1. The Federation invested in a women-owned chocolate-making company based in Kenya. This company was sourcing cocoa beans, with claims of Ugandan origin, from a supplier based in Kampala, Uganda. After further investigation, it appeared these beans were coming from the Democratic Republic of Congo. This supplier was not able to provide any documentation to reaffirm Ugandan origin nor proof of legal export from the DRC, therefore, all contracts were immediately terminated with this supplier.


      1. No incidences to report


      1. No incidences to report


      1. No incidences to report

     ASM Gold

      1. No ASM gold was sourced during this fiscal year



Month: August / Location: Beni, DRC

      1. Several shipments of cocoa beans from the Beni area were sacked by Allied Democratic Forces (ADF). While the Federation can do little to prevent armed groups from attacking goods in transit, it is making every effort to diversify its sourcing to regions outside of this armed group’s influence.


      1. No incidences to report


      1. No incidences to report


Month: Sept / Location: Goma, DRC

      1. While in transit across the border into Goma, a group of officials demanded payment, in cash, for the transit of goods. The payment was refused so the officials tried denying entry into the Democratic Republic of the Congo (DRC). The driver transiting the sugar simply parked the vehicle and removed the keys. After blocking traffic for several minutes, the officials gave up their attempts and released the vehicle without any payments.

     ASM Gold

Month: January / Location: Mambasa, DRC

      1. While transporting their cooperative beneficiary with gold in DFP1’s vehicle, their driver swerved to avoid oncoming traffic. While doing so, DFP1’s vehicle hit and killed a child, six years of age, while walking home from school. This accident was in no way the fault of the driver or DFP1, rather the fault of a bus attempting to illegally pass traffic in the opposing lane. However, DFP1 has failed to properly report this incident and failed to reply to multiple requests to see the issue resolved. Instead, DFP1 gave their driver $1,200 and instructions to handle the issue independently of the organization. As this was the Federation’s first engagement with DFP1, all attempts of DFP1 to engage in signing a partnership agreement have been denied by the Federation. As the cooperative beneficiary had nothing to do with this incident, other than being in the vehicle, the Federation has continued to work with and support their activities and purchase gold from them. It should also be noted that DFP1 violated local law by transporting gold in an NGO-registered vehicle.

Month: January / Location: Nyamurhale site

      1. The diggers exceed enormously the maximum depth allowed for pits (30 meters) established by the mining code.
      2. Presence of a pregnant woman at the washing station.
      3. A miner stole a bag of mineralized sand from the Eugle pit.
      4. There were two landslides in the Chokola pit. A miner was covered by the earth but he was saved by his colleagues. No one was injured.
      5. A miner stole a 40 kg bag of ore from the pit, it occurred in the evening when the miners were already out of the pits.
      6. 15 children under 16 years old wash the mineralized sand at the washing station.

Month: February / Location: Mambasa, DRC

      1. DFP1 received a phone call from a buying agent stating that one of his colleagues, also a buying agent, had been kidnapped. After alerting the police and SAEMAPE, who began an investigation, it was discovered that the alleged kidnapped victim had been “released” by his assailants to retrieve money from the other buying agent as ransom. As there was no evidence that the buying agent had been kidnapped after speaking with various neighbors and community members, the police looked into the buying agent’s personal life and discovered that he probably kidnapped himself to divert the buying money for personal reasons. All business was halted with the buying agent in question, and a new buying agent was hired; the police continue to investigate the situation.

Month: February / Location: Rusizi, Rwanda

      1. There were delays at the Rwandese borders where we had to call for backup from a stakeholder to ensure… It took almost 6 hrs to process paperwork raising security concerns around the material transport.

Month: March / Location: Nyamurhale, DRC

      1. A child, about 12 years old, who used to frequent the washing station was selling approximately 0.1 g of gold to a manager. This product was taken from the waste he had treated at the washing station. He sold the gold for 6000 Fc.
      2. Presence of children under 16 years old who were washing and sieving ore at the washing station. During this week (25 – 31 March 2018) about 15 children were present at the station every day, crushing and washing the minerals.

Month: April / Location: Nyamurhale, DRC

      1. About 25 children, all under the age of 16, were washing mineralized sand and crushing ore at the washing station.
      2. ITOA receipts were incorrectly completed by the SAEMAPE agent and mismatched from their tamper-proof bags.

Month: May / Location: Bukavu, DRC

      1. Approximately ten children, all under the age of 16 years, were not only present at the washing station but were seen washing and crushing the ore on a daily basis.
      2. While crossing the border from DRC into Rwanda, DRC security officials attempted to stop the transit of goods, claiming they needed to ‘inspect’ them first. The Federation employees refused to enter a private room with the security officials as they had no authority to their request. The Federation employee immediately called a UN partner program to ensure their safety and transparency. Two UN officials arrived shortly thereafter and were able to assist the Federation employees in avoiding what was clearly an attempt to extort money.
      3. Security Forces interrogation- Aggressively interrogated two Fair Congo employees including the managing director, while she was visibly pregnant. Both were forcibly brought into interrogation rooms located within the state security force’s local office, twice, each time they seized her passport and accused the managing director of insulting the president (Kabila). Demand for bribes later followed while increasing the levels of threats and accusations. Fair Congo team was able to call one of their civil society partners and a group of civil society members came and pulled both the managing director and program manager from the interrogation room. During the events, which took place over the course of a week, Fair Congo, as a partner, sent Donor1 a formal request for assistance which was not replied to. 

Month: May / Location: Kigali, Rwanda

      1. While transiting the same material shipment as noted above, a second incident happened upon goods clearance by Rwanda Revenue Authority (RRA) at the Kigali airport. After walking the Federation employee through the first security screening checkpoint, the RRA official seemed to whisper something to a Rwandan National Police (RNP) officer. That same RNP officer later stopped the Federation staff member and demanded to see the transit documentation accompanying the material shipment. Even after reviewing the International Conference on the Great Lakes Region (ICGLR) certificate which documented the material origin from the DRC, the RNP officer demanded to see the “other documentation” which he later stated was the Rwandan Certificate of Origin. After showing all the legal paperwork from the DRC the RNP officer stated the Federation employee still needed to claim the material’s origin from Rwanda. The Federation employee refused to falsify this documentation and immediately called the US Embassy for assistance. RNP later confronted the Federation employee, after covering their name tags, stating he should not have called the embassy, he was not being officially detained but he also wasn’t free to leave. The Federation employee remained in the airport overnight and later discussed the issue with the chief of police the next morning who stated, “it was just a misunderstanding” and that all future shipments should go through him to avoid future confusion of his officers. Shipments no longer transit through this border crossing or the Kigali International Airport.

Month: June / Location: Mambasa, DRC

      1. A member of the Armed Forces of the DRC (FARDC) demanded that CODEMA pay an illegal fee (USD 10.00) during travel on the Mambasa-Bunia route. CODEMA and DFP1 notified the Comité Provincial de Suivi about this illegal payment in July 2018.
      2. A miner from a non-validated site entered the Kafiawema site at which point he attempted to sell 1.86 grams of hard rock gold to the buying agent. Upon inspection, the buying agent noticed that it was in fact a piece of iron weighing 1.2 grams which was covered by a thin layer of gold weighing 0.84 grams.

Month: July / Location: Mambasa, DRC

      1. One buying agent requested to temporarily use the backpack of a miner. Inside this backpack was a small package of gold the miner had collected. When the backpack was returned to the miner, the package of gold had gone missing. The action taken to rectify this situation is to provide the buying agents with backpacks that can be used as well as verification that the backpacks are in good working order. The incident was reported to the security team on the mine site.

Month: July / Location: Kampene, DRC

      1. A landslide occurred in the Nyoso ya maboko ya nzambe pit from 19th to 27th July 2018. This pit was closed for a week and all activities were suspended following the clandestine sale of the gold that had been extracted while the pit was closed. After the suspension of activities, the miners had to do maintenance work through woodworking and tunneling.

Month: August / Location: Goma, DRC

      1. While transiting the mineral from Goma airport, the state tax authorities attempted to extort payments from the transporter, claiming that there were missing documents that were required to export the material. Fortunately, the transporter was escorted by two mining state agents who were able to handle the situation and ensure the security of the transporter and materials until the transporter left the country.

Month: August / Location: Chicago, USA

      1. While in transit from Chicago to Grand Rapids with the material, TSA (Transportation Security Administration) required the traceability bag be cut open so they could see the contents of the bag. Thankfully, the transporter had other tempered evidence bags with him and was able to take a video of the opening and the resealing of an additional bag.

Month: September / Location: Mambasa, DRC

      1. A miner also occupying the position of Director-General of the site administration was found to be tampering with the manual scales used in the purchasing of gold from his mining team. This miner was arrested and fined for the infraction. In response, SAEMAPE’s Chef de Service has conducted retraining on traceability standards.

Month: October / Location: Mambasa, DRC

      1. Two men from the FARDC arrived at the Tokomeka mine site and attempted to extract payments to guarantee safety. These men were informed that they were at a conflict-free mine site that did not require their services. These men then stated that they would require payment on their next visit and proceeded to leave. The two men in question have not been reported to have returned to the mine site. The manager of the CODEMA cooperative was in the process of arranging a meeting with the Administrator of Mambasa Territory to address the issue.

Month: October / Location: Walungu, DRC

      1. Although no longer sourcing from the Nyamurhale site, it was reported by DFP2 to have children present at the mining site. After further inquiry, DFP2 determined that the COMIANGWE cooperative had been approached by another DFP3 focusing on schooling children. The cooperative leader instructed her members to “bring their kids to work” so that the DFP3 could pay for their school fees. No further engagement of this cooperative is to take place until such time its leadership is replaced, though due larger to other considerations.

Month: October – November / Location: Mambasa, DRC

      1. For reasons unknown, recording of traceability data from DFP1 temporarily ceased (fault). As there was gold pre-financed by the Federation to the cooperative beneficiary, the Federation demanded that all gold be delivered to it in due order. DFP1 then facilitated a sale, 564 grams, to a known illicit actor with a history of money laundering and smuggling. This fault in recording was confirmed by the 3rd party private enterprise recording all traceability data offshore, described in their words as a complete data ‘blackout’. The Federation suspects this sale to an illicit actor was an attempt to conceal failures of DFP1s system. Since this incident, the Federation has enacted a companywide policy to implement its own traceability and due diligence measures with all cooperative partners to prevent any future lapses in data management. Direct engagement of DFP1 has been kept at a minimum in anticipation of the program’s closeout.



Month: x / Location: Beni, DRC

      1. Several shipments of cocoa beans from the Beni area were sacked by Allied Democratic Forces (ADF). While the Federation can do little to prevent armed groups from attacking goods in transit, it is making every effort to diversify its sourcing to regions outside of this armed groups’ influence.

     ASM Gold

Month: January / Location: Bukavu, DRC

      1. After returning from a field mission working on ASM gold, the Fair Congo program manager was hospitalized for two weeks showing symptoms of poisoning. The precise means or motive could not be determined, however, after receiving two weeks of treatment the program manager made a full recovery.

Month: February / Location: Goma, DRC

      1. While transiting material through the local airport, for export, state tax authorities attempted to extort payments from the transporter, claiming that there were missing documents that were required to have in order to export the material. Fortunately, the transporter was escorted by two state mining agents who were able to handle the situation and ensure the security of the transporter and materials until the transporter left the country.
      2. State security forces began visiting Fair Congo offices more frequently, this time stating they were “unhappy with the current engagement with them”. This was perceived as a demand for illegal payments.

Month: March / Location: Bunia, DRC

      1. While transporting material from Bunia to Bukavu, the transporter was pulled off the plane that was about to take off, by the state security forces and other state agents claiming that the transporter did not have the appropriate documents to legally transport the material exposing the shipment to additional risk of theft. The transporter went through a series of interrogations, attempted extortion, and intimidation. The transporter was finally let go after contacting mining state agents who were able to provide supporting evidence that the transporter had all the legal documents required to transport the materials.

Month: April / Location: Bukavu, DRC

      1. After receiving approvals from a downstream buyer, Fair Congo started processing export documents for material from CODEMA that had been recently transferred from Bunia to Bukavu. While processing the documents, the downstream buyer sent an email canceling the purchase of the material due to reasons unrelated to Fair Congo, rather DFP1.

Month: June / Location: Bukavu, DRC

      1. Export was postponed for completion of the supply contract due to lack of consensus among downstream partners, there was no reciprocity in communication.

Month: July / Location: Bukavu, DRC

      1. The Central Bank of Congo sent a PV requesting to pay fees to renew the immatriculation number of the company and an additional fee to cover the cost of control, which was an illegal payment. The immatriculation number fees are a one-off payment made when applying for a new mining license. Request for paying renewal fees for the immatriculation number has never been approved by the national government.

Month: August / Location: Bukavu, DRC

      1. After filing our annual tax returns, several DGI agents decided to review our annual financial reports and reported they discovered some “discrepancies”. From then onwards, we received a variety of notices from the DGI office listing a plethora of fines and taxes claimed to be due. One of these was VAT on all our gold exports, which was to be 16% on each export since the beginning of our operations.
      2. Meeting with downstream to get final confirmation, reciprocity was confirmed and export scheduled for October 2019

Month: October / Location: United States

      1. United States Customs and Border Patrol (USCBP) implemented a new Withhold Release Order (WRO) blocking all shipments of ASM gold from the Democratic Republic of the Congo. All shipments were halted during this period. An exemption to this WRO was issued formally to Chambers Federation by USCBP in June 2020.

Link to the related press release: https://www.cbp.gov/newsroom/national-media-release/cbp-modifies-withhold-release-order-gold-imports-democratic-republic

Month: October / Location: Kampene, DRC

      1. After heavy rainfall, a cooperative partner mine site collapsed killing 21 people and seriously injuring 10. Despite being falsely reported by several news outlets, this mine site has been validated since 2016 and is part of the Bundesanstalt für Geowissenschaften und Rohstoffe (BGR) [German Federal Institute for Geosciences and Natural Resources] program. It is believed that the cooperative pit manager overseeing this portion of the open pit site was not ensuring that ore was completely removed. This additional weight on the sides of the pit, combined with heavy rains caused the pit to collapse in on itself. There were no children or pregnant women among the victims of this accident.
      2. This site is managed by the COMILU cooperative which has been in existence since the year 2000. While the Federation has not recently sourced from this site, it has several times in early 2019 and late 2018. This site had been marked for reinspection before any sourcing could be reinitiated. Additional training will be provided to the cooperative, along with support from partner Donor Funded Program (DFP), to reinforce mine site safety protocols.

Month: October / Location: Bukavu, DRC

      1. The Central Bank of Congo withdrew funds from the account of Trust Merchant Bank (TMB) to cater for the renewal of the immatriculation number and fines which Fair Congo was advised, by the Ministry of Mines, Fair Congo’s legal council, and TMB’s own legal department, to be illegal taxes and not to be paid. TMB then issued an unauthorized overdraft loan to cover the remaining debt from the Central Bank without disclosing it to Fair Congo. This loan had an effective APR of 50%. This interest bearing overdraft loan continued to gain interest for a year before TMB disclosed it to Fair Congo. While collection attempts by TMB continued, their main office legal department stated they issued “millions of dollars” a year in such loans to cover illegal taxation aimed at other private companies but would do what they can to help fight this illegal tax. It should be noted that these overdraft loans are issued well above the cost of issuance and are generating profit for the banking industry. This mechanism forces private companies in the DRC to pay illegal taxes. Failure to pay these illegal taxes can also lead to a complete ban by the Central Bank for company directors, meaning they can no longer operate in country unless they comply. 

Month: November / Location: Bukavu, DRC

      1. DGI contacted both the managing director and the program manager of Fair Congo multiple times to discuss “discrepancies” they found in the files and fines that would apply to that effect. Despite discussing with the state tax agents about those discrepancies, which were illegal, Fair Congo still received a notice. The total in the fine that would be owed to the DGI would be comparable to Fair Congo’s total 2018 revenue. The agency also stated in the notice that they intended to seize Fair Congo’s assets if the fines were not paid in full.
      2. Fair Congo received communication from local civil society members that there were concerns over the targeting of Fair Congo operations due to influence from a local illicit actor by the use of state security forces and state tax offices. The civil society also stated that the Chief of Party (COP) of a newly Donor1-funded program, was affiliated with this actor demonstrating a clear conflict of interest.
      3. Fair Congo sent an email to Donor1 about DFP4 stating that we were aware of their engagements with illicit actors and requested a formal meeting. We believe the Chief of Party of the Donor1-funded program discussed our allegations against her with her illicit actor friend who then in turn ramped up his efforts to harass Fair Congo through his accomplices in the local state security service putting Fair Congo staff at risk. DFP4 program staff confirmed that they were in communication with the illicit actor that we had been warned about. They further confirmed, during a conference call, that the COP was “a personal friend” of this illicit actor. Donor1 did not provide an appropriate response to our formal complaint, and to date, we do not know about any investigation completed of this conflict of interest. We provided copies of reports of misconduct within Donor1 program, as well as the direct corruption we were facing due to that corruption, and as well as the threats to our staff. US Department of State, through the local embassy, provided Fair Congo further details on the illicit actor and expressed their lack of surprise regarding the COP involved. USDoS further warned Fair Congo of the illicit actors connections to the Allied Democratic Forces (ADF) a known terrorist group, and their suspicion of several assassinations that they believed he had arranged targeting local civil society actors.

Month: December – June 2020 Location:

      1. Retaliation against whistleblower

Donor1 and their implementing partner attempted to facilitate support for two known illicit actors, including one accused previously of money laundering and misuse of state funds and whose financing came from someone in the UN sanctions list.



Month: April – September / Location: Beni, DRC

      1. New taxes, blocked exports

April: September / Location: Beni, DRC

      1. New taxes, blocked exports

     ASM Gold

Month: September / Location: Bukavu, DRC

      1. After the lifting of quarantine, the Fair Congo managing director visited the state tax service office to formally address several attempts of illegal taxation.
      2. After the lifting of quarantine, the Fair Congo managing director visited central bank offices to formally address their illegal taxation and seizure of funds from Fair Congo accounts. Three visits were made in total.
      3. After the lifting of quarantine, the Fair Congo managing director visited the state mining service offices to process a provincial transfer of gold, with a value in excess of $200,000, kept in Bukavu, to the neighboring province. While leaving one of the state mining service offices, she was picked up by three armed assailants and forced into a nearby car. She was taken to a construction site where a fourth assailant showed up and tortured her for approximately two to four hours. The subject’s bag was taken immediately once she was forced into the car. It is unknown when the assailants discovered and removed any contents of the bag, including the gold shipment she was carrying. She was left at the site by the assailants though was able to contact her driver who took her to Panzi Hospital for treatment. She suffered permanent mental and physical damage which are detailed in a medical report, police report, pictures, and video among other evidence gathered. The whereabouts of the contents of her bag are unknown and assumed stolen. One of the assailants, the leader of the group, is known to the managing director as the same state security officer that led her interrogation, while she was pregnant, in 2018. The hospital evacuated her from the province where she was placed under armed protection as she recovered, listed as a protected person by the United Nations Joint Humans Rights Office (UNJHRO). Upon her partial recovery, she, and her family, were evacuated from the country. Upon advisement of critical stakeholders, public reporting of this incident was withheld until the evacuation was complete. Stakeholders informed and/or assisting with this incident and its aftermath include, though are not limited to: The United States Ambassador to the DRC; United States Department of State; USDoS International Narcotics and Law Enforcement Bureau; United Nations Joint Human Rights Office; United Nations Organization Stabilization Mission in the Democratic Republic of the Congo; United Nations Group of Experts; Panzi Hospital; APLC Office of the President (DRC).

Month: October / Location: Goma, DRC

      1. CF sent a notice to downstream

Month: November / Location: Goma, DRC

      1. Grant offered, ignored

Month: December / Location: Bukavu, DRC

      1. TMB sent an email showing the cumulative amount that FC owes after the bank issued an unauthorized overdraft loan to cover the debt from the Central Bank without disclosing to Fair Congo with an effective APR of 50%.



Month: April -? / Location: Beni, DRC

      1. At the beginning of the COVID-19 pandemic, a disagreement between two government agencies resulted in both agencies charging for the same tax which led to the blockage of all agricultural exports from the country for nearly six months.

Month: April -? / Location: Beni, DRC

      1. At the beginning of the COVID-19 pandemic, a disagreement between two government agencies resulted in both agencies charging for the same tax which led to the blockage of all agricultural exports from the country for nearly six months.

Month: April -? / Location: Beni, DRC

      1. At the beginning of the COVID-19 pandemic, a disagreement between two government agencies resulted in both agencies charging for the same tax which led to the blockage of all agricultural exports from the country for nearly six months.

     ASM Gold

Month: March / Location: Bukavu, DRC

      1. CEEC director threat


DFP = Donor Funded Program

Donor = Generally a government development organization

Donors and DFPs are anonymized though available by formal request by the appropriate stakeholders. Specific identifiers have been assigned to each entity such DFP1 or Donor2.