The GIFF Project
In 2015, ELL and The Global Initiative against Transnational Organized Crime (GI) came together around a shared urgency to better understand how illicit financial flows act as impediments to the formalisation of Artisanal and Small-scale Gold Mining (ASGM), with a focus on gold. The result is The Gold and Illicit Financial Flows Project (The GIFF Project).
The GIFF Project aims to:
- Raise awareness and understanding of IFFs and criminal networks in gold supply chains;
- Create a network of stakeholders interested in and working on ASGM formalisation and IFFs in gold supply chains that will share knowledge and strategies; and
- Provide stakeholders and decision makers (in government, civil society, and the private sector) with tools to identify, map, and address IFFs in their gold supply chains.
In 2016, the GIFF Project will:
- Develop a toolkit to arm stakeholders with knowledge and tools to better identify and combat IFFs in the gold supply chain that impede formalisation of the sector. It will assess the various forms and functions of IFFs in ASGM, analyse existing legal frameworks related to these flows, and prescribe ways to address and prevent illegal activity in gold supply chains.
- We are designing regional dialogues and local micro-dialogues to be held, if funding permits, in the Great Lakes Region, West Africa, and/or Latin America to inform the toolkit. We aim to democratise the conversation, bringing together small groups of stakeholders – for example, miners, financiers, government regulators, mine service providers – to better understand the link between IFFs and informality of ASGM sectors on the ground. This is a critical step, enabling stakeholders in gold producing regions to directly provide insights and advice, and potentially to build momentum on the ground to identify and address barriers to ASGM formalisation.
The GIFF Project’s first stage, funded through GIZ, is currently underway:
- The project was launched at the Miners, Minerals and Minimata Roundtable in December 2015. Presentations by Project Director, Estelle Levin, and Project Manager, Marcena Hunter, were warmly received as attendees drew strong connections to on-going work examining mercury supply chains and financing.
- A roundtable discussion was held in Washington D.C. in February 2016 to present the project and gather inputs from stakeholders on its priorities and expected outputs. Attendees included representatives from USAID, Department of State, the Enough Project, Global Financial Integrity, Resolve, GEF, and the World Bank, amongst others. For more on the key issues and questions identified by roundtable participants, see the full report here.
- A multi-stakeholder workshop will be held on the sidelines of the ICGLR-OECD-UN Group of Experts Multi-stakeholder Forum in Paris in May 2016. We would welcome your interest and participation.
To learn more about ASGM, IFFs, and The GIFF Project, you can read our concept note here.
To learn more about ASGM, IFFs, and The GIFF Project, you can read a project description here.
For more information on the project, to request an invitation to the multi-stakeholder workshop, or to be put on our mailing list please contact us at email@example.com.
You can also see our pleanary and conference presentations by clicking the links below:
 Seccatore J, Veiga M, Origliasso C, Marin T, De Tomi G. (15 October 2014) “An estimation of the artisanal small-scale production of gold in the world”, Science of the Total Environment. Vol. 496. pp. 662–667.
Marketplace of Ideas & Mongolia’s Best Practice
ELL Facilitates International Symposium Kicking off Global ASM Knowledge Hub – Ulaanbaatar, Mongolia June 2015
Estelle Levin facilitated an international symposium bringing together leaders of knowledge initiatives in the field of Artisanal and Small-scale Mining. Participants scoped opportunities for cooperation and knowledge sharing between them, setting up opportunities to drive greater impact for artisanal miners and their communities around the world.
One technique involved a decentralised marketplace learning approach. Under the bespoke approach, the brainwave of ELL Associate, Gisa Roesen, each participating organisation designed a booth to feature their work. Participants were encouraged to walk through the marketplace and directly engage with the materials. In addition to sparking conversations and facilitating learning in real time, the participants used slips of paper to tag comments, questions, insights, and ideas to each display with a focus on where there might be ‘touch-points’ for cooperation and leverage.
The event took place in Mongolia, which allowed local stakeholders an opportunity to share the best practice examples they have been developing in ASM formalisation. The gathering featured delegates from 18 countries and representatives from 35 different governments, NGOs, international bodies, consulates/embassies, leading ASM projects, research and training institutes, and local ASM communities. The ASM Knowledge Hub International Symposium drew upon the group’s rich experience and expertise to discuss the establishment of the Knowledge Hub. Key topics included:
- Need for and demand of an ASM Knowledge Hub
- Functionality and structure of a Knowledge Hub
- Networking and collaboration opportunities for the Knowledge Hub with other ASM knowledge initiatives and partners
- Sustainability of the Knowledge Hub
You can find out more about this event and download the workshop report, here: http://www.sam.mn/news_en.php?title=International-Symposium-held-in-Ulaanbaatar-to-discuss-the-establishment-of-Knowledge-Hub-on-Artisanal-and-Small-scale_Mining
Low Cost (‘Frugal’) Methods for ASM Environmental Rehabilitation Study
As part of the Asia Foundation’s programme on Engaging Stakeholders in Environmental Conservation (ESEC II) in Mongolia, ELL is conducting a study on international best practices of frugal and sustainable rehabilitation approaches for artisanal and small-scale mining (ASM) of gold, coal and fluorspar. ESEC II seeks to mitigate the environmental impacts of historic and current ASM and enhance ASM’s contribution to sustainable local development.
In Mongolia, where gold mining represents 90% of ASM and fluorspar and coal mining the remaining 10%, land degradation from ASM is perceived as one of the most pressing issues faced by communities and miners. Artisanal miners often do not have the resources to achieve the same level of rehabilitation as large-scale mining nor do they have reliable access to technologies that help prevent or reduce chemical contamination. Context specific, economically affordable, socially acceptable, and sustainable rehabilitation approaches are needed to help transform degraded landscapes into productive uses and to foster improved environmental stewardship within ASM operations.
ELL’s case study of international best practices in ASM rehabilitation draws upon examples from arid and semi-arid ecosystems in Africa, Latin America, and Asia that have demonstrated success and are relevant to the Mongolian context. The case study will provide recommendations on improved environmental stewardship at each phase of the ASM life-cycle, from operations to closure and reuse. ELL’s research will also apply ecological restoration planning concepts to post-mining land rehabilitation to encourage scientifically sound and economically and socially desirable rehabilitation projects that result in lasting and productive land uses.
The case study report will provide the basis for ESEC II to facilitate the implementation of frugal environmental rehabilitation by local NGOs.
Photo credit Cristina Villegas
Situational Analysis and Sustainability Assessment of the Tin Sector in Bangka Belitung, Indonesia
The purpose of The Sustainable Trade Initiative’s (IDH) Indonesian Tin Working Group is to explore if and how its members can positively contribute to addressing the sustainability challenges of tin mining in Bangka and Belitung whilst recognising the economic benefits of the sector in terms of development and poverty reduction. Group members include Apple, Blackberry, LG, Phillips, Samsung, Sony, EICC, ITRI and Friends of the Earth.
ELL conducted a situational analysis and sustainability assessment to aid the Group’s understanding of the local situation as a starting point for exploring ways to support sustainable growth through responsible sourcing. We also supported IDH in project managing and convening the group, and presented our findings at an ITRI tin event in Bangka in December 2013.
The ELL team was composed of local and international experts including mining engineers, environmental, human rights and ASM experts. Fieldwork was conducted for one month in Jakarta, Bangka and Belitung in September 2013. Throughout the project, the team consulted a range of international experts and over 100 Indonesian stakeholders, including but not limited to government officials at all levels (national, provincial, local), miners (large, small, legal, unconventional, male, female, etc.), collectors (tin buyers), smelters, civil society representatives, tin sector experts, academics, industry association representatives, farmers, shop-keepers, equipment renters and more. The team also visited smelting operations, large-scale mining operators’ concessions, offshore and onshore small-scale mine sites and abandoned (post mining) sites. This research culminated into findings and initial conclusions about the commercial, social, economic, political and environmental sustainability of tin mining supply chains in the region and potential pathways towards more sustainable production.
Ell’s work has helped inform the Working Group of the avenues, challenges and potential opportunities for sector engagement within their sphere of influence. The group is now empowered with enough understanding to start meaningful engagement with Indonesian stakeholders to jointly determine next steps.
Clink here for more information on the IDH Tin Working Group
Photo credit: Widi Brotokusumo
A Corporate’s Journey Towards Sustainable Gemstone Sourcing
Partnering with communications & CSR expert Bernadette Larcher, ELL was engaged to support a large corporate client determine an approach to improve sustainability in their gemstone sourcing. The company wanted to better assure their sourcing and aspires to educate their customers on their sustainable sourcing practices. ELL was brought in to build transparency into the client’s colored gem supply chains and so identify the gems’ countries of origin in order to help the company better understand the risks and opportunities for their actual supply chains and to create the tools to help support sustainable supply chain management.
The ELL team assessed the material issues in gemstone mining, trading, and processing. This assessment informed the design of a supplier questionnaire which was used in Asia and Latin America to interview Tier 1 suppliers to understand their knowledge of the supply chains and risks as well as their desire and ability to comply with sustainability criteria in their sourcing practices. The information was used to identify engaged suppliers, and understand the gaps in information about the supply chain. It also helped ELL to rank risks in sourcing which has become a powerful management tool. ELL has since conducted deep dive research on supply chains for specific gems and developed a Code of Conduct specific to gemstone sourcing, but which was later adapted into a general Code of Conduct and Extractives Policy for responsible sourcing across the group.
This work has helped the company meaningfully engage with its suppliers on the issue of sustainability. The company also now has tools that can help manage and mitigate risk. Furthermore, the work has helped raise awareness amongst the organisation senior management and suppliers about the challenges and opportunities on their journey towards sustainability.
Photo credit: Rupert Cook
Digging Deeper: Understanding the Incursions of Artisanal and Small-scale Mining in Protected Areas and Critical Ecosystems
As part of the ASM-PACE Programme’s mission of engagement, sharing and dialogue around the issue of ASM in Protected Areas and Critical Ecosystems, ELL, in collaboration with WWF, hosted two ASM-PACE Roundtables in Washington D.C. and London. These events were convened with the intention of sharing the research led by ELL, WWF and FFI in DRC, Gabon, Liberia and Madagascar as well as the results of ASM-PACE’s Global Solutions Study. The events were designed to garner feedback from interested stakeholders and to solicit interest and direction for the next iteration of the programme.
The ELL team convened over 50 stakeholders including development experts, conservation organisations, ASM specialists, and representatives from the industrial mining sector. WWF-US and the International Institute for Environment and Development (IIED) hosted the meetings in Washington D.C and London respectively. Over two years of research into the issue in over 25 countries was sythesised and presented to the audience. The dialogue facilitated by ELL brought debate, interest and new ideas to the topic.
In conceptualizing and delivering these events and presenting the ASM-PACE research, ELL has established a community of practice and a platform for discussion around the challenges and potential solutions for addressing the issue of ASM in PACE. Furthermore, ELL has created a call for action and new management strategies for tackling the issue on a local level. Lastly, ELL created a shared understanding amongst funders, policymakers, conservationists, and those that support ASM communities.
Clink here for information on ASM-PACE programme.
Photo credit: Rupert Cook
Mineral Supply Chain Due Diligence Audits and Risk Assessments in the Great Lakes Region
The German Federal Institute for Geosciences and Natural Resources (BGR) commissioned ELL to help the ICGLR Audit Committee determine opportunities for alignment of the Regional Certification Mechanism (RCM) with other systems over the short and long term and to have the foundations for developing their audit methodology and template. The ICGLR (International Conference of the Great Lakes Region) Audit Committee coordinates and monitors the RCM’S third party exporter audits to ensure the export of conflict-free minerals from the region.
The ELL team undertook fieldwork in Rwanda and the Democratic Republic of Congo (DRC), interviews with individuals managing the relevant conflict minerals initiatives, and liaised with the Audit Committee advisory group. This work included comparison of the audit schemes of the various conflict minerals initiatives with the Regional Certification Mechanism of the ICGLR. It considered the core systems driving responsible sourcing systems for ‘conflict minerals’ (the OECD Due Diligence Guidance, the Dodd-Frank Act) and analysed the audit components of nine upstream conflict minerals systems which support 3TG supply chain due diligence in the GLR. Lastly it considered the needs of downstream conflict minerals systems that require adequate assurance of upstream due diligence activities. The work was explored with the Audit Committee in a 3-day consultation workshop facilitated by ELL.
As a result of this work, there is a clear foundation and starting point for the design of a draft audit methodology for the RCM’s third party exporter audit. This ‘audit template’ will ensure consistency of approach by ICGLR third party auditors and will be used for data compilation during audit preparation and fieldwork, and as a basis for drawing audit conclusions with regards to the RCM compliance of the auditee. The process has also opened up discussions with non-ICGLR stakeholders regarding system alignment opportunities.
Clink here for the analytical report and audit template
Photo credit: Rupert Cook
Fairtrade/ Fairmined ASM Scoping Studies
Estelle Levin conducted scoping studies in Sierra Leone, Tanzania and Uganda to assess the potential of fair trade gold from these countries. The aim was to identify producer organisations and potential partners for setting up Fairtrade/Fairmined gold production in Africa. The work was commissioned by the Alliance for Responsible Mining (ARM). In each case the work was facilitated by a local partner, namely FBME Bank in Tanzania, the Foundation for Environmental Security and Sustainability in Sierra Leone, and the World Bank’s Sustainable Management of Mineral Resources Project in Uganda.
The studies, which included deskwork and fieldwork, required an assessment of the challenges and opportunities for the organized production and trade of ASM gold that could comply with an international social and environmental standard. Assessment of organizational structures, legislative frameworks, supply chains and trading relationships was done. They also considered compliance readiness—the ability of stakeholders within each country to meet basic social and environmental compliance criteria. The analysis involved site visit, document review, and interviews and workshops with miners, traders, government officials, vulnerable groups, development agencies, and other critical stakeholders. A key part of the work was also consultation on ARM’s ‘Standard Zero’ to see what changes were necessary to make it feasible in an African context.
As a result of this work Fairtrade Foundationl raised £820,00 from Comic Relief to provide the technical assistance necessary to bring 9 groups in Uganda and Tanzania to compliance with the Fairtrade standard. We can expect the first Fairtrade Gold from these producers by 2016.
Photo credit: Cristina Villegas
Comparative analysis of legal and fiscal regimes for Artisanal Diamond Mining in Central African Republic
ELL, working with Tetratech ARD, supported USAID’s Property Rights and Artisanal Diamond Development (PRADD) project by developing a comparative study to understand how artisanal diamond miners in Central African Republic could be incentivised to formalise their activities through reduced costs of licensing, royalties, taxes, and fees.
The ELL Team reviewed legal codes, statistics and reports pertaining to the fiscal and legal systems for artisanal and small-scale mining of precious minerals in 10 countries, and identified the factors that determine rates of formalisation of artisanal mining sectors. The team also consulted with experts and government officials and created detailed case studies from diamond producing countries—Liberia, Sierra Leone, Guyana, Tanzania, and the Democratic Republic of Congo (DRC) – and gold and coloured gem countries – Madagascar and Philippines. The Team performed statistical analysis and developed an economic model to determine what level of license fee will generate the higher formalization rate and the higher revenue for the state.
This work was acknowledged to be a key factor in the government of CAR’s decision to reduce the price of the miner’s licence fee (the patente) from 46,500 CFA to 30,000 CFA. This 36% reduction in price actually increased revenue in state coffers by 25% between 2010 and 2012. 1,821 licenses in 2010, 2,564 licenses in 2011, and 3,542 licences in 2012. This led to not only an uptake in formalization but also provided financial benefits to the state. Sadly the recent civil war in CAR means these gains may be lost, but at least this fiscal policy can help enable a more rapid formalization of the diamond sector when peace returns.
Clink here to read the report.
Photo credit: Cristina Villegas
Feasibility of Direct Marketing of Artisanal Diamonds from Liberia and Central African Republic to the USA
ELL, working with Tetratech ARD, supported USAID’s Property Rights and Artisanal Diamond Development (PRADD) project by conducting a feasibility study on nurturing more direct trading relations of rough diamonds from Liberia and Central African Republic (CAR) to the US market. The aim was to consider how to increase the numbers of diamonds into the formal chain of custody through the reconfiguration of incentive structures for artisanal miners. This work fell under the strategic direction of the US government’s work on the Kimberley Process.
The ELL team reviewed legal codes and relevant literature and interviewed jewellers and diamond manufacturers to gauge their interest in and the feasibility of their sourcing more directly from artisanal and small-scale producers in CAR and Liberia. The team assessed factors to setting up successful trading relations between artisanal producers and international buyers and developed scenarios for creating more direct trading relations that are both developmental and commercially feasible. ELL presented its findings to the participants and helped design and facilitate a multi-stakeholder workshop at the US Department of State in Washington D.C.
As of a result of this work, jewelers and manufacturers travelled to CAR to explore the direct marketing opportunities and create trade linkages with artisanal and small-scale producers.
Clink here to see the report
Photo credit: Cristina Villegas
Fairtrade Standard Revision and Facilitated Workshop
Fairtrade International called upon ELL to help them revise the Fairtrade Standard for Gold and Associated Precious Metals for Artisanal and Small Scale Mining. Having solicited feedback from multiple stakeholders, Fairtrade needed expert help to evaluate the comments and revise the production standards where appropriate. Estelle has been engaged with Fairtrade since the inception of product development for gold, having co-authored the product feasibility study in 2006. ELL was pleased to lend its expertise on multi-stakeholder standards and ASM to help Fairtrade develop a “fit for purpose” revised version of the standard.
The ELL team evaluated all of the stakeholder feedback and applied lenses of compliance realities, impact, and commercial demands. The team also recognised and honoured the importance of maintaining the Fairtrade brand integrity across all products when proposing changes to the gold standard. The revised standard was then presented for final feedback at a multi-stakeholder session, which was facilitated by ELL.
As a result of this work, Fairtrade now has a revised version of the gold standard that meets the expectations of miners and their commercial partners which should increase both the number of certified producers and the market for Fairtrade gold. Furthermore the standard has balanced commercial success with benefits for miners. The facilitated workshop helped the stakeholders to understand the changes and learn from each other, which helped to validate both the process and the standards revisions. It also exposed the main barriers to commercialization, so informing Fairtrade’s strategy for getting more Fairtrade gold to market, for the benefit of all supply chain operators and consumers.
Estelle now sites on the Technical Advisory Group for Fairtrade Gold in a voluntary capacity.
AVX Conflict Minerals Management System
AVX is a company that sources tantalum from the DRC that wanted to have a conflict minerals management system for the mining company from which they source as well as the ASM cooperative operating on the mining concession. Green Horizons Environmental Consultants Limited brought ELL into the project because of the team’s experience in ASM and conflict minerals. AVX desired to see this project through as a proof point for the Solutions for Hope conflict-free tantalum initiative.
Leveraging best practice and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, ELL and Green Horizons developed a conflict minerals and customized management system for the concession holder (MMR) and artisanal mining cooperative (CDMC).
As a result of this work, AVX not only has a management system for this supply chain, but also has a framework which can be rolled out across all of its sourcing operations in the Great Lakes Region. This management system meets international best practice, addresses ASM mining practices, and allows AVX – and its customers – source conflict-free mineral from the DRC with confidence.
Clink here to learn more about the Solutions for Hope project.
Photo credit: Rupert Cook
Relating RJC’s Code of Practices to OECD Due Diligence Guidance
The Responsible Jewellery Council recognized the need to help its membership understand how its Code of Practices and Chain of Custody Standard enable conformance with the OECD Due Diligence Guidance. The RJC reached out to ELL to help develop and deliver webinars for upstream and downstream audiences so that their membership might better understand how compliance with the RJC CoP and CoC supports and exceed conformance with the OECD Due Diligence Guidance, and what additional measures may be necessary.
The ELL Team designed a webinar that educated the audience on the issues, benchmarked the different initiatives, and explained in detail the linkages between the RJC tools and the OECD Due Diligence Guidance. These webinars were delivered to more than 100 of RJC members across the supply chain.
ELL helped RJC to eliminate confusion amongst their membership and put forward a clear explanation and path to conformance with the OECD Due Diligence Guidance. These webinars were taped and continue to serve as an educational resource for RJC’s membership.
Development of guidance for self-assessment by governments against the ‘Washington Declaration’
Working with Tetratech ARD on behalf of USAID, ELL created a tool to support the operationalization of the 2012 Washington Declaration on Integrating Development of Artisanal and Small Scale Diamond Mining within Kimberly Process Implementation. The concept of the Washington Declaration Diagnostic Framework is to create a way for member governments of the Kimberley Process’s WGAAP (Working Group on Artisanal and Alluvial Production of Diamonds) – and other stakeholders – to assess their performance against the policy goals set out in the Washington Declaration. These goals include measures for formalisation, as well as social and environmental sustainability.
The tool was developed through deciding first what type of tool would be most useful to ADM country governments, to support the realization of the policy goals of the Washington Declaration. ELL then designed the process by which governments could use the tool, at the same time as identifying categories and associated performance statements for key elements of each policy goal. These ‘indicators’, their descriptions, and examples were developed through document analysis, and close consultation with a range of key experts who are members of the WGAAP. The tool was then presented and workshopped by Tetra Tech at the Kimberley Process meetings in South Afican in June 2013, before its finalization later that year.
ELL designed the tool so that it can be employed in a multi-stakeholder process, and thus stakeholders are included in the performance evaluation of governments. Furthermore, the tool is designed to evaluate performance at a national level so other parties who have a role in bringing development to the artisanal diamond sectors can be assessed in addition to the work of the government. The tool was consulted with WGAAP members and other stakeholders at the KP Intersessional in South Africa in June 2013 and is now available for use.
Clink here for the tool.