Mining You Can Trust
The gold industry faces the responsibility with the application of the International Due Diligence regulations, such as the EU Conflict Minerals Regulations, the OECD Due Diligence Guidance, the US Dodd-Frank Act, National Action Plans on Business and Human Rights and the due diligence laws in particular national legislations. The implementation of due diligence protocols implies energies, efforts and resources. However, there exists an opportunity to transform those efforts into positive outcomes because the industry can engage with the most vulnerable group in the supply chain: artisanal and small-scale miners.
Although artisanal and small-scale mining (ASM) is associated with highs risks and some challenges, there is a window to convert the due diligence process into a tool for development using the Code of Risk-mitigation for ASM engaging in Formal Trade – CRAFT. The industry plays a key role to engage with the sector and to support their formalisation’s process, respecting human rights in mining communities and committing to the improvement of the conditions of the sector.
Due to the need to have a common understanding about how to apply due diligence in ASM, the Alliance for Responsible Mining (ARM) and RESOLVE (with the participation of a coalition of supply chain actors and experts) developed the CRAFT v 1.0 in 2018 with the support of European Partnership for Responsible Minerals (EPRM). Now, CRAFT shows there is a way that the industry engage with ASM. CRAFT is a standard to engage with MINING YOU CAN TRUST.
The CRAFT criteria
CRAFT offers a set of requirements with guidance for the application of each criterion.
Module 1: Adopting a Management System. This includes the basic elements to create a management system for artisanal and small-scale mining, such as a description of the operation and members, the responsible person, or the complaints point of contact.
Module 2: Legitimacy as a condition of engagement (OECD). It offers 4 country context scenarios (ASM legislations, enforcement, state commercialisation).
Module 3: OECD Annex II – immediate disengagement risks. The Module has pass/fail criteria. It covers the following set of risks:
- Forced labour
- Worst forms of child labour
- Gross human rights violations
- War crimes
- Support to non-state armed forces
Module 4: OECD Annex II – risks requiring mitigation. The Module has pass/fail and progress criteria. It covers the following set of risks:
- Involvement of public and private security forces
- Money laundering
- Bribery/fraudulent representation of the origin
- Non-payment of taxes, fees, royalties
Module 5: High risks beyond OECD DDG Annex II which are aspirational, and the adoption depends on priorities. The set of elements are not an impediment to access formal markets, but it marks other step by step improvements. Module 5 has only pass or progress criteria, of risks being controlled or mitigation in progress.
- Health and safety
- Child labour
- Women’s rights
- Land & mineral rights + formalisation
- Peaceful coexistence
- Organisation strengthening
- Environmental mitigation: Minamata + water
© Alliance for Responsible Mining
CRAFT application is an opportunity to engage with the sector
Today the industry faces a unique opportunity to support the artisanal and small-scale mining sector. The volume of gold purchased from the LBMA members is still marginal. It represents less than 50 tonnes in comparison with the total ASM gold production of 560 tones (LBMA). This means it still exists a huge opportunity for LBMA’s refiners to decide to make a responsible engagement despite the risks because there are tools in standards such as CRAFT to facilitate the application of the due diligence. CRAFT does not replace the due diligence responsibility from the industry, nonetheless, it offers the potential to simplify the starting point of the process and create a common language for risk identification and mitigation.
Key characteristics of CRAFT Code to facilitate the adoption:
- CRAFT creates a conversation of due diligence between ASM and/or local mineral aggregators and the refiners and downstream companies.
- CRAFT promotes the legitimacy of the ASM and the continuous development and improvement of the management of risks.
- CRAFT takes into account the five steps of the OECD framework particularly in risk assessment (step 2), risk mitigation (step 3), verification (step 4) and reporting (step 5).
- A code of progressive compliance for Artisanal and Small-Scale Mining (ASM) producers and closely aligned with the OECD Due Diligence Guidance.
- An open-source code released under the Creative Commons CC BY-SA 4.0 license. It may be used by any stakeholder in the ASM supply chain.
The experiences with the application by the Alliance for Responsible Mining are available at www.craftmines.org.
CRAFT 2.0 is already published
After the second public consultation and discussions in the governance bodies, the CRAFT 2.0 is available from October with a new structure and it has the possibility to include other commodities such as 3T, cobalt and coloured gemstones.
Click on each volume to know the content depending on the needs or access to the full version in one single book: https://rebrand.ly/CRAFTv2-ESP.
Volume 1: Introduction and General Characteristics.
Volume 2: Requirements for ASM Mineral Producers.
Volume 2A: Commodity-independent Requirements.
Volume 2B: Commodity-specific Requirements.
Volume 3: Guiding Principles for CRAFT Schemes
How can refiners adopt and support miners using the CRAFT?
CRAFT proposes how the industry can proactively support miners in the application and improvement of the legitimacy of the sector and their conditions. Particularly, refiners can decide on including the ASM sector into their supply chain and sourcing programmes. They can define how they can incorporate the application of CRAFT into their due diligence policies. For instance, it is worth mentioning that LBMA includes CRAFT in the ASM Self-Assessment Questionnaire*.
CRAFT invites refiners as supply chain schemes to engage with the ASM sector with a particular role for each Module:
Refiners might evaluate if the ASM groups fall into the scope of CRAFT and if the organisational setup of the ASM group is suitable for commercial engagement. Refiners might start supporting miners to establish and strengthen their organisational structure.
Determination of legitimacy and counting with all public or private documents that authorise its operation is one of the big challenges in the ASM sector. There are different kinds of legislations and commercial and banking access procedures for each country. Here it is the initial and important phase of engagement with ASM groups, evaluating whether the miners are legitimate, and participate in the formalisation process to provide guidance to accomplish this point.
For some of the requirements in this module it might be difficult for miners to obtain evidence to make verifiable claims. In some cases, where the members of the ASM groups are victims of human rights abuses by non-state armed groups, the attempt of assessment of these crimes by them may even put their physical integrity at life-threatening risk. Refiners may count on tools or contacts to access sensitive conflict-related information, which miners do not have. CRAFT Schemes are expected to support miners to the extent possible with the collection of evidence to accomplish Module 3.
For some of the requirements in this module it might also be difficult for miners to obtain evidence. Particularly in their relation to public security forces, ASM miners are usually the victims of abuses and extortion and extremely vulnerable. Refiners are expected to support miners to the extent possible with the collection of evidence and the implementation of risk management plans, as required to accomplish Module 4.
Is intentionally not prescriptive on sequencing and prioritising improvements of high risks in Module 5 and it is an opportunity for refiners and industry to proactively contribute towards the stepwise process to adopt some additional issues that are important for the miners. This may be a very early point towards responsible ASM mining practices, responsible supply chains and sustainable development.
The CRAFT >> Fairmined model as an alternative to support the economic revival and formalisation of artisanal and small-scale mining.
At the Alliance for Responsible Mining, we invite the gold industry market, NGOs and governments to get involved with our Sustainable Mines Program, based on the CRAFT Code and Fairmined model as a way to support mining groups and organisations that are making efforts to develop responsible mining. If the interest is to start from early engagement, initially starting with the management of high risks, CRAFT is the solution (www.craftmines.org), because CRAFT supports mining you can trust.
However, if refiners and downstream companies want to give further steps to access fair gold, the Fairmined Initiative (www.fairmined.org) offers the solution with the highest performance level requirements in the sustainable mineral standards for ASM. The Fairmined standard certifies responsible and ethical mining organisations and promotes gold to be proud of. Fairmined is an alternative to support the positive development of mining communities, offering decent job opportunities and making positive impacts at social, economic and environmental levels. Fairmined is gold to be proud of.
The CRAFT code promotes the formalization and risk management of artisanal and small-scale mining organisations that start engaging to formal markets and the mitigation of their high risks. CRAFT is the beginning of the responsible mining journey. For more information about CRAFT, please contact: firstname.lastname@example.org.
Natalia Uribe, Head of Standards and Certification at ARM, is an economist, with a professional career focused on local development, especially in vulnerable communities. Since 2014, she has been working in ARM particularly in the creation, governance, assurance and maintenance of Fairmined and CRAFT standards, as well as management of project activities. Natalia has interacted with all gold supply chain actors from the ASM miners to downstream companies, standards-setting organizations and thematic experts. Natalia has a wide understanding of the ASM sector stakeholders and a large experience in developing capacity building and sensitization content related to ASM.