BGR Bundesanstalt für Geowissenschaften und Rohstoffe

Certified Trading Chains

The general Certified Trading Chains (CTC) approach was developed and internationally consulted in 2007-2008 and has been implemented at a pilot scale by BGR and its national partners in Rwanda (2009-2011) and, in adapted form, in the DRC (2009-2016). The main objective of the CTC scheme is to certify responsible mining practice or “ethical” production and trade of minerals, notably the 3TGs (but in principle open to other minerals as well). Importantly, the scheme acknowledges the specific challenges pertaining to the ASM sector and is hence particularly concerned with feasibility and impact in an artisanal context. It emphasizes process rather than just demanding and certifying certain performance targets.


The Improvement Dimension of CTC

The general Certified Trading Chains (CTC) approach was developed and internationally consulted in 2007-2008 and has been implemented at a pilot scale by BGR and its national partners in Rwanda (2009-2011) and, in adapted form, in the DRC (2009-2016). The main objective of the CTC scheme is to certify responsible mining practice or “ethical” production and trade of minerals, notably the 3TGs (but in principle open to other minerals as well). Importantly, the scheme acknowledges the specific challenges pertaining to the ASM sector and is hence particularly concerned with feasibility and impact in an artisanal context. It emphasizes process rather than just demanding and certifying certain performance targets.

The CTC scheme integrates improvement of the auditee’s operations through a twin-audit approach consisting of a baseline audit (including specific recommendations how mining companies or cooperatives may improve their performance) and a compliance audit. Audits are performed against the CTC standard set (see below). The scheme aims to facilitate responsible engagement along the supply chain: smelters or downstream stakeholders shall provide targeted technical support to their upstream clients to help implementing audit improvement recommendations. In turn, they benefit from improved supply security and knowledge of their suppliers through strengthening of supplier relationships and encouraging exchange of data. Issuing of CTC certificates by national authorities is based on verifying sufficient performance improvement, measured against the different CTC standards evaluated during the compliance audit.

The five CTC principles and 20 individual standard topics as adopted in Rwanda. For details refer to the specific standard descriptionsThe five CTC principles and 20 individual standard topics as adopted in Rwanda. For details refer to the specific standard descriptions Source: BGR

The set of CTC standards does not only integrate conflict risk-related aspects such as the origin of minerals, traceability and transparency, but focuses on responsible mining practice through evaluating health and safety, environmental performance, and local community engagement aspects of the audited artisanal mining entity (company or cooperative). The CTC compliance mechanism – as the base for certification – integrates all individual standards (with adjustable weighting factors for single standards as either a performance or “do or die” standard).
Individual standards are grouped into five universal CTC principles. As part of the CTC approach, standards are adaptable to reflect the national regulatory context. In Rwanda, where CTC was applied for the first time, a total of 20 individual standards were integrated into the scheme. The fundamental CTC standard base has been developed based on international integrity references (e.g., the OECD Guidelines for Multi-national Enterprises) with a specific focus on their feasibility in the ASM sector context. Individual performance level indicators are defined for each standard to streamline accurate auditing procedures and verification of audit findings.

The five CTC principles comprise:

  1. Traceability and Transparency: Origin and volumes of produced goods as well as company payments to host government are transparent.
    Upstream mineral trading chains start at the production site and include all steps of internal and external mineral upgrading, shipping and trading within the host country, export, and import on behalf of an industrial consumer. Precise, accurate, and verifiable shipping documentation comprises information on origin, amount, type and quality of traded minerals. This information needs to be maintained and updated throughout the supply chain, and has to be made available to a third-party auditor upon request in the frame of supply chain certification.
    This approach shall ensure that the verification of mineral origin and traceability is particularly robust. For CTC auditing purposes, the auditor is required to evaluate supply chain integrity by performing plausibility checks where information from different sources (documentation, interviews, site inspections) is verified and cross-referenced, e.g., by comparing numbers of artisanal miners, payments made to the miners, and usage of mining equipment and explosives to mineral production figures recorded for a given concession in a given time period. The audit also includes an evaluation of the transparency and legality of mining operations and associated payments. As such, the first CTC principle forms a core contribution to the OECD supply chain due diligence concept.
  2. Labor and Working Conditions: The company does not use child labor and ensures fair remuneration and work conditions as well as continual improvement of health and safety measures for all employees.
  3. Security: The company ensures security on company sites whilst respecting human rights.
  4. Community Development: The company consults communities in which it operates and contributes to their social, economic and institutional development taking into account gender.
  5. Environmental Protection: The company seeks continual improvement of its environmental performance.

Individual CTC standard sets have been formalized in Rwanda and the DRC. Note that these documents outline the respective CTC standards and level descriptors used during auditing. They do not describe the CTC system as a whole.

The updated CTC scheme in the Democratic Republic of the Congo (2019)

After a series of consultations throughout 2018-2019, a new CTC Manual for the DRC was introduced in October 2019. The new scheme updates and replaces the previous CTC Manual in place. Key updates include

  1. establishing a multi-stakeholder steering structure for CTC governance;
  2. aligning the CTC standard with the OECD Due Diligence Guidance and the new DRC Mining Code of 2018; this was done through development of 38 new standard indicators replacing the old 21 standard indicators;
  3. expanding the scope of CTC certification beyond the 3Ts and gold: CTC now applies to all artisanal mining activities in the DRC involving the 3Ts, gold, copper-cobalt, galena, and semi-precious stones;
  4. replacing the former approach of baseline and compliance audits with a single audit process.

In order to allow sustainable operationalization of the CTC scheme in the DRC, a national pool of future CTC auditors will be established in 2020.

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