MINERAL TRACEABILITY SERVICES

RMB provides mineral traceability services for 3Ts (Tin, Tantalum and Tungsten). The provision of these mineral traceability services complies with the Dodd-Frank Wall Street Reform and Consumer Protection Act adopted in 2010 by the U.S. Congress. Section 1502 requires publicly traded companies on the U.S. Stock Exchange to disclose their use of 3Ts or gold and to make an annual report if these minerals coming from the DRC or any adjoining country, such as Rwanda, were conflict-free. Rwanda was the first country in the Great Lakes Region (GLR) to commit to the nationwide implementation of a due diligence and traceability system with the support of the International Tin Research Initiative (ITRI) Tin Supply Chain Initiative (iTSCi) and RCS Global Group (Former Better Sourcing Program/BSP).

 

     1. ITSCI (International Tin Supply Chain Initiative)/ITA (Former ITRI)

ITA (International Tin Association) is a membership-based organization funded by major tin producers representing the interests of the tin industry supply chain on a global basis. ITA has developed with a range of industry partners a phased and constructive approach towards improved due diligence, governance and traceability of cassiterite (the ITRI Tin Supply Chain Initiative referred to as “iTSCi”) and has been operating a pilot project on Phase 2 (traceability) in the DRC since June 2010. ITA wishes to expand the scope of Phase 2 to other relevant minerals and other countries affected by the US ‘conflict minerals’ Bill in order to further reassure metal buyers on the provenance of their materials.

Hence, a Memorandum of Understanding (MoU) was signed between ITRI and the Rwanda Natural Resources Authority (RNRA) /Geology and Mines Department (GMD) former OGMR, under the Ministry of Natural Resources on 10th September 2010 and it still fulfilled.

     2. RCS Global Group/Former BSP

This is a mineral supply chain due diligence implementation and assurance service, supporting compliance of upstream natural resources operators with transparency and sustainability expectations from international buyers and investors. The Memorandum of Understanding (MoU) with RNRA to implement Minerals Traceability Scheme was signed in March 2016.

Its services are intended to offer a mineral supply chain due diligence, transparency and traceability solution which is cost-effective, efficient and reliable for the mining companies, Government, small scale miners, mineral buyers and exporters in Rwanda with respect to the Designated Minerals.

3.  Due Diligence

a)  What is Due Diligence for Conflict-Free Supply Chains?

Due diligence is a process that companies or individuals should undertake to ensure that the extraction and trade of mineral ores containing tin, tantalum, tungsten and gold support peace and development, not conflict. This includes a number of steps to put in place strong systems of control over the supply chain, pass vital information to buyers and to the governments and regional institutions that regulate the mineral trade, assess conflict conditions at mine sites, transportation routes and points where minerals are traded in order to source from areas and suppliers that do not contribute to conflict, and report on due diligence.

 b) Due Diligence in Rwandan Mining Sector

As Rwanda belongs to the area that special attention should be given to when supplying minerals to guarantee they are conflict-free, international buyers should be at least indirectly committed to promoting human rights and fighting against mineral conflict.

Traceability and certification initiatives both contribute to the due diligence process by enabling buyers to ensure that these ores have neither been used to finance conflicts nor, more broadly, to violate human rights in the countries of production. With the objective to comply with due diligence conditions set by the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 on conflict minerals, several measures are taken to enforce a sustainable development of the mining sector and undermine illegal exploitation and trade of its products. This includes a verification and description of all produced minerals. In December 2010 the iTSCi, a certification scheme for domestically produced 3Tminerals, was implemented by the Rwandan government and the ITRI screening the end-user requirements set by the Dodd-Frank Act (DFA) and the RMAP (e.g. indicating conflict minerals that could be misused for financing illegal or military purposes).

4 .  What we do in Mineral Traceability

  • Responsible for traceability materials (logbooks and tags) distribution and management
  • Weighing, tagging and record all produced minerals for each Mine site of Mining companies/Cooperatives
  • Follow up on any potential risk of health, safety, security, fraud and environment damage in mining
  • Work closely with regulation and inspection unit on demands/application of tags and logbooks
  • To ensure that all steps to check the compliance of procedures in traceability (mineral chain tracking) are respected
  • Joint field visits/inspections (RMB & Traceability services Providers) for baseline reviews and updates.
  • In collaboration with Mineral Traceability Services Providers; Supervise, monitor and handle any Mineral Traceability Issues that may arise
  • Follow and monitor mineral chain of custody payment and other fees related
  • Keep and document all information related to mineral chain of custody, payments and tag distributions and management database
  • Work closely with ITA/PACT and RCS Global Group (Former BSP) or any other chain of custody service provider in relation to tag distribution and management
  • Receiving, reviewing and handling the RMB Staff’s reports related to Mineral Traceability from the District and Comptoirs.