Responsible Sourcing Guidelines: A Call for Small-Scale Miners to Act


12 July 2023

Compiled by Nobuhle T Chikuni

 The Organization for Economic Co-operation and Development (OECD) has developed guidelines known as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. These guidelines aim to ensure that minerals are sourced responsibly, without funding conflict, human rights abuses, or environmental damage. The application of OECD guidelines depends on the specific context and the engagement of relevant stakeholders. While the OECD guidelines on responsible sourcing of minerals are not region-specific, they can be applied to any area where mineral extraction takes place, for example, the Great Lakes region. The Great Lakes region, particularly countries like the Democratic Republic of the Congo (DRC), has been associated with conflict minerals, including tin, tantalum, tungsten, and gold. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas provides recommendations for companies to exercise due diligence to mitigate the risk of sourcing minerals that finance armed conflict. Implementing these guidelines can help address the issue of conflict minerals in the region.

There is a need for small-scale miners to implement the responsible sourcing guidelines although there are various issues that have been raised as an impediment due to the unregulated nature of these miners, including:

-Lack of Awareness: Small-scale miners may not be aware of the existence or importance of responsible sourcing guidelines. They might have limited access to information and resources compared to larger mining companies.

-Limited Capacities: Small-scale miners often have limited technical and financial capacities to implement complex due diligence processes. Compliance with responsible sourcing guidelines may require additional resources, such as training, expertise, and documentation systems.

-Informal and Fragmented Structure: Small-scale mining operations are often informal and fragmented, making it difficult to track the origin of minerals and ensure responsible practices throughout the supply chain. The lack of formalization can hinder the implementation of due diligence measures.

-Access to Markets: Small-scale miners may face challenges in accessing responsible markets that require compliance with sourcing standards. Limited market options and pricing pressures can discourage them from investing in responsible practices.

Despite these challenges, there are initiatives aimed at supporting small-scale miners in adopting responsible sourcing practices. From 2019 to 2021, ZELA received financial support from the European Partnership for Responsible Minerals (EPRM) to pilot a project in Zimbabwe. The goal of the project was to promote safe, sustainable, traceable, responsible, and profitable gold by working with the Mthandazo women miners in Gwanda. During the implementation period, ZELA was able to host several capacity-building sessions. The sessions included capacity building on the laws that govern the gold sector, the OECD guidelines, UNGPs, safe mining practices, procurement of equipment, conducting 3rd party due diligence, and the development of a responsible sourcing policy. We convened several engagement forums with the Fidelity Printer Refinery and other mining stakeholders during the Zimbabwe Alternative Mining Indaba (ZAMI), the annual ASM academy, and other stakeholder engagement forums. While COVID-19 affected the implementation of the activities, both ZELA and Mthandazo were able to adapt to the changes. During the COVID period, the organisation worked with the women to ensure they provided COVID-19-appropriate personal protective Equipment (PPE) for their workers. Partnering with the Zimbabwe School of Mines (ZSM), the women were trained on the fundamentals of mining to increase their knowledge on mining. The members of the Mthandazo women were not immune to the machete gangs that caused havoc in late 2018 and early 2019. The women lost some workers to the violence, with many injured and a lot of property and money stolen. To reduce the risk, following the OECD guidelines, a security risk was identified, resulting in the engagement of security personnel and the organisation was able to develop traceability.

The pilot program with Mthandazo women is an indication that with proper support of the small-scale miners, responsible sourcing guidelines can be applied in the Zimbabwean context, especially for miners who are organized are willing to comply. With more financial support, the project can be replicated in other areas.

Given that mineral supply chains are often interconnected across borders, regional cooperation is important for the application of responsible sourcing guidelines.

  • Engaging a wide range of stakeholders is crucial for the effective application of the OECD guidelines in the gold sector. Meaningful engagement can foster transparency, build trust, and ensure the perspectives and concerns of all stakeholders are considered.
  • Establishing robust traceability systems is crucial for tracking the origin of gold and ensuring responsible sourcing.
  • Implementing traceability measures, such as certification schemes, secure transport and storage protocols, and transparent documentation systems, can help prevent the mixing of responsibly and irresponsibly sourced gold and provide assurance to downstream actors.

Lastly, ASM plays a significant role in the Zimbabwean gold sector. Formalizing the sector can help improve responsible sourcing practices by providing miners with legal recognition, access to finance, technical support, and market opportunities. Formalization should be accompanied by support for sustainable livelihoods, environmental management, and social safeguards.

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