Our Transparency

Public incident reporting is updated on an annual basis and covers all major sourcing activities related to investments into other companies (referenced as “we”, “our” or “investees”), usually woman-led startups, made by the Chambers Federation (Federation). While the Federation reports on supply chain incidents of other companies it is not liable for any such incidents.

Since 2017, the Federation has implemented a strict transparency rule for all its investees and their related supply chains. Every effort is made to implement and replicate the due diligence standards recommended by the OECD, among other organizations, across all sectors including but not limited to ASM gold, coffee and cocoa. Supply chain issues will happen but not acknowledging those errors increases the likelihood of them happening again

How information is collected:
Information is currently collected by a variety of sources including:

  • local civil society;
  • international donor-funded program partners;
  • cooperative suppliers;
  • internal compliance officers.

Our Approach to Responsible Sourcing[1]

We understand that due diligence is an ongoing process of engagement with all levels of the supply chain responsible for identifying, mitigating, and addressing any risks. While we typically fill the role of a mid and downstream actor we engage in direct trade with our producing partners, whether miners or farmers. We inspect each sourcing site located in high-risk areas in order to ensure proper due diligence is carried out, but also so that we can understand the impacts of our supply chains on the people involved, both directly and indirectly.  

Our Sources[2][3]

COCOA

SUGAR

COFFEE

VANILLA

ASM GOLD

DRC; North Kivu & Ituri provinces

Rwanda

DRC; North, South Kivu, & Ituri provinces

DRC; North Kivu & Ituri provinces

DRC; South Kivu, Maniema & Ituri provinces

Uganda

Kenya

Kenya

Uganda

Kenya

Tanzania

 

Uganda

   
   

Tanzania

   

 

Our Management Systems

    1. Conflict Minerals Policy: Please read this link.
    2. Organizational Policy and Procedure Manual: The Federation provides its investees a single manual to cover the following policies: child labor; environmental protection; hygiene; employee rights; public interest disclosures; anti-bribery; code of ethics; data and privacy protection; AML/CFT among others. This manual may be adapted by its subsidiaries, investees, others including but not limited to any unrelated companies, to contextualize specific local laws, depending on the jurisdiction. Copies of this manual are available by sending your request to admin@chambersfederation.com.
    3. Supply Chain Due Diligence: The Federation engages law enforcement, United Nations Group of Experts (UNGoE), and independent experts to engage in supplier due diligence and background checks. Any ‘red flags’ that come from these checks are reviewed on a case-by-case basis. Should any of these ‘red flags’ link to AML/CFT violations, a strict no engagement policy is enacted. 
    4. Supplier information: The Federation keeps a list of all active (and past) suppliers and keeps files for each supplier, including Know Your Customer (KYC) forms where applicable.
    5. Record keeping: The Federation collects and stores documentation related to all goods purchases electronically for a minimum of 7 years, including any relevant chain of custody or due diligence documentation. This may include receipts, KYC forms, import/export documentation, material analysis, and traceability reports. 

Our Approach to Risk Assessment & Mitigation[4]

As experts in building inclusive, sustainable business in conflict-affected and high-risk areas, the Federation and investees are well versed in risk assessment and mitigation. A fluid, adaptive approach is used to balance financial, environmental, and social risks.  While we work with a variety of development organizations and international NGOs, we recognize that risk assessment and mitigation is our own responsibility, not that of 3rd parties. All of our downstream partners should adopt similar strategies. 

    1. Human Rights Abuses associated with the extraction, transport, or trade of goods:
      1. While sourcing from, or operating in, conflict-affected and high-risk areas, we will neither tolerate nor by any means profit from, contribute to, assist with, or facilitate the commission by any party of:
        1. any forms of torture, cruel, inhuman, and degrading treatment;
        2. any forms of forced or compulsory labor, which means work or service which is exacted from any person under the menace of penalty and for which said person has not offered himself voluntarily;
        3. the worst forms of child labor;
        4. other gross human rights violations and abuses such as widespread sexual violence;
        5. war crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.
    2. Child labor
      1. While the Federation and investees reference the Craft Code created by Alliance for Responsible Mining (ARM), and the International Labor Organization’s (ILO) definition of child labor, there are often additional considerations to be made on a case-by-case basis. Local law as well as standards followed by countries such as the United States or other “Western” countries must also be taken into consideration to ensure that no expectation set by our organizations creates a double standard. The Federation and its investees believe that there should never be an expectation of our partner countries or partner communities that isn’t even met withing our own homes. That said, we do still report on worst forms of child labor as well as minors below the age of 15 in our supply chain incident reporting. We strive to continue to work with our suppliers, often rural communities with limited resources, to develop strategies to ensure that anyone still at school age have the resources necessary so that their health and personal development is not negatively affected.
    3. Direct or indirect support to non-state armed groups:
      1. We will not tolerate any “direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling, or export of minerals. “Direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling, or export of goods includes, but is not limited to, procuring goods from, making payments to or otherwise providing logistical assistance or equipment to, non-state armed groups or their affiliates who:
        1. illegally control mine sites or otherwise control transportation routes, points where goods are traded and upstream actors in the supply chain;
        2. illegally tax or extort money or goods at points of access to sourcing sites, along transportation routes or at points where goods are traded;
        3. illegally tax or extort intermediaries, export companies, or international traders.
    4. Public or Private Security Forces
      1. We agree to eliminate, direct or indirect support to public or private security forces who illegally control sourcing sites, transportation routes, and upstream actors in the supply chain referenced as:
        1. illegally tax or extort money or goods at the point of access to sourcing sites, along transportation routes or at points where goods are traded;
        2. illegally tax or extort intermediaries, export companies or international traders.
    5. Financial Risk Mitigations: 
      1. Fund origination
        1. Whenever possible, funds from the Federation originate from the US banking system. Though all funds must flow through international banks which adhere to the US and European bank transparency laws such as but not limited to FATCA.
          1. Subsidiaries or investees that operate in high-risk areas have account restrictions limiting the amount of funds kept in-country at any given time. 
      2. Bribery and fraudulent misrepresentation of the origin of goods:
        1. We will not offer, promise, give or demand any bribes, and will resist the solicitation of bribes to conceal or disguise the origin of goods, to misrepresent taxes, fees, and royalties paid to governments for the purposes of extraction, trade, handling, transport, and export.
      3. Money Laundering:
        1. We will support efforts, or take steps, to contribute to the effective elimination of money laundering where we identify a reasonable risk of money-laundering resulting from or connected to, the extraction, trade, handling, transport, or export of goods derived from the illegal taxation or extortion of goods at points of access to mine sites, along transportation routes or at points where goods are traded by upstream suppliers.
      4. The payment of taxes, fees, and royalties due to governments:
        1. We will ensure that all taxes, fees, and royalties related to the extraction, trade, and export from conflict-affected and high-risk areas are paid to governments and, in accordance with the Federation’s or investee’s position in the supply chain, we commit to disclose such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI) and other related organizations.
    6. Environmental Risk Mitigations: 
      1. Investees implement a variety of strategies to ensure that all its farming and mining partners are using the most environmentally sustainable, climate-smart practices available.
      2. In ASM mining, the Federation recently provided a financial incentive its investees and all its/their upstream suppliers, increasing payouts, contingent on mercury-free mining and farmers adoption of climate-smart farming practices. All cocoa and coffee are shade-grown, helping prevent deforestation. 
      3. Training on the dangers of using mercury, suppliers outside our supply chain, has begun in early 2019. The Federation’s newest initiative in gold value addition employs our new process of ‘refining’ which eliminates the use of all chemicals, except borax. This means the gold alloy used is true to form eco-friendly gold as no mercury, cyanide, chlorine gas or sulfuric, nitric, or hydrochloric acids are used in the process. 
    7. Gender-Based Violence Prevention: 
      1. The Federation implements a variety of robust efforts to empower women in upstream partner communities with specific priority focused on survivors of gender-based violence. By training, educating, and providing economic opportunities to vulnerable groups we seek to directly empower those that are all too often marginalized.
    8. Site Compliance: 
      1. In the case of mining, once a site has been validated ‘green’ or in general legally approved by relevant government authorities, compliance begins with the compliance officer, usually the ‘on the ground’ company officer who is tasked with site visits and gathering of all due diligence documentation. This includes ASGM SC Evaluation, KYC, land title documents, taking pictures and/or video and randomly interviewing individual miners (a process largely designed by the partners of the USAID funded CBRMT and later reviewed by the LBMA and OECD). In context of mining in high-risk areas, during this site visit, a small sample of material is taken to be analyzed using X-Ray Florescence (XRF) Spectrograph technology and kept on file to reference future material shipments to ensure no foreign material enters that sources supply chain (An amended process similar to that of the fingerprinting initiative by BGR). Our farmers, while not as regularly inspected as our mine sites, do have inspections completed on their farms from one of our investee staff members or partners. 
    9. Building Resilient Communities, Building Peace and Stability: 
      1. Many of our miners and farmers are coming from the same communities, some are the same people both farming and mining. By working closely with and trading directly with our community partners we’re able to create a more stable, resilient local economy. This means they aren’t as dependent on fluctuating international market prices for commodities like coffee or gold. Furthermore, by developing and stimulating local value addition, we solidify that local economic resilience even further. 
    10. Direct Trade: 
      1. Direct Trade is a way of doing business. It’s used by smaller companies that have an integrated supply chain and work directly with producers on the ground. It’s a bottoms-up approach to improve producer income and bridge the gap between grower or miner, producer, and you. Fairtrade is a label. It’s used by large companies, to verify that farmers who live thousands of miles away from where the chocolate is made are paid a fair price for their cocoa (which isn’t actually fair enough to be sustainable). It’s a top-down approach for companies with an outsourced supply chain. We go way beyond fair trade. We know the farmers and miners we work with on a daily basis. And they know us. We share meals in their homes, and we share a vision for equitable prosperity.
    11. Community Reporting Mechanism:
      1. The Federation has established an anonymous disclosure and reporting mechanism which can be accessed by anyone, at any time. This allows anyone from cooperative members, government officials, and stakeholders to report and identify issues within the supply chain. The reporting form can be found here and is available for use by all Federation investees to use.
    12. ASM Gold Specific:
      1. There are particular risks in sourcing ASM gold from conflict-affected and high-risk areas. These are broadly detailed risks outlined in Annex II of the OECD Due Diligence Guidance on Responsible Minerals Supply Chains in Conflict-Affected and High-Risk Areas. The following were identified as potential risks that can be found when sourcing ASM gold from a CAHRA:
        1. presence of non-state armed groups;
        2. human rights violations;
        3. worst forms of child labor;
        4. illegal & informal payments to security and government actors;
        5. nonpayment of legal taxes, e.g., smuggling;
        6. money laundering;
        7. falsified material origin.
          1. Most, if not all, of these identified risks, are mitigated by direct trade relationships with our cooperative partners and regular site inspections for verification. We also manage our own supply chains from the sourcing site to our processing facilities, so this further reduces our risks. Though we do not depend on them, all of our ASM gold sites have donor-funded projects working with our cooperative partners.
      2. ASM Gold Supply Chain Integrity: 
        1. Our supply chains are controlled through several different layers of security to ensure compliance and brand integrity. The first layer is a bagging system used to transport the material, ensuring no mixing of materials along the transport route (An amended process similar to the ITOA and the BGR bagging systems). The second is a ‘fingerprint’ of each mine site, as noted above, recorded and re-analyzed during each transaction to re-verify provenance. (Please note, fingerprinting transactions can only happen at the processing facility. Purchases made at an upstream point of sale are not yet analyzed in this manner. However, since all material is bagged, and not mixed, we analyze the material once it has arrived in the main processing and/or export facility. Any material purchased at these upstream point of sales not matching the our fingerprint records for the mine site it is claimed to come from shall be flagged for re-inspection by the compliance officer.

Our “Step 5” – Annual Reporting of Supply Chain Incidents & Indirect Risks[5]

Learning from our mistakes, and those of our development and community partners, we’ve determined that supply chain transparency cannot and should not be limited only to supply chain incidents. There are many risks that occur in the day-to-day operations of our supply chains that can have significant outcomes for the miners and farmers we work with. They are people just like you and me, and sometimes they are in situations well beyond their control or maybe they’ve just made a mistake. When we develop new supply chains we seek to build on continuous progress, which means we’re often starting from a baseline well below what some would call “international standard”. We’re willing to take those risks, often in areas where no others seem willing to work, to help build that community partners potential, so they may grow and prosper, increasing their capacity to reach higher standards and meet other downstream market actors’ expectations.

 

2017-2021 Cumulative Annual Incident Report

 

  1. Please note we do not publicly disclose information that may violate a person’s privacy or put a person’s or group of persons security at risk. Should further details be requested on a specific incident we and the Federation shall review on a case-by-case basis.

  2. All gold sourced in the DRC comes from sites both ‘green’ validated as well as having a presence of a donor-funded program working in support of our sourcing activities.

  3. While most cocoa and coffee sourced are from certified organic and UTZ farms, all our farming partners employ organic farming techniques. 

  4. The Federation supports the special report from the Intergovernmental Panel on Climate Change (IPCC) on 1.5°C and has joined the Net-Zero by 2050 Team. Many of the Federation investees, such as Cocoa Congo and Recycle Tribe, are already net-positive companies.

  5. DRC- Independent reports are published on a bi-annual basis by the UN Group of Experts. All supply chain actors are encouraged to read these reports as they are published @: https://www.un.org/securitycouncil/sanctions/1533/panel-of-experts/expert-reports