How important is responsible sourcing these days? It appears that both for upstream and downstream companies, it is becoming more and more of a priority. For tin, the Responsible Mineral Initiative lists sixty companies as conformant with their Responsible Minerals Assurance Process (RMAP), and another five as in the process of becoming conformant - 75% of eighty-six eligible tin smelters. On the downstream side of things, both the European Union and the United States - home to some of the leading downstream manufacturers working with those metals - have passed legislation requiring companies to assure their tin is sourced in a conflict-free manner.
Now those requirements are typically discussed, developed, and decided upon in countries like the United States, France (where the OECD has its headquarters), or Brussels - always with input from the relevant companies and actors on the ground. The places where implementation often starts are the DRC or Rwanda, among others, and assuming that everything works well there, it means the supply chain can rely on credible information and compliant material. The RMI recognizes this fact through its engagement with upstream mechanisms, and overall stakeholder engagement from different sectors and geographies.
As requirements have become both stricter and more in-depth, implementing them increasingly requires companies to have dedicated and specialized personnel. Without these personnel, the demands for traceability and assured compliance could not be met. Incidentally, these are also the people we work with at Minespider, since they are the ones using our platform on a regular basis. Theophile Ishimwe is one of those people. He works at the traceability and due diligence department of LuNa Smelter, one of Minespider’s longest standing partners who has started using the digital platform for traceability purposes starting in late 2020. The department is headed by Juliette Mukakaranda, who directly reports to the Managing Director, Joseph Butera.
Educated as a mining engineer, Theophile describes the journey to being a due diligence professional as a gradual one: “My background is as a mining engineer, but after university I worked first with the RMB [Rwanda Mines, Petroleum and Gas Board]. Back then it was called the GMD - the Geology and Mines Department. I then worked with Mineral Supplies Africa (a prominent mineral trader in Kigali at the time); which is where I first heard about the OECD guidance and started working as a Due Diligence Officer. Four years ago I started working with LuNa Smelter. This is where I have learned most about Due Diligence and responsible sourcing.”
The reason for that is the fact that LuNa Smelter has a peculiar role, within a peculiar geographical context.
As Rwanda is a neighbor to the DRC, it is subject to the Dodd-Frank Act, which defines the DRC and all adjacent countries as “Conflict Affected or High Risk Areas” (CAHRA), in spite of not having armed conflict in Rwanda. The EU is more nuanced in its Conflict Minerals Regulation, and its indicative CAHRA List does not list Rwanda. (For more information on Dodd-Frank and the EU Conflict Minerals regulation, see here.) LuNa Smelter is the first fully RMAP-conformant tin smelter in the Great Lakes region and sources input material from Rwanda, Tanzania, and the DRC - hence, a full range of Due Diligence Requirements apply.
Theophile explains, what that means for his day-to-day, in Rwanda:
“I go to the field about three days per week. If we have a new supplier under contract, I immediately go there and visit them and check that the operations are done in alignment with our expectations, such as verifying all critical points related to mine site due diligence, for example that there are no children on site.”
Advocating for and maintaining compliance on site is what Theophile describes as the biggest challenge. “Miners in Rwanda, they don’t know the details of the OECD guidelines. They have limited knowledge on safety requirements and environmental standards in mining operations.” The only help here is continued engagement and ongoing improvements, ultimately leading to an improved understanding of and adherence to the standards in place. This is something that has often been lacking.“ Having a smelter in the country is helpful to foster this progress, according to Ishimwe, as now the concentrate is processed in Kigali:
“It's just boosted the traceability understanding to another level. Because recently Rwanda used to send materials to, let's say in Malaysia, but no one no one knew what happens when materials arrive in Malaysia, and now it's here in Kigali. So it's up to us and it's a very good opportunity. We have experts here in LuNa, we have support of our external stakeholders, and we can do it – organize trainings, sharing the knowledge. And often it’s not training but more like marketing and conversations, so people start understanding it better. In the end you need traceability in the whole country and not only for cassiterite, also for coltan, for wolfram, for all minerals.”
According to Ishimwe, these changes have brought about a positive change in the way audits are thought of and implemented. In the past many visits and audits instilled fear in the miners, as the message was centered around the threat to either comply, or have the operations shut down. This has led to a superficial compliance, where mines would pretend everything is perfect, thereby avoiding any chance for gradual improvement.
Greater visibility can create investment opportunities for the upstream. In many cases, more investment would also be helpful of course: “Many companies, all they want to do is get minerals out of the ground and sell them. They don’t see that their business will be more profitable in the long run if they take care of their workers. With more investment, mine sites could have better equipment, and be safer to operate.”
Maintaining RMAP Conformance
The Responsible Minerals Assurance Process is the RMI’s flagship program to assure responsible sourcing of conflict minerals. During an audit process, the RMI auditor makes sure that the auditee has all processes and policies in place to ensure compliant sourcing, and reviews the according documentation. In the case of LuNa Smelter, which is based in Rwanda - a CAHRA according to the Dodd-Frank Act - an RMAP audit is due every year (every three years for companies not in CAHRA locations).
The work, however, is continuous, as Theophile describes: “We prepare for the RMAP every day. Because for every piece of mineral we purchase, we have to make sure that everything is done compliantly, we have to document it, and make sure that the documentation is available for the audit”. In the case of LuNa, this has so far always been done well: “Since I’m here, I’ve participated in three RMAP audits, and LuNa has always passed them, a fourth one is currently under process.”
Vision for the mining sector and concluding thoughts
Mining is Rwanda’s second biggest source of export revenue (topped only by tourism), and the sector is growing. Not only that - Rwanda is developing it’s metals processing and metallurgy sector too, as the example of Luna Smelter vividly portrays. As the sector is gaining more importance, so is the awareness and appreciation of responsible sourcing.
“It used to be the case that people just said, ‘I need 100 tons of cassiterite, get it out of the ground and ship it from Kigali to Malaysia’ - that doesn’t happen so much anymore.” People are increasingly aware of the importance of responsible sourcing, are asking more questions, and of course are also buying refined products, not only unprocessed minerals. This gradual change is enabled by the persistent work of all the people on the ground involved, as well as the awareness of companies further downstream, that the provenance of their mineral matters.
Asked about what he hopes for the Rwandan mining sector in the future, Theophile says “I would hope that we are not listed as a CAHRA anymore. There is no conflict in Rwanda. And actually not only for Rwanda, across the entire region there are areas of conflict and of peace. When I look at the EU CAHRA list, I see that in Nigeria for example some provinces are considered CAHRA, some are not. We need this level of detail here as well and not label entire countries just because they are neighbors of the DRC.
From mine site audits to assessments of entire regions and countries, one aspect of due diligence and traceability is particularly important: emphasizing continuous improvements, and showing pathways to compliance, not on paper but to the benefit of the people. Companies have to realize it is ok to have certain shortcomings, as long as there is commitment to continuous improvement. Only then does this bring about the change envisioned by those who originally set up the regulations. It seems significant progress has been made in the past years, as Rwanda evolves from a supplier of mineral concentrate to an exporter of refined material, and industry players are increasingly emphasizing the need for actual compliance. This change is in no small part due to the work of “the people behind traceability”, who are doing the day-to-day work of ensuring companies not only comply, but understand why.
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