THE EU CONFLICT MINERALS REGULATION: PERSPECTIVES FROM PRODUCER COUNTRIES

THE EU CONFLICT MINERALS
     REGULATION: PERSPECTIVES FROM
          PRODUCER COUNTRIES
                                       13-14/01/2021

On the occasion of the application of the EU Conflict Minerals Regulation on 1 January 2021,
a milestone event in responsible mineral sourcing, the German Federal Ministry for
Economic Cooperation and Development (BMZ) and the Responsible Minerals Initiative
(RMI) convened a multi-stakeholder conference to take stock of the implementation and
impact of the EU Conflict Minerals Regulation, in particular through the lens of producer
countries.

The conference featured interactive discussions in an inclusive multi-stakeholder spirit,
engaging a global audience of public, non-profit and private sector participants. It explored
impacts of past due diligence measures as well as anticipated impacts of the EU Conflict
Minerals Regulation on stakeholders in producer countries across the board.

This document reflects selected outcomes of the conference. It is a non-exhaustive list of
discussion points and the views herein expressed can under no circumstances be viewed as
representing the positions of the organizers of the conference.

BACKGROUND: EU CONFLICT MINERALS REGULATION

The EU Conflict Minerals Regulation went into effect on 1 January 2021 and establishes due
diligence requirements for EU importers of tin, tantalum tungsten and gold (3TG) over
defined thresholds. It requires them to source their minerals responsibly and to ensure that
their supply chains do not contribute to funding armed conflict by aligning their practices
with the standards set out in the OECD Due Diligence Guidance for Responsible Mineral
Supply Chains.

The new regulation applies directly to between 600 and 1000 EU-based importers of tin,
tantalum, tungsten and gold. As these importers are required to identify and control smelters
and refiners in their supplier chains, indirectly the regulation also impacts smelters and
refiners globally.

Supported by:

The European Commission has published a non-exhaustive and indicative list of conflict-
affected and high-risk areas (CAHRAs), which it will regularly update. It gives an indication
of areas that are currently or could be affected by conflict and other related illegal activities,
and it does not necessarily include every area in the world affected by conflict, which means
that companies have to comply with the Regulation when operating in CAHRAs even if they
are not listed.

A key feature of the Regulation is its reliance on industry schemes. The European
Commission will review and assess the alignment of applying schemes with the OECD Due
Diligence Guidance for Minerals Supply Chains. Companies that are in scope of the
Regulation’s due diligence obligation can comply through participation in those schemes that
are recognized by the Commission as meeting the criteria set by the Regulation. To help
companies, the European Commission will introduce a ”white list” of global smelters and
refiners which source responsibly.

EU member states play a key role in the implementation of the Regulation, particularly in
monitoring and enforcement, as each EU member state must check whether EU importers
comply with the Regulation. To that end, member states establish a national competent
authority.

OPENING AND WELCOME: GERMAN FEDERAL                            MINISTRY      FOR     ECONOMIC
COOPERATION AND DEVELOPMENT (BMZ)

The German Federal Ministry for Economic Cooperation and Development (BMZ) is
committed to strengthening responsible mineral supply chains.

The BMZ welcomes the Regulation as it establishes due diligence requirements for the
supply chains of 3TG minerals. As part of a smart mix of measures, it requires the support of
all actors involved: governments, industry and civil society. Through a multi-stakeholder
approach the Regulation can realize tangible impacts on the ground: the protection of miners
and their communities (especially in the ASM sector) in producing countries and the
strengthening of their human rights.

To that end, the BMZ closely collaborates with the European Partnership for Responsible
Minerals (EPRM). It works with bilateral and regional partners to strengthen extractive
sector governance, among them the Democratic Republic of the Congo, the International
Conference on the Great Lakes Region, the Mano River Union and the Andean countries.
Moreover, Germany supports governments of developing countries to negotiate better deals
with investors in partnership with the EU through the CONNEX initiative.

Supported by:

KEYNOTE ADDRESS: PRODUCING COUNTRY REPRESENTATIVE

AMBASSADOR JOÃO SAMUEL CAHOLO, EXECUTIVE SECRETARY OF THE INTERNATIONAL
CONFERENCE ON THE GREAT LAKES REGION (ICGL R)

Ambassador Caholo stated that in recent history the resource rich Great Lakes Region has
been marked by conflicts, which have affected the socio-economic wellbeing of the
population. As the major challenge he sees the missing link between the supply chain and
the formal economy. Illegal exploitation was one of the main root causes causing instability.
Consequently, he shared, the ICGLR signed the Lusaka Declaration in 2010 as a
comprehensive and collective solution.

Ambassador Caholo encourages using lessons learnt, for example from the Dodd-Frank Act,
which, he said, has been enforced without preliminary consultation with the leaders of the
ICGLR, leading to a de-facto embargo. Against this backdrop, he highlighted the importance
of dialogue. Additionally, he emphasized the need for horizontal and vertical integration of
due diligence and transparency. Initiatives should include governmental and industrial
stakeholders. Responsibilities, including costs, must be shared by all stakeholders along the
supply chain.

ICGLR, he stated, has developed a strategy for ASM of gold. The strategy strongly encourages
international actors to facilitate market access of responsibly mined and traded artisanal
gold. As important first steps he sees pilots on gold due diligence and traceability. However,
he also identified a need for physical solutions, which have to be implemented jointly by
national governments and industries. A regional framework could serve as guidance.
Additionally, Ambassador Caholo demanded a fair share of the financial burdens along the
supply chain.

JOSEPH IKOLI YOMBO YAPEKE, SECRETARY GENERAL, DEMOCRATIC REPUBLIC OF THE CONGO,
MINISTRY OF MINES

Secretary General Ikoli highlighted that the EU Conflict Minerals Regulation would
encourage producing countries to strengthen local mining governance, mainly in the ASM
sector by focusing on measures to formalize the sector (e.g. traceability system). He stated it
was also important to strengthen the qualification process of artisanal mining sites,
measures to promote peaceful coexistence of ASM and industrial mining and elimination of
child labour. Therefore, he encouraged the support of the EU and other actors.

Supported by:

Mr Ikoli called for a continuous political dialogue with the EU to address questions pertaining
to the Regulation’s accompanying measures. He went on to state that producer countries
advocated for sanctions for EU companies that violate the provisions of the Regulation. At
the same time the Secretary General called for technical and financial support to strengthen
local mining governance. It was necessary, he asserted, to cooperate and exchange
information. Further, he added, the DRC advocated for the application of sanctions against
transit countries that promoted illicit imports of 3TG into the EU.

Mr Ikoli further asked the EU to use its political and commercial weight to encourage tax
harmonization at the regional level between ICGLR member states.

The Secretary General closed by stating that the DRC welcomed the new EU Regulation and
encouraged the EU Commission to support capacity-building to strengthen the local
ownership of this legislation. Finally, he encouraged the EU to support the implementation
of his country’s Traceability Initiative for Artisanal Gold (ITOA).

CAN THE EU REGULATION ON CONFLICT MINERALS SUPPORT LOCAL SUSTAINABLE
DEVELOPMENT? PERSPECTIVES FROM CIVIL SOCIETY

In the lead-up to this conference, members of the Civil Society Pillar of the European
Partnership for Responsible Minerals (EPRM) consulted with about 50 civil society
organizations in 20 countries that produce gold, tin, tungsten and tantalum. Gabriela Flores,
who is a Senior Associate with the International Institute for Environment and Development
(IIED), presented an overview of civil society organizations’ perspectives on the EU Conflict
Minerals Regulation.

Ms Flores stated that the entry into force of the Regulation came with an opportunity to
leverage action – not only to reduce the entry of minerals that fuel conflict into the European
Union, but, crucially, action that leads to better outcomes for local sustainable development
and the human rights situation in the many communities that produce gold, tin, tungsten and
tantalum around the world. To unlock the Regulation’s potential to contribute to sustainable
development, she called for:

       1. Building knowledge of the Regulation in producing countries, especially
          beyond the Great Lakes Region. Whether the Regulation could help bring about
          positive changes, Ms Flores argued, would depend on local understanding of what
          the Regulation itself and due diligence processes more broadly are about, and
          crucially on whether local actors were engaged in putting these into practice.

Supported by:

2. Finding ways for the Regulation to leverage the action that matters at the
          local level. She stated that the advent of the Regulation could create momentum
          towards more responsible and productive mining practices. Alongside, it could
          also trigger action and mobilize resources towards other issues that were
          important to mining communities, for example women’s empowerment,
          environmental safeguarding and wider local economic development.

       3. Ensuring that the process is inclusive, fair and all actors play their part. Ms
          Flores asserted that it is essential that the costs, direct and indirect, brought about
          by the implementation of the Regulation are borne fairly by all players across the
          supply chain.

Ms Flores’s contribution was supported by video contributions from Isabel Blandón from
Fundación Atabaque, Colombia, Nouhoum Keita, ASFA 21, Mali, and Lynn Gitu from IMPACT,
Uganda.

PANEL: WHAT IS THE IMPACT OF THE EU CMR ON UPSTREAM ACTORS?

Following the opening remarks by high-level representative of producing country
governments, this plenary panel discussed the impact of the EU Conflict Minerals Regulation
on upstream actors.

MODERATOR:
       ·   Hannah Koep-Andrieu, Manager, Responsible Mineral Supply Chains and
           Alignment Practice, OECD Centre for Responsible Business Conduct

PANELLISTS:
       ·   Olena Wiaderna, Board Member, LuNa Smelter Ltd.
       ·   John Kanyoni, Vice President of the Chamber of Mines of the Federation of
           Congolese Businesses, Managing Director at Metachem Sarl and Managing
           Director at Tembo Power DRC
       ·   Dr Rachel Perks, Mining Specialist, Extractive Industries Practice, World Bank
       ·   Sasha Lezhnev, Deputy Director of Policy, The Sentry

THE PANELLISTS MADE FOLLOWING RECOMMENDATIONS:
       ·   Need for permanent EU bilateral dialogue and collaboration with producing
           country governments & regional organizations (incl. ICGLR)
       ·   Importance of proactively identifying and tackling illicit trade flows
       ·   Call on the EU to use political and commercial weight to encourage tax
           harmonization at the regional level between ICGLR member states

Supported by:

·   Importance of building capacity of upstream actors and access to finance to
           reduce dependence on smuggling
       ·   Need to foster formalization of ASM and strengthening local forums for
           sustainable development of ASM communities
       ·   Need to increase local capacity in due diligence processes and foster connections
           with downstream actors to increase traceability and shared responsibility
       ·   Need for consistent market understanding of companies falling under the EU
           Conflict Minerals Regulation and downstream commitment to source only from
           companies that pass third-party audits

BREAK-OUT SESSION 1: CAN DUE DILIGENCE SUPPORT GOOD EXTRACTIVE
GOVERNANCE IN PRODUCING COUNTRIES?

HOSTS:

       ·   Alec Crawford, Senior Policy Advisor and Lead on Environment, Conflict and
           Peacebuilding, Intergovernmental Forum on Mining, Minerals, Metals and
           Sustainable Development (IGF)
       ·   Lisa Zschunke, Advisor Mineral Resource Governance, GIZ, ICGLR/Rwanda

DISCUSSANTS:

       ·   Gerard Nayuburundi (ICGLR) - Regional coordinator and due diligence expert at
           the Natural Resources Unit ICGLR
       ·   Erica Westenberg (NRGI) – Extractive governance expert with expertise in the
           nexus of new technologies, such as blockchain, and governance
       ·   Gabriela Flores Zavala (IIED) – Senior Associate and member of CSO Pillar of the
           European Partnership for Responsible Minerals (EPRM)

Participants: 170

This break-out session explored how due diligence and producer country efforts for good
extractive governance are interconnected. Do they support or undermine each other? The
discussion was enriched by live contributions and questions from producing country
governments, importing country governments, private sector representatives and sector
experts.

Supported by:

PARTICIPANTS RECOMMENDED THAT:

   1. All actors critically analyse proposed blockchain or other technological due diligence
      solutions for their potential risks and benefits to good extractive governance

   2. Share financial burdens along supply chains in an equitable way, particularly for
      upstream actors and producers

   3. All actors work to strengthen the role of civil society to ensure that due diligence can
      contribute towards good extractive governance

   4. Provide increased support for and focus on industry operating in CAHRAs to ensure
      success and scalability of due diligence tools, systems and processes

   5. Ensure alignment between domestic and international regulations, standards and
      certifications to reduce confusion and increase effectiveness.

BREAK-OUT SESSION 2: IMPACT OF EU CONFLICT MINERALS REGULATION ON
ARTISANAL MINERS

HOST:

        ·   Boukje Theeuwes, Head of Policy Influencing, Solidaridad Europe

DISCUSSANTS:
        ·   Yves Bertran, Executive Director, Alliance for Responsible Mining ARM Europe
        ·   Lotte Hoex, Researcher, International Peace Information Services IPIS
        ·   Roper Cleland, Program manager ITSCI// pre-recorded video message

Participants: 102

This interactive break-out session explored the impact of the EU Conflict Minerals Regulation
on artisanal miners in producing countries – economic, environmental, social, health and
safety, and other. The discussion was enriched with input and questions from CSOs,
companies, governmental organizations and ministries.

PARTICIPANTS RECOMMENDED:

   1. Companies in Europe should not abstain from sourcing ASM from CAHRA’s

   2. Need to work in partnerships

   3. System to share costs along the supply chain

Supported by:

4. Start monitoring of the impact of the implementation on the ground: role for local
      CSOs in monitoring

   5. Lack of knowledge, need to raise awareness

   6. Involving governments and local actors of producing countries from the beginning on

   7. Tools to enforce, capacity to strengthen enforcement

BREAK-OUT SESSION 3: DOES DUE DILIGENCE VIOLATE OR UNDERMINE THE
HUMAN RIGHTS OF VULNERABLE GROUPS?

HOST:

        ·   Dr Fabiana Di Lorenzo, Responsible Sourcing Senior Manager, Levin Sources

DISCUSSANTS:

        ·   Dr Cristina Duranti – Director of Good Shepherd International Foundation, key
            partner of Bon Pasteur Kolwezi
        ·   Alice Vanni – Compliance and Sustainability Officer, Italpreziosi SPA
        ·   Sebastien Pennes – Artisanal Mining Specialist
        ·   Norman Mukwakwami – artisanal mining and due diligence specialist,
            Zimbabwe
        ·   Jennifer Hinton – Advisor to Women’s Rights and Mining - Head, ESG and Uganda
            Country Head, Jervois Mining Ltd.

Participants: 91

This session explored if and how human rights due diligence, if not implemented properly,
can violate or undermine the human rights of vulnerable groups and what can be done to
mitigate this. Discussions initially revolved around the question of whether the Regulation
and its impacts are known at all by ASM miners. In addition, it was discussed whether the
Regulation has “blind-spots”? For example, gender-blind spots. Moreover, the question was
raised how vulnerable groups can be detected and included along the entire supply chain?
Following that, the panellists’ contributions revolved around what might have gone wrong
in the past and how we can do better this time. What can be done better from a business and
civil society perspective? What do companies and civil society see as the biggest challenge in
implementing due diligence?

The overall conclusion was that not the “instrument” of due diligence violates or undermines
human rights, but the way of implementation might.

Supported by:

The discussion was enriched by live contributions and questions from importing country
governments, private sector representatives and sector experts.

PARTICIPANTS RECOMMENDED:

   1. Information and support are crucial! Invest in information in a wider way. African
      policy makers, miners and civil society do not know about the EU Regulation, create
      wide platforms, bring positive examples, connect with ASM representatives, local
      producers etc.

   2. Create a new normal! African policy makers should take the EU Regulation as an
      opportunity to think more deeply about reasonable entry points in legislation to be
      stronger and specific on gender and human rights

   3. Create safe spaces for dialogue. There is the importance of bringing this discussion
      beyond the corporate sector. Companies should join Multi-Stakeholder platforms.

   4. Detect vulnerable groups along the supply chains.

   5. Inform Upstream stakeholders about the irregulation as they are not aware on it
      and invest in capacity building.

BREAK-OUT SESSION 4: IMPACT OF THE EU CONFLICT MINERAL REGULATION ON
ILLICIT TRADE

HOST:

        ·   Louis Maréchal, Sector Lead Minerals & Extractives, OECD represented by
        ·   Marcena Hunter, Senior Analyst, Global Initiative Against Transnational
            Organized Crime (GI TOC)

SPEAKERS:

        ·   Marcena Hunter – Senior Analyst, Global Initiative Against Transnational
            Organized Crime (GI TOC)
        ·   Joanne Lebert – Executive Director, IMPACT
        ·   Dr. David Soud – Head of Research & Analysis, I.R. Consilium
        ·   Michael Gibb – Natural resource wealth expert

VIRTUAL CONTRIBUTIONS FROM PRODUCING COUNTRIES:

        ·   Désiré Nikiema, National Coordinator, Alliance for Responsible Mining Burkina
            Faso

Supported by:

·   Me Benjamin Bisimwa Cibaye, Advocate and Civil Society Delegate to the
           Provincial Monitoring Committee on Mining in Sud-Kivu
       ·   Natalia Uribe, Head of Standards and Certification, Alliance for Responsible
           Mining Colombia

Participants: 83

This break-out session explored possible effects of the EU Conflict Minerals Regulation on
the financial and transport flows of artisanal gold into the EU, focusing on two key conflict-
affected and high-risk regions, namely Central Africa and Latin America. International
experts and stakeholders from producer countries discussed challenges to implement the
EU Regulation on the ground.

Two specific risks connected to mitigating illicit financial flows were emphasized during the
session and need to be considered when implementing the EU Regulation. The first risk is
the relatively high threshold for gold established by the EU Regulation. There are good
reasons to suspect that many of the highest-risk imports into the EU are transacted in
relatively low quantities, some of which may fall below the thresholds. The second risk is the
potential rerouting of gold smuggling, especially in Latin America. Minerals are then
channelled through other countries that are not covered by the EU Regulation.

RECOMMENDATIONS TO EU INSTITUTIONS & IMPORTING COUNTRIES:

   1. The EU Regulation should not lead to de-risking or blanket bans by importers. To
      assure this, ASM producers need support (political, economic and technical) to
      comply and maintain market access:

           ·    Technical support for progressive improvement among producers lest they
                turn to less demanding importers and further fuel illicit trade

           ·    Facilitating access to finance to free producers from dependence on predatory
                smugglers

           ·    Tailored risk assessments to avoid excluding informal sector and exposing it
                to additional harm

           ·    Emphasize risk mitigation in the application of EU Regulation so that abuses
                are addressed instead of hidden

   2. Enhance international law enforcement cooperation including customs, financial
      intelligence units (FIU) and police

Supported by:

3. Strengthen checks at EU points of entry and at trading hubs to close loopholes

           ·    Illicit trade should come at a higher cost than formal trade

           ·    National competent authorities (NCAs) in the EU should be adequately staffed,
                funded, and trained

           ·    Need for more direct engagement with source countries to bring more
                transparency to supply chain and engage responsibly with ASM (Scrap gold is
                one example of how origins and links to abuses may be obscured)

   4. Dynamic approach to due diligence: constant vigilance, including vertically integrated
      structures, and quality data to monitor impact of volume threshold

RECOMMENDATION TO PRODUCER COUNTRIES:

   1. Governments to adopt appropriate measures to incentivize due diligence in domestic
      gold supply chains

CONCLUDING PANEL: WHAT ARE THE CHALLENGES AND OPPORTUNITIES AHEAD
ON THE JOURNEY TOWARDS IMPLEMENTING THE EU CONFLICT MINERALS
REGULATION?

This panel session was aimed at passing on the outcome recommendations from the
conference onto the senior EU policymakers and policy experts responsible for or advising
on the implementation of the EU Conflict Minerals Regulation.

The representatives of different EU institutions welcomed the wealth of ideas and
recommendations generated by the two days of discussions and committed to considering
these in their ongoing implementation of the Regulation and future revision.

The panellists agreed that the Regulation aims at a stronger engagement with producing
countries in improving production standards and safeguards in the 3TG sector, rather than
incentivizing companies to withdraw from CAHRAs. For maximum impact the EU Regulation
should be aligned with both sectoral and cross-sectoral initiatives of due diligence and
strengthened through partnerships. The issue of traceability, the need for monitoring the
implementation and the upcoming review process in 2023 were also discussed among other
topics. In line with a recommendation for the participants, there was also agreement on the
panel in referring to the Regulation as the Responsible Minerals Regulation (RMR) rather
than the Conflict Minerals Regulation (CMR).

Supported by:

MODERATOR:

   ·   Bart Devos, European Director, Responsible Business Alliance

SPEAKERS:

   ·   MEP Bernd Lange, Chairman of the International Trade Committee, European
       Parliament
   ·   MEP Iuliu Winkler, Rapporteur on the EU Conflict Minerals Regulation and Vice-
       Chairman of the International Trade Committee, European Parliament
   ·   Tyler Gillard, Head of Due Diligence, OECD Responsible Business Conduct Unit
   ·   Madelaine Tuininga, Head of Unit, European Commission, DG TRADE - Unit C.4
       Multilateral Trade and Sustainable Development Policy, Green Deal, Conflict Minerals
   ·   Guus Houttuin, Senior Advisor Trade, European External Action Services (EAAS)
   ·   Cécile Billaux, Head of Unit, European Commission, DG DEVCO - Unit C.4 Private
       Sector & Trade

Supported by:

OUTCOME RECOMMENDATIONS*

                     To Importing Country Governments

•   Support to producer countries in establishing good extractive governance by importing
    countries, EU and CSOs
•   Support civil society in producing countries to be active players in due diligence
•   Focus on supporting responsible ASM of gold
•   Stand with EU to address illicit trade issues, trading hubs, etc.
•   Fund, staff and train competent national authorities (CNAs) in the EU

                     To Producer Country Governments

•   Formalize ASM - with policy focus on inclusion and poverty reduction
•   Reduce red tape on land ownership for ASM
•   Invest in community development
•   Ensure alignment between domestic and international regulations, standards and
    certifications to reduce confusion and increase effectiveness
•   Use EU CMR as an opportunity to mainstream human rights and gender into national
    legislation
•   Reduce tax incentives for smuggling
•   Transit countries: discontinue exporting illicitly mined resources
•   Adopt appropriate measures to incentivise due diligence in domestic gold supply chains

* This set of recommendations is a consolidated list of feedback provided by participants during the
event; it may not be comprehensive of all views and perspectives.

     Supported by:

To EU Institutions
          ·

•   Follow through on EU CMR with robust diplomacy and teeth
•   Don't stop here! The EU CMR is a great first step, but the work is not done yet: environment,
    inclusive local development, etc.
•   Develop tools to support enforcement of the EU CMR
•   Application of EU CMR should emphasize risk mitigation so that abuses are addressed
    instead of hidden
•   Review focus of companies affected by EU CMR
•   Generate quality data to monitor impact of volume threshold
•   Disclose list of companies falling under the EU CMR to enable civil society to raise
    substantiated concerns
•   Build M&E frameworks and monitor KPIs that would allow us to better understand if illicit
    trade into EU is effectively curbed
•   Close loopholes and implement serious consequences for companies that continue to deal in
    conflict minerals
•   Implement measures against illicit imports of 3TG into the EU through transit countries
•   CAHRAs list: take smuggling countries into account
•   Create a consultative mechanism for CSOs to contribute to the list of CAHRAs
•   Work on trading hubs (Dubai, Switzerland, China)
•   Strengthen checks at EU points of entry and at trading hubs to close loopholes - illicit trade
    should come at a higher cost than formal trade!
•   Monitor evolving risks of negative impacts on small-scale miners, such as de facto embargos
•   Tailored risk assessments to avoid excluding informal sector and exposing it to additional
    harm
•   Support ASM producers (political, economic and technical) to comply and maintain market
    access: Technical support for progressive improvement among producers lest they turn to
    less demanding importers and further fuel illicit trade – and facilitating access to finance to
    free producers from dependence on predatory smugglers
•   Support regional certification schemes, such as ICGLR
•   Use political and commercial weight to encourage regional tax harmonisation, for example in
    ICGLR member states, to disincentivize smuggling that undermines the EU CMR
•   Permanent dialogue between Great Lakes Region/ producing country leaders and EU (bi- and
    multilateral dialogue)
•   Tripartite linkages with DRC government - that support industrialization
•   Enhanced international law enforcement cooperation including customs, FIUs and police
      Supported by:

To Private Sector

•   Expand scope of efforts to relevant issues beyond conflict (e.g. child labour)
•   Share financial burdens along supply chains in an equitable way (including cost
    transparency)
•   Close pipe systems to enable market access for ASM
•   Risk Management: Stop sourcing from smelters and refiners that fail third-party audits
•   Downstream companies: Engage with the upstream to provide capacity-building support
    (traders/exporters/miners)
•   Technical support for progressive improvement among producers lest they turn to less
    demanding importers and further fuel illicit trade (gold)
•   Facilitate access to finance to free producers from dependence on predatory smugglers
    (gold)
•   Dynamic approach to due diligence: constant vigilance, including of vertically integrated
    structures, and quality data to monitor impact of volume threshold

                                  To Civil Society

•   Go beyond “conflict” and work on socio-economic, environmental, health and safety issues
•   Scale up monitoring and evaluation of EU CMR and beyond, work with data
•   Raise awareness about the EU CMR and due diligence
•   Foster connections with downstream actors to increase traceability and shared
    responsibility
•   Enable south-south knowledge sharing
•   Strengthen local forums for sustainable development in ASM communities
•   Encourage CSOs to play an active role in due diligence
•   Keep up the pressure

     Supported by:

C
                                   Collective action
                        To Multi-Stakeholder                  Initiatives
                                   Collective action
•       Building awareness on due diligence on the local level, especially beyond the Great Lakes
        Region, and beyond smeltersCollective         action
                                    by the EU, CSOs, producer    country governments
•       Incorporate ILO Decent Work Agenda, especially health and safety components, into
        upstream work
•       Identify best practices from industry operating in CAHRAs to promote scaling of due
        diligence tools, systems and processes

                                      Collective Action

    •    Speak about responsible sourcing instead of conflict minerals
    •    Get rid of silos: cooperate & partner across organizations
    •    Conversation should include ASM/LSM interface
    •    Identify and protect vulnerable groups along the supply chains
    •    Critically analyse proposed blockchain or other technological due diligence solutions for
         their potential risks and benefits to good extractive governance, using frameworks such
         as NRGI’s GENESIS
    •    Develop tools to support enforcement of the EU CMR and capacity-building to strengthen
         enforcement in producer countries by multi-stakeholder initiatives, civil society, private
         sector, etc.
    •    Look beyond Central Africa

         Supported by: