This report is updated on an annual basis, as high-level incidents occur, and covers all subsidiaries of the Chambers Federation including Fair Congo and Cocoa Congo (Federation).
Since 2017, the Federation has implemented a strict transparency rule for all its supply chains which is not restricted to mineral sourcing, conflict-affected or high-risk areas. Every effort is made to replicate the due diligence standards recommended by the OECD for responsible mineral sourcing across all sectors including coffee and cocoa. Supply chain issues will happen but not acknowledging those errors means they could happen again.
How information is collected:
Information is currently collected by a variety of sources including but not limited to: local civil society; international donor funded program partners; cooperative suppliers; internal compliance officers.
1: Our Approach to Responsible Sourcing
The Federation understands that the due diligence is an ongoing process of engagement with all levels of the supply chain responsible in identifying, mitigating and addressing any risks. While the Federation is a mid and downstream actor we engage in direct trade with our producing partners, whether miners or farmers. We inspect each sourcing site 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.
*Please note we do not publicly disclose information that may violate a person’s privacy or put a person or group of persons security at risk. Should further details be requested on a specific incident the Federation shall review on a case by case basis.
2: Our Sources
The Federation sources goods from the following countries:
Cocoa: North Kivu and Ituri provinces, DRC
Sugar: Kibuye, Rwanda; Mumias, Kenya
Coffee: North Kivu, South Kivu, Ituri provinces, DRC
Vanilla: North Kivu, Ituri provinces, DRC
Gold: Kakamega, Kenya (2008 & 2009 only); Maniema, South Kivu, Ituri provinces, DRC
*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. While most cocoa and coffee sourced are from certified organic and UTZ farms, all our farming partners employ organic farming techniques.
3: Our Management Systems
Conflict Minerals Policy: Please read at this link.
Organisational Policy and Procedure Manual: The Federation implements 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. This manual may be adapted by its subsidiaries to contextualize specific local laws, depending on the jurisdiction. Copies of this manual may be viewed in person in any of our offices around the world.
Supply Chain Due Diligence: The Federation engages law enforcement and independent experts to engage in supplier due diligence and background checks. Any ‘red flags’ that come from these checks are reviewed by the Federation board. Should any of these ‘red flags’ link to AML/CFT violations, a strict no engagement policy is enacted.
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.
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 includes receipts, KYC forms, import/export documentation, material analysis and traceability reports.
4: Our Approach to Risk Assessment & Mitigation
As an expert in building inclusive, sustainable business in conflict-affected and high-risk areas, the Federation is 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 organisations and international NGOs, we recognize that risk assessment and mitigation is our own responsibility, not that of 3rd parties. All downstream partners of the Federation should adopt similar strategies.
Financial Risk Mitigations: All funds from the Federation, and downstream partners, originates from the US banking system and must flow through international banks which adhere to US and European bank transparency laws such as FATCA. Subsidiaries which operate in high-risk areas have account restrictions limiting the amount of funds kept in country at any given time.
Environmental Risk Mitigations: The Federation implements a variety of strategies to ensure that all its farming and mining partners are using the most environmentally sustainable, climate smart practices available.
In ASM mining, the Federation recently (mid 2019) implemented a financial incentive to all its upstream suppliers, increasing payouts, contingent on mercury free mining. 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 a true to form eco-friendly gold as no mercury, cyanide, chlorine gas or sulfuric, nitric or hydrochloric acids are used in the process.
Farmers also receive a premium from the Federation to engage in climate smart practices. All Federation cocoa and coffee are shade grown, helping prevent deforestation.
*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 subsidiaries, such as Cocoa Congo and Recycle Tribe, are already net-positive companies.
Gender Based Violence Prevention: The Federation implements robust efforts to empower women in our local communities. By training, educating and provided economic opportunities to vulnerable groups we provide
Site Compliance: In the case of mining, once a site has been validated ‘green’, compliance begins with the in-house agent de conformité (compliance officer), the ‘on the ground’ company officer who is tasked with site visits and gathering of all due diligence documentation including ASGM SC Evaluation, KYC, land title documents, taking pictures 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). During this site visit a small sample of material is taken to be analyzed using XRF 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 company staff members or partners.
Building Resilient Communities, Building Peace and Stability: 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. By creating local value addition, we solidify that local economic resilience even further.
Direct Trade: 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. Fair trade 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 prosperity.
Community Reporting Mechanism: 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.
ASM Gold Specific:
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-free and High-Risk Areas. The following were identified as potential risks that can be found when sourcing ASM gold from the a CAHRA: presence of non-state armed groups; human rights violations; worst forms of child labor; illegal & informal payments to security and government actors; nonpayment of legal taxes, eg smuggling; money laundering; falsified material origin. 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.
ASM Gold Supply Chain Integrity: Federation 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 verify provenance. (Please note, fingerprinting transactions can only happen at the processing facility. Purchases made at a PDV, ‘point de vente’, are not yet analyzed in this manner. However, since all material is bagged, and not mixed, the Company analyzes the material once it has arrived in the main processing and export facility in Goma. Any material purchased at these PDVs not matching the Company’s fingerprint records for the mine site it is claimed to come from shall be flagged for re-inspection by the agent de conformité (compliance officer)).
5: Annual Reporting of Incidents & Actions Taken
6: Future Improvements to Our Due Diligence & Reporting Processes
1) The Federation has begun training and implementation of ORIGINS Gold CRAFT Scheme, based on Alliance for Responsible Mining CRAFT Code. This contextualizes the due diligence and traceability realities specific to CAHRAs such as the Democratic Republic of Congo.
2) The Federation will begin to implement new supplier contracts to better monitor premiums paid to its farming partners.