As publicly traded OEMs work to ensure conflict mineral compliance, at the other end of the supply chain, delays in mine certification may harm the development of free minerals trade in Central Africa.
Regional governments are struggling to close the gaps in minerals certification processes in eastern Congo, Rwanda, and the surrounding region, according to a new Enough Project report titled “Coming Clean: A Proposal for Getting Conflict Minerals Certification Back on Track” that was released last month. Enough Project Field Consultant Aaron Hall said in a press statement:
Certification is the most critical component of the entire conflict-free minerals system. If minerals from the Great Lakes region cannot be certified as conflict-free, then efforts to trace and audit become moot. Without functioning regional audits or an Independent Mineral Chain Auditor, minerals cannot be credibly certified according to regional and international standards.
Today, certifications are being done on an ad hoc basis for easy to certify mines. Rwanda issued its first conflict-free certificate on November 6, and Congo plans to begin issuing certificates for mines and exporters soon, according to the Enough Project. In many instances, though, transparency and accountability remains lacking.
The ICGLR Regional Initiative against the Exploitation of Natural Resources (RINR) creates a regulatory framework for minerals certification. The ICGLR Certification Scheme is comprised of four main components:
- Mine inspections and traceability: Mines are assigned with a green, yellow, or red status depending on whether or not they are conflict free. Minerals are put in tracing systems (sometimes called bag and tag systems) for tracking from min to export.
- Information database: The regional database would support mineral tracking.
- Auditing: Mines are to be audited by independent third-party auditors that are overseen by a committee made up of electronics companies, regional states, and non-governmental organizations.
- Independent monitoring: An Independent Mineral Chain Auditor (IMCA) checks for smuggling and fraud and to sanction smugglers.
This seems like a reasonable system, but, to date, most of it hasn't been fully implemented. Today, 55 mines in the Great Lakes region of Africa are designated “green” and 500 mines have tracing systems in place. The actual details of the mineral certification, called the Regional Certification Mechanism (RCM), have not been completed and the structures around creating third-party audits and oversight of those audits haven't been finalized, according to the Enough Project report. Finally, the IMCA has not been assembled.
These realities leave electronics OEMs trying to clean up their supply chain in a tough spot. The report said:
To date, electronics and other companies have relied on the 'bag and tag' system, run by the tin and tantalum industries, to purchase minerals from Congo and the region. This system, implemented on a wide scale in Rwanda and in some parts of Congo, deserves praise for being a good first step, but the system remains opaque and it does not guarantee conflict-free minerals.
Clearly, there is much work to be done — and until it is completed, minerals from the region can't be officially confirmed or sold as conflict free. This is bad news for electronics manufacturers who want to buy from the region — and for those selling minerals in the region. Without reassurance, organizations may remove or severely limit purchases from the area.
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