IMCA) is a special

investigator reporting directly to the Executive Secretary of the ICGLR. While independent 3rd

party audits

under the supervision of the audit committee focus on individual supply chain compliance, the IMCA is also

tasked to perform on-going risk assessments and compliance assessments of the RCM system as a whole.

If any actors, including member states institutions, do not implement the RCM according to the agreed

regional standards, the IMCA has the authority to shut down any malfunctioning parts of the RCM and

request stakeholders to bring the system processes into full RCM compliance. These multi-level compliance

checks by different, mutually independent stakeholders provide the base for the credibility and transparency

of the RCM system as a whole.

Since mid-2011, BGR has supported GMD to establish a dedicated mine inspections unit fully

capable of performing inspections as required under the RCM. Through workshops and test

inspections, an inspection template was developed that covers both regional (RCM) standards as

well as additional elements of national interest. Following four pilot inspections in 2012, the

inspection scheme is now implemented at a broad scale in Rwanda and running on its own

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initiative. More than 10% of all (ca. 200) Rwandan mine sites have been inspected in early 2013

with a plan (including availability of trained staff and a dedicated budget) to roll the scheme out to

all mines in late 2013/ early 2014. Apart from the actual inspection process, GMD, with BGR

support, also organized outreach workshops in all Rwandan provinces where miners, local

administration and security organs were sensitized on relevant RCM standards.

Fig. 4: Project-relevant activities in Rwanda. Illustrations of responsible health/safety and environmental

management (here: through water recycling; A), GMD mine inspections (B, F), regional peer exchange on

best practice (C, G), training workshops (D) and AFP sampling (E).

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In collaboration with the Africa Governance Initiative’s Strategic Capacity Building Initiative and

PAC, BGR has continuously worked with GMD to improve management and oversight of mineral

supply chains in Rwanda. This included the development of internal management processes for

the traceability project (the latter being implemented by GMD in cooperation with iTSCi, the ITRI tin

supply chain initiative), as well as national-level supply chain verification through a Certification

Unit. The Certification Unit, jointly established in mid-2012 by GMD and RBS (operating

independently from the GMD-iTSCi traceability project) shall be responsible for issuing ICGLR

certificates in Rwanda for individual mineral shipments (containers) based on a detailed verification

of shipment contents: only shipments where individual lots can be tracked back to GMD-inspected

eligible (that is, green or yellow-flagged) national mine sites and where a given exporter submits to

an annual independent 3rd party audit are eligible to receive an ICGLR certificate in Rwanda. As

such, ICGLR certificates from Rwanda shall provide full due diligence assurance for international

buyers.

BGR also continues to support GMD to proactively share best practice on certification, both as an

on-the-ground peer-learning exchange within the Great Lakes region, as well as internationally

(e.g., through participation in the international consultation process on due diligence, or publication

of relevant reports).

While the BGR project focus has moved towards supporting RCM implementation in recent years,

its project partners in Rwanda have also remained strongly interested in questions of responsible

mining practice as originally included in the CTC concept. Therefore, BGR has continued to

provide capacity building for GMD on significant items such as mine health and safety

management through both workshops and practical field training.

AFP reference sampling refers to BGR-accredited samplers obtaining mineral concentrate samples

directly at individual mine production areas (that is, tunnels and pits) where full control on the origin

of these minerals is available. Since 2011, GMD, with support by BGR, has intensified AFP

reference sampling activities in Rwanda. A total of 377 reference samples have been taken in

Rwanda so far (see Fig. 5), accounting for more than 50% of the total national production of

cassiterite, coltan, and wolframite, and making Rwanda the country with the highest AFP reference

sampling density worldwide. Stakeholders (e.g., auditors) looking to verify mineral supply chains

originating from Rwanda may take a control sample along any supply chain and submit it for AFP

analysis for comparison with any of these reference samples. Any such activities taking place

under the umbrella of the ICGLR/RCM are fully funded through the German support program until

2015 and thus do not invoke any external costs. A Management Unit was recently established at

the ICGLR Secretariat to manage the AFP process framework in this regard.

Additionally, training was provided and a petrographic laboratory was installed at GMD for full in-

country preparation of samples as “polished sections” required for subsequent (mass-

spectrometric) AFP analysis taking place at international laboratories (in the absence of such a

petrographic laboratory, AFP reference samples were prepared at BGR in Germany). The

petrographic laboratory also allows for preparatory works related to other geological research

(such as studying ore minerals and rock alteration features for mineral exploration purposes).

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Fig. 5: AFP reference samples taken in Rwanda by June 2013, illustrated on a map of Rwanda calculated

from digital elevation data (USGS). A database with comprehensive data (scope and type of mining

activities, geology, mineralogy, and geochemistry) on each individual sample is available. Individual

reference samples are taken by a team (at minimum, two members) of BGR-accredited GMD samplers.

Note: 377 reference samples have been taken in Rwanda to date; however, due to the scale of the above

map compared to the high resolution of AFP sampling at a given mine, not all single samples may be

graphically differentiated.

The availability of a comprehensive dataset on current Rwandan mineral production mineralogical

and geochemical features, allowing for the option of independent spot checks through the AFP

method, combined with the installment of a regular mine inspection regime, the establishment of a

national export certification process to verify chains of custody, and the formalization of

independent audits and risk monitoring (all through a regulation by the Ministry of Natural

Resources in agreement with the ICGLR RCM standards and procedures) is meant to strengthen

the credibility of and generate confidence in legitimate mineral production in Rwanda.

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Contacts:

Contacts to GMD counterparts responsible for processes outlined above can be provided upon

request.

BGR Rwanda office; c/o Rwanda Natural Resources Authority/Geology and Mines Department;

Avenue de la Justice, Muhima, Kigali.

Dr. Philip Schütte, +250 (0)78 22 69 699, Philip.Schuette@bgr.de

Ms. Patricie Mwambarangwe, +250 (0)78 886 48 79, m.patricie370@gmail.com