Chambers Federation is not a supply chain actor but supports beneficiary organizations with formal routes to market, often tied to specific donor related projects or objectives and co-financed between public and private sector organizations. Through this hosted portal for reporting, beneficiaries may submit incidents and risks that they would like to shine light upon. This is updated on an annual basis and covers all major sourcing activities related to beneficiaries, including but not limited to those receiving route to market or capacity building. Chambers Federation is not liable for any incidents and is merely providing a platform for beneficiary reporting.

Beneficiaries are independent organizations who have received all or part of the following from the Chambers Federation: investment; financial transaction assistance including but not limited to intermediary banking services; training; capacity building; formal market access; technical support. Should you have any questions regarding an organizations relationship with the Chambers Federation please send an email to matthew@chambersfederation.com.

Since 2017, all beneficiaries and their related supply chains have had access to this hosted portal. 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.

Approach to Responsible Sourcing[1]

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

Sources[2]’[3]

Management Systems

1. Conflict Minerals Policy: Please read this link.
2. Organizational Policy and Procedure Manual:  Chambers Federation provides its beneficiaries 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 beneficiaries, 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 a request to admin@chambersfederation.com.
3. Supply Chain Due Diligence: Law enforcement, United Nations Group of Experts (UNGoE), and independent experts are engaged 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: Beneficiaries keep a list of all active (and past) suppliers and keep files for each supplier, including Know Your Customer (KYC) forms where applicable.
5. Record keeping: Beneficiaries collect, and store documentation related to all goods and 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. 

Approach to Risk Assessment & Mitigation[4]

As experts in building inclusive, sustainable business in conflict-affected and high-risk areas, beneficiaries are trained in risk assessment and mitigation. A fluid, adaptive approach is used to balance financial, environmental, and social risks.  While beneficiaries work with a variety of development organizations and international NGOs, they recognize that risk assessment and mitigation is their own responsibility, not that of 3rd parties. All their 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.

1. Child labor
   1. While beneficiaries 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 the organizations creates a double standard. Beneficiaries believe that there should never be an expectation of partner countries or partner communities that isn’t even met within their own homes. That said, they do still report on worst forms of child labor as well as minors below the age of 15 in supply chain incident reporting. Beneficiaries strive to continue to work with 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.

1. Direct or indirect support to non-state armed groups:
   1. Any “direct or indirect support” to non-state armed groups through the extraction, transport, trade, handling, or export of minerals will not be tolerated. “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.

1. Public or Private Security Forces
   1. Beneficiaries 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.

1. Financial Risk Mitigations: 
   1. Fund origination
      1. Whenever possible, funds directed towards beneficiaries 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. Beneficiaries 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. Bribes are not offered, promised, given or demanded, and 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 are resisted.
   3. Money Laundering:
      1. Support is given to efforts or steps to contribute to the effective elimination of money laundering are where it has been identified that there is 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. It will be ensured 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 beneficiary’s position in the supply chain, the disclosure of such payments in accordance with the principles set forth under the Extractive Industry Transparency Initiative (EITI) and other related organizations has been committed to.

1. Environmental Risk Mitigations: 
   1. Beneficiaries implement a variety of strategies to ensure that all their farming and mining partners are using the most environmentally sustainable, climate-smart practices available.
   2. In ASM mining, a financial incentive for beneficiaries and their upstream suppliers has been provided, 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 the supply chain, began in early 2019. A new initiative in gold value addition employs a 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. 

1. Gender-Based Violence Prevention: 
   1. A variety of robust efforts to empower women in upstream partner communities with specific priority focused on survivors of gender-based violence are implemented. By training, educating, and providing economic opportunities to vulnerable groups it is aimed to directly empower those that are all too often marginalized.

1. 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 Fluorescence (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). Farmers, while not as regularly inspected as mine sites, do have inspections completed on their farms from beneficiary staff members or partners. 

1. Building Resilient Communities, Building Peace and Stability: 
   1. Many 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 community partners there is the opportunity 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, local economic resilience is solidified even further. 

1. 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 bottom-up approach to improve producer income and bridge the gap between grower or miner, producer, and consumer. 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. Beneficiaries go way beyond fair trade. They know the farmers and miners they work with on a daily basis. And they know them. They share meals in their homes and share a vision for equitable prosperity.

1. Community Reporting Mechanism:
   1. This is 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. 

1. 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 cooperative partners and regular site inspections for verification. Supply chains from the sourcing site to processing facilities are also managed, so this further reduces risks. All ASM gold sites have donor-funded projects working with cooperative partners.

1. ASM Gold Supply Chain Integrity: 
   1. 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, material is analyzed once it has arrived in the main processing and/or export facility. Any material purchased at these upstream point of sales not matching the fingerprint records for the mine site it is claimed to come from shall be flagged for re-inspection by the compliance officer.

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

Learning from mistakes of our development and community partners, it has been 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 involved. There is a human element when people get in situations well beyond their control. When new supply chains are developed, it is sought to build on continuous progress, which often means starting from a baseline well below what some would call “international standard”. It’s worth taking 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.

2017-2022 Cumulative Annual Incident Report

1. Please note information is not publicly disclosed if it 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 it shall be reviewed 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 sourcing activities. ↑
3. While most cocoa and coffee sourced are from certified organic and UTZ farms, all farming partners employ organic farming techniques.  ↑
4. The special report from the Intergovernmental Panel on Climate Change (IPCC) on 1.5°C and the Net-Zero by 2050 Team are supported. Many beneficiaries part of Project Origins 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 ↑