Here are a few of our recent news stories.

The GIFF project translated into Spanish

June 13, 2017

Following international interest for its comprehensive and actionable methods, the GIFF project handbook has been translated into Spanish.


The GIFF project handbook in Spanish

‘Sigue el Dinero’

The translated version of ‘Follow the Money: A handbook for identifying financial flows linked to Artisanal and Small-Scale Gold Mining’ unlocks the tools, technologies and methodologies to actors in Spanish-speaking countries. Artisanal and Small-Scale Gold Mining (ASGM) takes place in Argentina, Bolivia, Chile, Colombia, Costa Rica, Dominican Republic, Ecuador, Haiti, Mexico, Nicaragua, Peru, and Venezuela amongst others.

The tool has international appeal regardless of whether ASGM takes places in a country as illicit financial flows (IFFs) are often transnational, with actors spread across value chains globally. The tool is also applicable to minerals besides gold, especially precious minerals such as coloured gems or diamonds.

In April, the American Bar Association’s Rule of Law Initiative, implementing partner for the U.S. Embassy in Lima, Peru, delivered the handbook to police, prosecutors and judges in during their workshop on illegal mining. Participants reportedly found the contents “very useful” – particularly the investigation questions worksheets contained within.

In April, the American Bar Association’s Rule of Law Initiative, implementing partner for the U.S. Embassy in Lima, Peru, delivered the handbook to police, prosecutors and judges in during their workshop on illegal mining. Participants reportedly found the contents “very useful” – particularly the investigation questions worksheets contained within.

Read the Spanish version of ‘Follow the Money: A handbook for identifying financial flows linked to Artisanal and Small-Scale Gold Mining.

The value of the handbook has already been demonstrated in Sierra Leone and Guinea through practical application by the GIFF project and ELL respectively.

Read the case study: Financial Flows linked to Artisanal and Small-Scale Mining in Sierra Leone (English).

The landmark handbook, released in English in March 2017, provides practical tools, techniques, methodologies and pointers for stakeholders seeking to broaden their understanding of and engage with the financial flows linked to artisanal and small-scale gold mining. This includes the identification of illicit financial flows IFF that implicate parts of the sector with corruption, money laundering and organised crime.

The GIFF Project is a collaboration between The Global Initiative Against Transnational Organized Crime and Estelle Levin Ltd., with generous funding from The Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ).

Read the English version of ‘Follow the Money: A handbook for identifying financial flows linked to Artisanal and Small-Scale Gold Mining’ here.



El manual del Proyecto GIFF ha sido traducido al español, dado el interés internacional que han atraído sus métodos comprensibles y viables.

La versión traducida de “Sigue el Dinero: Un manual para la identificación de los flujos financieros ilícitos (IFF) vinculados a la Minería de oro artesanal en pequeña escala” pone las herramientas, tecnologías y metodologías a la disposición de actores en países hispanohablantes. La minería de oro artesanal en pequeña escala (ASGM) ocurre en Argentina, Bolivia, Chile, Colombia, Costa Rica, República Dominicana, Ecuador, Haití, México, Nicaragua, Perú y Venezuela, entre otros países.

El manual tiene relevancia internacional independientemente de si el país cuenta con ASGM, ya que los flujos financieros ilegales (IFFs) muchas veces son transnacionales, con actores a lo largo de las cadenas de valor a nivel global. Éste manual también es aplicable a otros minerales además del oro, especialmente a las piedras preciosas de colores y a los diamantes.

La Iniciativa sobre la Norma del Derecho del Colegio de Abogados de Estados Unidos (American Bar Association’s Rule of Law Initiative), socios implementadores de la embajada estadounidense en Lima Perú, les entregó el manual a la policía, a los persecutores y a los jueces durante un taller sobre la minería ilegal. Los participantes encontraron el contenido muy útil, especialmente la lista de preguntas investigativas que contiene el manual.

Lea la version de “Sigue el Dinero: Un manual para la identificación de los flujos financieros ilícitos (IFF) vinculados a la Minería de oro artesanal en pequeña escala” en español.

El mérito del manual ya ha sido demostrado en Sierra Leona y en Guinea a través de las aplicaciones prácticas realizadas por el Proyecto GIFF y por ELL, respectivamente.

Lea el estudio de caso “Los flujos financieros ilícitos vinculados a la Minería de oro artesanal en pequeña escala en Sierra Leona” en inglés.

Este manual destacado fue publicado en marzo del 2017 y provee herramientas, técnicas y metodologías prácticas para aquellos actores que deseen ampliar sus conocimientos e intervenir en los flujos financieros vinculados a la minería de oro artesanal en pequeña escala. Esto incluye la identificación de los flujos financieros ilícitos los cuales implican a parte del sector en la corrupción, el blanqueo de dinero y el crimen organizado.

El Proyecto GIFF es una colaboración entre la Iniciativa Global contra la Delincuencia Organizada Transnacional y Estelle Levin Ltd., con el generoso apoyo financiero de Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH.

Lea la version de “Sigue el Dinero: Un manual para la identificación de los flujos financieros ilícitos (IFF) vinculados a la Minería de oro artesanal en pequeña escala” en inglés.

Launch of the GIFF handbook and Case Study

March 8, 2017

GIFF Launch

The GIFF project partners – Estelle Levin Limited and the Global Initiative Against Transnational Organised Crime – are proud to release the culmination of many months of discussion and research: ‘Follow the Money: A handbook for identifying financial flows linked to Artisanal and Small-Scale Gold Mining’.

This landmark handbook  provides practical tools, techniques, methodologies and pointers for stakeholders seeking to broaden their understanding of and engage with the financial flows linked to ASGM, including the sub-set of illicit financial flows (IFFs) that implicate parts of the sector with corruption, money laundering and organized crime.

Alongside the handbook we are also releasing our first case study demonstrating application of the handbook’s methodology to analyse the IFFs surrounding the ASGM sector in Sierra Leone, showing its practical application and the importance of financial mapping to a meaningful understanding of ASGM.

To read more about this launch head over to our publications page.

Sector Experts on the GIFF Handbook:

Manuel Papouschek, GIZ
“For GIZ it was important to fund the GIFF Toolkit in order to raise awareness and increase knowledge on illicit financial flows linked to the ASM sector and how they impede formalisation efforts. We hope that the toolkit will serve to effectively mitigate and respond to these specific challenges and barriers to a sustainable use and development of the ASM sector.”

GIFF project director, Estelle Levin-Nally
“S/he who controls the money controls the means. Our aim at GIFF is that this handbook leads to improved due diligence and planning for all actors involved in instituting good governance around and doing better business with the Artisanal and Small-Scale Mining sector. Ultimately, this handbook will help governments, buyers, development agencies and NGOs remove barriers to formalisation and help optimise the opportunities that minerals offer for sustainable development.

Ludovic Bernaudat, Programme Officer, GEF Team, UNEP
“Understanding financial flows in the Artisanal and Small-Scale Gold Mining is key to the development of any intervention to supporting the sector”.

Michael Mesaric, CEO, Valcambi SA
“Through shedding an important light on the significant challenges illicit financial flows pose to the ASGM sector and to its formalization, this publication is a useful tool for gold businesses along the supply chain”.

Fair Luxury 2017 is here

March 8, 2017

This unique two-day event brings together pioneers in the responsible jewellery sector, offering insights from and for both the small retailer and the biggest brands.

The only conference of its kind, FLUX brings together stakeholders across the supply chain here in the UK – the leader of fair luxury and jewelry. We have helped organise and participate in the conference for the second year running to push forward the sustainable luxury agenda.

Come, share, learn and join us in making an impact that will multiply and transcend borders.

FLUX is a two day event. Delegates can book for each day individually or both days together at a discounted rate and can do so by clicking here.


ELL joins Cambridge Social Ventures, to deepen our social impact and do better business with our clients

January 24, 2017

Estelle Levin Limited is delighted to join twelve other businesses in Cohort 7 of Cambridge Social Ventures, a programme in the Centre for Social Innovationof the Cambridge Judge Business School of the University of Cambridge. CSV is dedicated to supporting businesses seeking to make a positive social or environmental impact.

Cambridge Social Ventures offers us a great opportunity to consolidate on recent rapid growth to build resilience into the business and our ventures, whilst ensuring that we maximise our social and environmental impact, fulfilling our mission of helping minerals transform society for good.

The 12-month programme kicked off with a 3-day training event at the Future Business Centre in Cambridge. Informative sessions on measuring social impact, finance, visioning and branding provided a platform for lively discussions and the sharing of experiences with other socially-minded businesses. Our attendees, Estelle Levin-Nally (ELL Director) and Andrew Cooke (ELL Senior Manager) are thankful for this chance to enhance ELL’s business capabilities and have returned empowered to better steer the team towards reaching its highest potential in making a difference. We look forward to cooperating with CSV and the other social entrepreneurs making innovation through impact.

Electronic Industry Citizenship Coalition

January 24, 2017

ELL will be attending the Electronic Industry Citizenship Coalition (EICC) Outreach Meeting in Brussels on January 26th. Come and meet ELL representatives Yolande Kyngdon-McKay and Kate MacLeod who are happy to talk more about our service offerings, experience and thought leadership on responsible sourcing of raw materials.

ELL has been contracted by the European Commission to develop due diligence guidelines on conflict minerals for small-medium enterprises (SMEs). We therefore welcome the chance to talk to participating SMEs and their business partners and associations on how they are managing to implement conflict mineral due diligence as part of our ongoing work for this project.

Other projects that may interest EICC members include:

  • Environmental Profit & Loss accounting for a major consumer brand
  • Due diligence and supply chain management on coloured gems for a major consumer brand
  • Building due diligence systems for the world’s biggest gold refinery
  • Due diligence on child protection issues, including mitigation and remediation
  • Facilitating responsible production systems for African governments
  • Designing the ICGLR mineral tracking database and training ICGLR officials on its implementation

For more information or to arrange a meeting with ELL during the EICC Outreach Meeting, please contact Kate at

Contract Awarded by European Commission

January 20, 2017

Estelle Levin and Edif ERA awarded contract by European Commission to design a conflict minerals due diligence support system for SMEs

Estelle Levin Ltd. (ELL) and Edif ERA have recently been awarded a contract by the European Commission to design a comprehensive support system for EU small and medium-sized enterprises (SMEs) regarding conflict minerals in 2017. The aim is to enhance due diligence capacity in the EU’s SME sector.

Dr Yolande Kyngdon-McKay, Manager at ELL and Project Manager for the contract said, “This is an important and timely piece of work, given the growing trend for developed world governments, NGOs and consumers to demand greater accountability from companies for what happens in their supply chains, including those importing tin, tantalum and tungsten, their ores, and gold originating in conflict-affected and high risk areas.”

The project will involve undertaking research and gathering data from SMEs in the EU that currently import conflict minerals. Working closely with the OECD and other stakeholders, the project team will develop management guidelines for SMEs together with training tools and educational resources.  This will help SMEs to better understand the issues, reconsider their sourcing practices and so make their supply chains more transparent.

Dr Alex Martin, Senior Regulatory Consultant at Edif ERA, added “SMEs are a crucial part of the supply chain of virtually all mineral-dependent industries. Within the EU, SMEs account for 99% of all companies and therefore have a significant role to play in supply chain due diligence. SMEs in the EU need to possess adequate due diligence skills in order to remain competitive both at home, and globally.”

If you have any questions about this project, please email the project manager

Dr Yolande Kyngdon-McKay:

If you are an SME in the EU, involved in importing 3TGs, and would like to participate in this research, please email Dr Alex Martin:

November 2016 Newsletter

November 14, 2016

A lot is happening at ELL and we have several exciting developments to share.


ELL core staff will be attending the following conferences over the next month and would welcome the opportunity to connect with you:

8-10 November
Palo Alto, USA
CFSI Annual Meeting and Conference 2016 Presenting on Tools for Supply Chain Due Diligence Dr Fabiana Di Lorenzo (Presenting)
30 November- 1 December
Berlin, Germany
Conflict Minerals Supply Chain Compliance and Transparency Forum Compliance and Transparency – Responsibility and Efficiency Conference presenting on Prevent, Detect, Respond to Child Labour and Child Rights Risks in Minerals Supply Chains Dr Fabiana Di Lorenzo (Presenting)
22 November London Natural Resources Forum
Rolling Stones: Moss or Momentum? An insight into the Gemstones Industry.
Estelle Levin-Nally
1-2 December
Bogotá, Columbia
OECD Latin American Workshop on Responsible Mineral Supply Chains Olivia Lyster

Optimising the Minerals System: present work

Our present work includes projects in Brazil, Burkina Faso, Colombia, DRC, Ethiopia, Guinea, Liberia, Madagascar, Mongolia, Rwanda, and Switzerland, to name just a few. We continue to drive forward the debate and practices for enabling responsible mining and responsible sourcing from artisanal and small-scale miners of coloured stones, precious metals, diamonds, conflict minerals and rare earths.

Dark Gold HandCredit: Magnus Arrevad

The GIFF Project: ELL, in partnership with the Global Initiative against Transnational Organized Crime, has undertaken this project to provide greater insight into how illicit financial flows (IFFs) are impeding the formalisation of artisanal gold mining.

To read about May’s international dialogue at the OECD, click here
To get different perspectives on IFFs in ASM, read the GIFF blog series, click here
Stay tuned for the release of the GIFF Tool for Intervention in Illicit Financial Flows in Artisanal and Small-scale Gold Mining later this month.
If you want to learn how to take what we’re doing for gold and apply it to other minerals get in touch with Asher Smith
Follow @GIFFProject on Twitter. #FollowtheMoney

Corporate & Private Sector Work: From Brazil to Burkina Faso, ELL is supporting corporate clients with responsible sourcing across mineral categories, including conflict minerals. We are at the cutting edge of due diligence practice providing bespoke, personalised support. We can adapt our tools for precision upstream due diligence across the full range of risks in mineral supply chains, including child labour. If you are looking to improve supply chain sustainability, for a responsible source for your mineral, or need an investor for your responsible mineral initiative, please get in touch with Estelle.

Mineral Sector Development: ELL has completed its project for the Government of Ethiopia to design and deliver training of trainers in responsible mining of salt, gold and gemstones. This month we start work in Guinea conducting diagnostic assessments of their gold and diamonds sectors, and also begin a 4-year project in Kenya on their extractives sector. Our work on good governance and ICGLR database design in the Great Lakes Region continues. Contact Adam Rolfe.

Mining, Minerals & Environment: BEST-ASM and Frugal Rehabilitation: In early 2017 ELL will launch a new initiative to improve the environmental performance of Artisanal and Small-scale Mining. Taking a practical and progressive approach to achieving positive environmental outcomes across all mineral sectors, the BEST-ASM initiative seeks to develop and universalise the application of tools such as the Frugal Rehabilitation Methodology pioneered in Mongolia by the Swiss government’s ESEC II programme. If you are looking to advance best practice in environmental management in ASM contact Andrew Cooke.

Yellow Bucket 1Credit: Asher Smith, 2016
Location: Koinadugu District, Sierra Leone.
Artisanal gold miners spend a 3 hour shift down the mine shaft digging gravel. Full buckets are pulled up to crewmates at the surface.

Just Published!

Exploring the potential in Mongolia’s Jewellery Sector: In 2014, ELL advised GIZ and SDC on how to redirect Mongolia’s ailing jewellery sector towards prosperity, whilst adding value to Mongolia’s gold supply chains. In this report, we explore ways to support Mongolian jewellery design and/or manufacturing by connecting it with international markets.

Ethiopia’s Coloured Gemstones Sector: This study maps the landscape of Ethiopia’s coloured gemstone industry and draws best practices from other key gemstone producing countries, to provide strategic guidance to the Government of Ethiopia on how to leverage its opals for sustainable development.

Ethiopian artisanal minersCredit: Adam Rolfe, 2016
Location: Tigray, Ethiopia
Paying attention Ethiopian artisanal miners pay attention as colleagues teach ELL trainers on the technical training needs of women in this gold community

New Staff

ELL now has 14 core team members, and a growing network of associates to service our clients’ needs. This includes three hires in the last month.

We are pleased to welcome our two new Researcher and Project Assistants: Kate MacLeod who started on the 11th October and Theodora Panayides who started on the 31st October.

We also look forward to welcoming our new Responsible Mineral Sourcing and Development Specialist, Victoria Gronwald who will start on the 5th December.


Our Team is now truly global, with core members based in:

Germany: Contact Fabiana Di Lorenzo

Singapore: Contact Yolande Kyngdon-McKay

Washington, D.C.: Contact Asher Smith

Cambridge, UK Office:
Wellington House
United Kingdom
01223 450 200

Did you know that ELL has staff that are fluent in Arabic, French, German, Greek, Italian, Mandarin, Spanish and Portuguese? We work in other languages too, and through our associates have additional languages from Krio to Bahasa Indonesian. Get in touch!


We are proud to announce:

Estelle has been re-elected onto the Responsible Jewellery Council Committee for another 3 year term. For more information, click here

Estelle was awarded highly commended in the STEM Category of the London & South-east Regional Finals for the National Women in Business Awards, 2016. For more information, click here

Conflict Minerals Supply Chain Compliance and Transparency – Responsibility and Efficiency

October 26, 2016

Establishing reliable and transparent supply chain, developing a responsible sourcing initiative and a sustainable business model of the future, managing Conflict Minerals compliance.

BIS group s.r.o. announces Conflict Minerals Supply Chain Compliance and Transparency Forum taking place on 30thNovember – 2nd December 2016, in Berlin, Germany.

Dr Fabiana Di Lorenzo from ELL will be presenting :   Prevent, Detect, Respond to Child Labour and Child Rights Risks in Minerals Supply Chains at the conference.

The meeting will be focused on the industry and supplier engagement to eliminate conflict minerals, concepts and practice of collaboration among and across industries, methods for thorough but reasonable risk mapping for affected components as well as affected source countries. The Forum will showcase holistic strategic approaches to obtain responsible sourcing and improve existing business-models. Attendees will gain the forefront knowledge of how to build an effective conflict minerals compliance programme and improve supply chain sustainability and transparency.

Main market players will share their ideas and experience throughout 2-day case studies, interactive breakout sessions, workshops, networking & experience exchange.

The small-scale nature of the event, expert speakers and balanced spectrum of attending companies will ensure extensive networking and business opportunities. All attendees have an opportunity for deep involvement and can actively participate in the discussions in order to overcome relevant challenges and have influence on the overall industry development.

About BIS Group s.r.o.

We are the Business Intelligence Services company based in Europe. We believe that knowledge is the most powerful asset, especially, in the context of time and money. This inspires us to work with top professionals, global leaders and experts active in Oil & Gas, Energy, Renewable Energy, Automotive, Supply Chain and Project Management. We are an exclusive platform supporting ambitious, progressive and forward-thinking companies and empowering them with the best market practices for today’s fast changing markets.

For further information

Contact Name: Matyas Ostriz

Company Name: BIS Group s.r.o.

Company Address: Kodaňská 558/25, 101 00 Praha, Czech Republic

Phone:+420 27 000 3436

E-mail address:



Conflict Minerals Supply Chain

Design of the ICGLR regional database on mineral flows

September 25, 2016

The Executive Secretariat of the International Conference on the Great Lakes Region (ICGLR), with the financial support of Partnership Africa Canada (PAC), has commissioned a consultancy to design the architecture of the ICGLR Regional Database on mineral flows, one of the six tools of the Regional Initiative on Natural Resources (Lusaka declaration). Estelle Levin Ltd. (ELL) and the International Peace Information Service (IPIS) have been recruited by the Secretariat to this purpose.

From August 14th to September 9th 2016, two ELL consultants, along with two IPIS researchers, conducted a field mission through the Great Lakes Region to consult representatives of the ICGLR, Member State officials and other stakeholders on existing mineral databases and tracking systems, and critical requirements for the design of the ICGLR regional database. See more at

ITSCi tags on the mining site of Rutongo, Rwanda

ITSCi tags on the mining site of Rutongo, Rwanda

Processing of mineral on the mining site of Rutongo, Rwanda

Processing of mineral on the mining site of Rutongo, Rwanda

Processing of mineral on the mining site of Rutongo, Rwanda

Processing of mineral on the mining site of Rutongo, Rwanda

Bag of mineral tagged for export on the mining site of Rutongo, Rwanda

Bag of mineral tagged for export on the mining site of Rutongo, Rwanda

ELL Director Shortlisted for National Women in Business Awards

July 25, 2016

Estelle Levin Ltd. is proud to announce the shortlisting of our Founding Director, Estelle Levin-Nally, for the National Women in Business Awards. These awards, which were established by Forward Ladies and are supported by HSBC, recognise the achievements of women in a wide variety of industries across the UK. Estelle has been shortlisted in the small and medium-scale enterprise emerging category and the STEM category, due to her achievements running ELL since founding the company in 2010. In that time, ELL has grown into a ten-person core team based in Cambridge, Washington, D.C. and Singapore, and over 50 associates based round the world.

With Estelle’s experienced oversight, ELL offers a broad array of research, advisory, assurance, convening, and capacity building services to stakeholders throughout mineral supply chains, from mine to market. Some examples of recent projects undertaken by the ELL team include: re-developing due diligence systems for the Swiss gold refinery, Valcambi; assisting private sector clients to responsibly source coloured gemstones from high-risk areas; advising the European Partnership on Responsible Minerals (EPRM) on how it could support the trade in responsibly-produced tin, tantalum, tungsten and gold in anticipation of the European Commission’s proposed regulation on conflict minerals; advising the UK Department for International Development (DFID) on how to drive the sustainable development of Rwanda’s mining industry; and training government officials and miners in responsible mining and lapidary for the Government of Ethiopia.

Every project ELL undertakes aligns with Estelle’s goal to help build resilient futures through minerals, ultimately transforming this ‘extractive’ sector into something contributory.

ELL also remains true to Estelle’s original vision and values by driving discourse in the mineral sector on important but challenging topics, including the vulnerability of the artisanal and small-scale gold mining sector to illicit financial flows (via the GIFF Project), for which Estelle is Project Director; and the environmental impacts of the artisanal and small-scale mining sector and how they can be managed (via ASM-PACE).

Estelle recently served as co-chair of the Standards Committee for the Responsible Jewellery Council, is a member of the World Commission on Protected Areas (WCPA) and is an Industry Fellow at the University of Queensland’s Centre for Social Responsibility in Mining (CSRM). She was shortlisted in the Top 100 Conflict Minerals Influencers of 2016.

To see more of the work ELL does under Estelle’s leadership, click here.

To get Estelle’s view on being a woman and running your own business, click here.

For the Forward Ladies Press Release on this, click here.

The GIFF Project

Release of the GIFF International Dialogue Report

July 19, 2016

On 13 May 2016, the GIFF Project held an International Dialogue on links between artisanal and small-scale gold mining (ASGM) and illicit financial flows (IFFs). The event furthered the GIFF Project’s work to raise awareness of IFFs linked to ASGM, increase knowledge on the topic and strengthen responses.

The GIFF Project is pleased to present the GIFF Project International Dialogue Report. This report represents the collaborative work of all attendees to the event. The ideas and themes resulted from robust participation by the speakers and participants. As one of the attendees shared:

“You’re grappling with cutting-edge issues that in my research and some related areas we’re not seeing many people grapple with. This whole issue of how to move from formal to informal, in a context where there are heavy levels of criminalisation and other forms of legalisation.”

The GIFF Project will be releasing all the presentations from the day as a series of blogs. The first blog, by GIFF Project Director, Estelle Levin-Nally, will be available online on the 10 August.

Key Themes and Takeaways included:

  • IFFs impede formalisation. The dialogue confirmed IFFs are a concern for a wide range of stakeholders. Multiple participants, from various geographic regions, gave concrete examples of how IFFs were a direct obstacle to efforts to formalise ASGM.
  • Holistic approaches are needed. ASGM does not happen in a vacuum and is a nuanced topic. To adopt narrow definitions (informal, illegal, etc), lenses, approaches, or partnerships puts responses at risk of being ineffective, and in a worst-case scenario may be damaging to development efforts. Widening how we define and perceive the issue of IFFs in ASM (not only development or crime) and engaging with a range of stakeholder groups is essential.
  • ASGM is a livelihood. Artisanal gold mining is often poverty driven, is a lifeline for vulnerable groups, and can contribute to resilience in rural households and economic development for communities.
  • ASGM is a business. The high-profit, low-risk nature of gold trading makes it appealing to criminal actors who exploit the sector for financial or political gain. The nature of their engagement structures a landscape where human rights violations (e.g. forced labour, child labour, health and safety issues, violence etc.) are more likely. If incentives and pathways towards more formal and legitimate business are not developed for the ASGM sector, criminal actors will continue to take advantage of the marginalised nature of the sector to satisfy their own ends.
  • Better data. There is a huge lack of data and a there was a strong call for more quality research. It is widely acknowledged IFFs are a challenge to formalisation, but more information is needed to better understand how and to develop effective responses. Minerals traceability is important, but not the silver bullet for stopping IFFs. We must follow the money as well as the mineral. Data should not be limited to mapping IFFs, but should examine the motivations of actors and their vested interests in the sector. Engaging local partners is key: they are often the best situated to collect data, contextualise it, and put it to use.
  • Next step: The GIFF Project Toolkit. The GIFF Project will focus the Toolkit on data collection and analysis. The Dialogue highlighted this as a pressing need and offered concrete measures and techniques on how to do so.

All the presentations from the day as a series of blogs, from the 10 August onwards. These include:

  • Categorising Activity and Actors: Informal v. Illicit, Felix Hruschka
  • The GIZ Perspective, Mark Mattner, GIZ
  • Tracking Gold Flows and IFFs, Marcena Hunter, Global Initiative against Transnational Organized Crime
  • Illicit Financial Flows: What can we learn from the Panama Papers?, Khadija Sharife, World Policy Institute
  • Latin America Case Study, Livia Wagner, Global Initiative against Transnational Organized Crime
  • West Africa Case Study, Etienne Atger, BARKSANEM SARL
  • Central Africa Case Study, Shawn Blore, Partnership Africa Canada (PAC)
  • Downstream Industry Perspective, Mike Loch, Responsible Trade LLC
  • The 10 T’s, Estelle Levin, Estelle Levin Ltd.


The GIFF Project would like to thank: GIZ for their robust support – conceptually and financially; Dirk-Jan Koch (Special Envoy for Natural Resources of the Dutch Government) for facilitating, nurturing, and enlivening the discussion; the speakers: who generously presented their findings, expertise, and research at the event; all attendees and participants for their enthusiastic engagement and eagerness to share; and the OECD for kindly allowing us to host this event alongside the 10th Forum on Responsible Mineral Supply Chains on 13th May 2016 in Paris. The event was not possible without such generous, thoughtful, and candid contributions.

Follow the GIFF project on Twitter to stay up to date: @GIFFproject. Please distribute the report through your networks!

If you’d like to be added to or removed from our mailing list, email:


Press release EPRM study

June 23, 2016

Estelle Levin Ltd. is excited to announce the publication of the “Scoping Study on Possible Activities of the European Partnership for Responsible Minerals (EPRM)”. This study was commissioned by the Netherlands Ministry of Foreign Affairs, and was carried out by Estelle Levin Ltd. and Profundo. The report examines the activities that the newly formed European Partnership for Responsible Minerals could undertake to help enhance the trade in responsibly-sourced tin, tungsten, tantalum and gold, also known as the 3TGs. ELL’s recommendations for activities the EPRM could undertake include:

  • Training, supporting and equipping civil society to take part in monitoring, reporting and evaluating issues related to the due diligence and traceability process in an effort to reinforce the voice of civil society, improve accountability structures in conflict-affected and high-risk areas, and render existing efforts more effective, accurate and sustainable;
  • Facilitating the harmonisation of existing responsible 3TG mining and sourcing projects around the world, and supporting their up-scaling whenever possible;
  • Carrying out a review of the measures being taken by businesses and industry associations operating in the UAE to find entry points and incentives to tackle illegal gold trading (from DRC and elsewhere) and promote conformance with the OECD Due Diligence Guidance; and
  • Engaging with the Gold and Illicit Financial Flows (GIFF) Project to better understand Illicit Financial Flows in the gold industry and provide greater insight into this issue to help develop solutions that can improve efforts in the formalisation of the artisanal and small-scale gold mining sector globally.

The full report can be found here.

If you have any feedback or questions, please contact ELL’s project lead on this study, Dr. Yolande Kyngdon-McKay:

ELLs April Newsletter

April 25, 2016

A lot is happening at ELL and we have several exciting developments to share. If you’d like to learn more, or have interesting work we should know about, please get in touch!

Please click  to see Newsletter April 2016

FLUX: Fair Luxury Goldsmiths Centre 19th April 2016

April 21, 2016

Tuesday 19th April saw the inaugural FLUX conference at the Goldsmiths Centre in central London.  Conceived by a group of independent jewellery professionals, FLUX was formed with the intention of creating an open platform for discussion and debate of those issues surrounding ethics and sustainability in today’s jewellery industry.

A packed day of diverse keynote speakers and interactive workshop sessions began with Lina Villa, Executive Director of the Alliance for Responsible Mining in Colombia, responsible for the Fairmined initiative.  Lina shared with an attentive audience her experiences of implementing change through increased standards in mining safety and the positive effect such essential work has had on the lives of the millions of artisanal miners across South America.

Next followed Orsola de Castro – co founder of the global phenomenon that is ‘Fashion Revolution.  Conceived in the wake of the Rana Plaza disaster in which 1,130 Bangladeshi garment factory workers lost their lives, Orsola shared her inspirational journey of just what is involved in flying the flag for sustainability amidst todays seemingly insatiable desire for fast fashion.

Orsola de Castro

Orsola de Castro

Willie Hamilton

Willie Hamilton

Greg Valerio, Estelle Levin, Alan Frampton

Greg Valerio, Estelle Levin & Alan Frampton

Jack Cunningham, Group Sustainability Manager at Gemfields PLC rounded off the keynote speakers with a frank and honest discussion of the challenges faced in gemstone mining and marketing when acting as the model for ethical policy within an industry that has an inherently chequered history of environmental practice.

Woven between these fascinating topics were workshop sessions held by such industry specialists as campaigner, Greg Valerio MBE, responsible sourcing specialist, Estelle Levin and CMJ Chief Executive, Willie Hamilton.

Joanna Hardy

The day’s proceedings where brought to a buoyant close by Antiques Roadshow jewellery expert Joanna Hardy who shared a
light hearted presentation on her recent experiences whilst searching for rubies in Myanmar.This ticketed event sold out soon after launch proving the un-doubtable hunger for such debate within the jewellery supply chain.

The UK really is leading the way in ethical practice within our industry” commented key note speaker Lina Villa. ‘It is always inspiring to come here and see the enthusiasm you have to make real change.’

The overall sense of the day was one of hope and conviction. Delegates and speakers alike shared experiences and knowledge across a broad spectrum of topics – all united by the common belief that advancement is possible and by continuing to communicate and work together we can all play a part in effecting real change.

With a follow on event planned for later this year, FLUX hopes to build on the energy generated and create an evolving and appropriate programme that not only covers those topics felt most in need of debate but also, more crucially, encourages real change through knowledge, collaboration and action.

For further information and a full list of speakers please contact

FLUX are

Team FLUXJane Barnett of Estelle Levin Ltd 
David Crump of Cockpit Arts
Amanda Li Hope of Amanda Li Hope Jewellery
Anna Loucah Of Annaloucah Fine Jewellery
Stuart Pool of Nineteen48
Gary Seneviratne of Nineteen48
Rachel Sweeney of Cox + Power


Special Thanks to Anna Barker and Olivia Lyster from ELL for Registration, Photographs and general running around !

News Item written by Anna Louch for FLUX: Fairluxury

All images © Estelle Levin Ltd


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Press Realease for Due Diligence for Responsible Sourcing of Precious Stones Discussion Paper

April 13, 2016

The Precious Stones Multi Stakeholder Working Group (PS-MSWG) an open nonexclusive coalition of companies, associations, NGOs and governments sharing an interest in responsible sourcing and supply chain due diligence for precious stones, today announced the release of a discussion paper.

The discussion paper looks at due diligence efforts in the precious stone and diamond supply chains

Please click the links to see the  Press Release or Final SRS Report

OECD Insights Blog Features Patience Singo and Estelle Levin

March 30, 2016

OECD Insights Blog has published a piece by ELL Director Estelle Levin and the SAM Project Director, Patience Singo, titled, “What Mongolia’s Artisanal Miners Are Teaching Us: The Link Between Human Rights and Artisanal and Small-scale Mining (ASM) Formalisation.

The blog highlights one of the best examples, globally, of the successful application of a Human Rights Based Approach. This technique builds the political will and capacity of stakeholders – miners, government agents, and communities – to come together to formalise the artisanal and small-scale mining (ASM) sector. Under a Human Rights Based Approach, government agents act on their duty to deliver services to their constituents (in this case, miners) and thus enable them to understand and claim their rights.

The blog also explores Mongolia’s 15-year partnership with the Swiss Agency for Development and Cooperation (SDC) to bring about the Sustainable Artisanal Mining Project (SAM). ELL has been an active contributor in this process since 2014, when Estelle worked with ASM gurus, Dr. Felix Hruschka and Dr. Jennifer Hinton, to design the fourth phase of SAM. Most recently, Estelle facilitated an international symposium kicking off a global knowledge hub on ASM.

For more on Mongolia’s remarkable progress, read the full blog piece here: OECD Insights Blog: “What Mongolia’s Artisanal Miners are Teaching Us: The Link Between Human Rights and Artisanal and Small-scale Mining (ASM) Formalisation”

You can learn also more about ELL’s work with the SAM Project and with Mongolia’s artisanal mining sector, here:

Marketplace of Ideas & Mongolia’s Best Practice

Global Trends in ASM: Mongolia

Ninja miners and rural change in Mongolia

SDC’s Sustainable Artisanal Mining (SAM) Project

The GIFF Project

Gold and Illicit Financial Flows Project – Fundraising for Regional and Local-Dialogues

March 24, 2016

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:

Artisanal and small-scale gold mining (ASGM) accounts for 16% of world supply and is an important livelihood for tens of millions of people . Much of ASGM production is informal and unregulated, creating a sector vulnerable to criminal influence and IFFs – and resistant to formalisation.

  1. Raise awareness and understanding of IFFs and criminal networks in gold supply chains;
  2. 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
  3. 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.

Please see our Dialogues Concept Note

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Flux: Fair Luxury

March 14, 2016

Jane Barnett ELL’s Office Manager is proud to be part of the organising committee for the Flux: Fair Luxury Conference. This one-day event offers all in attendance the opportunity to further understand what is meant by ‘responsible practice’ and discuss the need for transparency within the prestigious setting of London’s Goldsmiths’ Centre.

Pioneering figures from across the worlds of jewellery and fashion come together in offering the rare chance to share in their experience. Hear first-hand from industry leaders currently questioning the way we approach provenance and sustainability by examining the journey between original source and end consumer.

WHAT: The UK’s first conference-style event dedicated to debating and investigating issues surrounding responsible sourcing and best practice within today’s jewellery industry.

WHERE: The Goldsmiths’ Centre

WHEN: 9.30am – 5pm Tuesday 19 April 2016

Key note speakers include:

Lina Villa – Executive Director Alliance of Responsible Mining (ARM) Jack Cunningham – Group Sustainability Manager Gemfields Orsola de Castro – Co-founder of Fashion Revolution Delegates are then invited to participate in workshops covering three key topics from jewellery’s mine-to-market supply chain:

Fine Grain

  • mining, sourcing and importing;
  • design, production and manufacturing;
  • retail, selling, marketing, PR and press/media.

Estelle Levin will be co-hosting on of the mining, sourcing and importing workshops.

As FLUX (short for Fair Luxury) we aim to present delegates with an arena in which to discover and debate key issues of best practice surrounding today’s jewellery industry.

This day will encourage a vital and dynamic platform, providing an atmosphere of collaboration between open-minded individuals who wish to be a part of something truly trailblazing.

So come and be a part of this inaugural event – join us in questioning, challenging and facilitating progress, achievement and change.

Tickets are now sold out for this event.


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ELL Joins Global Mercury Partnership

February 4, 2016

ELL is pleased to announce its acceptance into the Global Mercury Partnership. As a member, ELL will focus on contributing to the Partnership’s artisanal and small-scale gold mining stream.

Most recently, this included Director Estelle Levin presenting and serving as a roundtable co-chair at the December’s “Miners, Minerals, and Minamata” International Research Conference hosted by the Centre for Artisanal Mining Innovation at the University of British Colombia in Vancouver, Canada. About the intersections between ASM and Mercury, Estelle reflected:

[The impacts of mercury are devastating for artisanal miners and their communities, but are also felt in global fisheries, thereby affecting all of us. ELL hopes to help the Global Mercury Partnership in a number of ways: getting the importance of trading and commercial logic upfront in the push for ASM formalization, and leveraging our expertise, network, and projects to ensure mercury management and elimination opportunities are realized and implemented across all our work.]

The UNEP Global Mercury Partnership is a voluntary and collaborative relationship amongst various parties, in which all participants agree to work together in a systematic way to take immediate actions to achieve the goal of the UNEP Global Mercury Partnership. Established in 2008, the partnership supports immediate actions on mercury in parallel to the negotiations of a mercury convention.[1]

The overall goal of the UNEP Global Mercury Partnership is to protect human health and the global environment from the release of mercury and its compounds by minimizing and, where feasible, ultimately eliminating global, anthropogenic mercury releases to air, water and land. [2] You can learn more about the Partnership, here: UNEP Global Mercury Partnership Website

[1] UNEP GMP, 2015
[2] UNEP GMP, 2015

Social Terrain – Estelle Levin Ltd. Impact Investment Partnership

November 16, 2015

ELL is delighted to announce a new partnership with Social Terrain.

Social Terrain is an impact investment firm, driving social change by coordinating businesses and investors to address intractable development and social problems.

Estelle Levin Ltd. (ELL), as one of the world’s leading consultancies on artisanal and small-scale mining (ASM) and responsible sourcing, is deeply familiar with the persistent challenges of the mineral sector. Together, we will bring together leading businesses, governments, NGOs, communities and stakeholders around our shared resolve to overcome these challenges and bring about resilient futures for miners and their communities.

The challenges facing the mineral sector are significant. There are serious structural and cultural impediments that must be tackled, not least poverty; an oversimplification of issues; and a caricaturist demonisation of ASM as the worst of all evils. These are issues we care deeply about. If ASM is to be a source of positive development and its negative social and environmental consequences are to be addressed, we can’t do it alone. No one entity can solve these problems on its own.

Together, ELL and Social Terrain will drive positive impact and effective solutions turning the mineral sector’s numerous challenges into opportunities for shared benefit and positive social change.

ELL is supporting the development of DRC’s tourmaline industry

November 2, 2015

This gorgeous gemstone comes in virtually every colour under the sun, and individual gemstones can be bicoloured or even multicoloured. Tourmaline is one of ELL’s favourite gemstones! In fact, we love it so much that we’re working to establish an OECD Due Diligence Guidance conformant source of tourmaline from the Democratic Republic of Congo.

In February our researchers visited the DRC mine we’re working with and saw some tourmaline rough in a gorgeous array of pinks, purples, and greens, including a highly prized bicoloured “watermelon” piece.

We’re looking for parties interested in helping with the establishment of this ground-breaking ethical sourcing initiative, and cutters/polishers and jewellers who may wish to sample and buy some of the gorgeous tourmaline coming from this mine.

For more information, please contact ELL consultant Yolande Kyngdon-McKay at

Dr. Abdul Haris

October 14, 2015

It is with great sadness that ELL marks the passing of one of our Associates, Dr. Abdul Haris.

Abdul’s work in the fields of chemical engineering, development, and mining technology made him a leader in his field.

His more recent work, in artisanal gold mining and tin, gave us the opportunity to work with this remarkable man. For this, we are most grateful. 

We extend our condolences to Abdul’s family and friends, wishing them solace and strength during this difficult time.

ELL Seeking Senior Manager

October 8, 2015

ELL are currently seeking a proactive and highly organised Senior Manager to manage diverse client relations, oversee sales, deliver high quality projects, and provide leadership to members of our dynamic, highly skilled team. The individual will share our vision and values, thrive in a collaborative, fast paced environment, and bring substantial expertise to help us drive greater impact for our clients.

If you are interesting in joining us please see the detailed job description here

Accra. Antalya. London. Scotland. California

September 29, 2015

This month, ELL Associates and Staff are presenting at events across four continents. We’d love to connect with you.

If you’ll be attending – or would like to learn more –do get in touch!



* 1. Associate Daniel Fahey presented ELL research on due diligence activities on small and medium sized enterprises (SMEs) at the EICC Responsible Electronics conference 2015. The research, led by Dr. Yolande Kyngdon-McKay highlights how SMEs are managing conflict minerals reporting and provides recommendations to improve performance.  Dan also moderated a panel on impacts to date of responsible sourcing in the Great Lakes Region.

“The conference highlighted progress in conflict free sourcing” Dan reported “but also demonstrated that many companies continue to struggle to get quality information from suppliers and smelters about conflict minerals, leading to concerns about compliance with due diligence requirements.

Another key discussion theme was the new Chinese due diligence guidelines. For more information on these, see ELL’s blog on the CCCMC, here.



*2. Researcher, Angela Jorns, spoke at the Fairphone Launch Event in London on Sunday 27th September. The Launch, part of the London Design Festival, will include a pop-up space allowing the public to take apart the symbol of progressive electronics – by opening up the phone and learning about its components and their supply chains.


ghana conference

*3. Kathleen Charles will be at the Africa Dubai Precious Metals Forum (ADPMF) 2015 on 28th – 29th September. The event, “Dubai and Africa Rising Together”, aims to strengthen the relationship between precious metals market participants in Africa and Dubai.

“The conference will be an excellent opportunity to bridge the gap between the financial and technical worlds of artisanal mining. While these gaps are almost non-existent in the real world, they are all too often gaping at the policy and discourse levels.”

Kathleen is presenting on Transaction Finance for artisanal gold sector at large, as well as the potential for Public Private Partnerships to transform the artisanal mining sector.



*4. Adam Rolfe will be presenting at the Meech Symposium of the Sustainable Industrial Processing Summit & Exhibition in Antalya, Turkey next week, 5-10 October. The Symposium honours the memory of Professor John Meech, a fixture in the sustainable mining field whose career positively impacted a broad range of technical, environmental, and socio-political issues related to mining. ASGM will be a strong theme at the symposium.

Adam’s presentation will highlight ELL’s unique approach to responsible sourcing of minerals and ASM, and present the attendees with challenging and innovative ideas on the topic.

That ASM has been afforded such a central role at the 2015 summit demonstrates just how far the mining discourse has come –in no small part due to the work of John Meech.” Adam went on to say that, “This is a great opportunity for some of the biggest thinkers in ASM to build on Prof. Meech’s work and focus the energy around the issue in development circles today.”



*5. Meanwhile, last weekend, having delegated all speaking responsibilities to our talented team, our Director helped raise £1,000 for Macmillan Cancer Relief by participating in a bingo afternoon with her favourite aunties and uncles in Scotland. Estelle said, “There’s nothing more enjoyable than being with all my old aunties, eating cake, and winning prizes. Thank goodness ELL is growing.”


Published BGR/ELL report – “Assessing and Enhancing the Contribution of Small and Medium-scale Enterprises to Due Diligence for Responsible Mineral Supply Chains”

August 18, 2015

This study is an examination of how small and medium-scale enterprises (SMEs) in the jewellery, medical technology, automotive and electronics industries in Europe, the United States of America and China are managing their “conflict minerals” reporting and/or due diligence requests and/or obligations. It was commissioned by the German Federal Institute of Geosciences and Natural Resources (BGR). ELL researchers used survey and interview research methods to gain an understanding of the key challenges faced by SMEs in relation to conflict minerals, what large-scale companies and industry associations have observed within their own respective SME supplier groups and memberships, and which efforts have ameliorated SME limitations in this field of compliance.

To review the report please click here

ELL Associate’s Degree Capstones Over a Decade of Mining Expertise

August 6, 2015

Congratulations to ELL Associate Alain Chishugi, who recently graduated with a bachelor’s degree in Environment and Community Health from the Open University of the Great Lakes Region in Bukavu. He passed with Honours (Distinction).   Alain has worked as a Congolese mining consultant for over ten years, publishing works such as ‘Les défis enquêtant sur la situation de l’exploitation minière artisanale et a petite echelle dans la Reserve Naturel d’Itombwe, au Sud-Kivu, RDC’, for ASM-PACE in 2013.

As ELL’s leading Associate in the DRC, Alain works in and on supply chains of minerals in the Great Lakes Region for industries, development agencies, and civil society organisations. Alain has conducted intensive field research in the areas of gold, tin, coltan, and the wolfram in harsh situations in DRC, as well as the coordination of studies and initiatives including the Durban process.  Alain frequently works on highly sensitive issues for ELL, such as illegal mining in protected areas and the cohabitation of artisanal mining and industrial operations in fragile post-conflict settings.

All of us at ELL join Alain in marking this important achievement.

 “Alain is a great field researcher and companion, always happy to provide valuable advice and insight, and very talented in getting things done in difficult contexts – he always knows a way.  Moreover, his calm and considerate personality makes him a pleasure to work with!”   Angela Jorns, Researcher

Alain is courageous and tenacious, but he is also gentle and wise. He gets the different perspectives and interests at stake. He fundamentally works to improve the situation of his fellow Congolese, as well as the non-human beings who share their habitat. I value his friendship and collegiality immensely and am really proud of his achievement in getting this degree. Now I’m sure he’ll have even more to teach us at ELL!”  Estelle Levin, Director

Fairtrade International announced changes to the Fairtrade Standard for Gold and Precious Metals

April 29, 2015

Last week, Fairtrade International announced changes to the Fairtrade Standard for Gold and Precious Metals. The revisions include progressive safeguards on conflict minerals, increased social and environmental protections, and further empowerment of workers to participate in decision-making processes.

The new Standard is the result of a stakeholder-rich process in which ELL has been pleased to take a part. Throughout 2014, ELL collaborated with Fairtrade to determine a pathway to harmonise the Standard with the OECD Due Diligence Guidance and other conflict minerals initiatives. This included engaging directly with the initiatives, presenting proposed revisions, and managing comments from public consultation processes. Meanwhile, ELL has been supporting Artisanal and Small-Scale Mining Organisations (ASMOs) and Fairtrade Producer Support Units in Kenya, Tanzania, and Uganda through the development and delivery of toolkits, checklists, and training.

To learn more about the Fairtrade Standard for Gold and Precious Metals, check out this Webinar co-chaired by ELL Director Estelle Levin and Amy Ross of Fairtrade Gold which provided an overview of to key stakeholders. You can also learn more about the revisions at Fairtrade Standards.

Revisiting the Conflicts Minerals Rule

February 12, 2015

Companies listed in the U.S. are required by Section 1502 of the Dodd-Frank Act to report whether they manufacture products that incorporate so called conflict minerals (defined as gold, tin, tungsten and tantalum coming from the Democratic Republic of Congo and its neighbouring countries).

Estelle Levin, in conjunction with McGuireWoods partners Yves Melin and Alex Brackett recently co-authored an article that reviews and assesses the impact of the conflict minerals rules of Dodd-Frank, summarizes the proposed European Commission rules for the EU, compares the EU proposal with the U.S.’s Dodd-Frank, and critically reviews it in view of its stated objective.

In the authors’ opinion, the EU proposal helps improve the ability of operators to perform due diligence of their supply chain. But, it does not contain any meaningful incentive meant to foster the responsible sourcing of minerals from conflict areas. If adopted as such, the proposed EU rules are likely to result in the same embargo as the one Dodd-Frank created, but for the EU this time, and for potentially a lot more countries than the African countries targeted by Dodd-Frank.

To view the full article, click here.


Survey on the contribution of SMEs to due diligence for responsible mineral supply chains

February 11, 2015

Assessing & Enhancing the Contribution of Small and Medium-scale Enterprises to Due Diligence for Responsible Mineral Supply Chains

The German Federal Institute for Geosciences and Natural Resources (BGR) with the support of the Organisation for Economic Cooperation and Development (OECD) has initiated an important new study titled: “Assessing & Enhancing the Contribution of Small and Medium-scale Enterprises to Due Diligence for Responsible Mineral Supply Chains”. The background to this study is the growing importance of due diligence in “conflict minerals” supply chains (gold, tin, tungsten and tantalum), and the anticipated challenges facing SMEs in the automotive, electronics/ICT, medical technology and jewellery industries in fulfilling due diligence recommendations and requests.

The objectives of this study are fourfold. It will:

  1. Ascertain how “conflict minerals” due diligence is implemented by SMEs today, and why it is sometimes eschewed by these companies;
  2. Determine the common challenges and successes experienced by SMEs in performing due diligence;
  3. Draft recommendations for SMEs on implementing due diligence, and present best practice examples to encourage and inform the broader implementation of due diligence by this sector;
  4. Encourage governments, international organisations and industry partners to initiate supportive action for SMEs in their conflict minerals due diligence, and inform the ultimate content of this support.

If you are a company in the automotive, electronics/ICT, medical technology or jewelry industry that meets the definition of a small or medium-scale enterprise (<250 employees and <€50 million annual turnover), please click here to participate in the study’s confidential survey of “conflict mineral” due diligence activities in SMEs. This survey is also available in German, French and Mandarin, and will take between 10-35 minutes to complete, depending on your answers. You can also elect to participate in a follow-up interview to further discuss due diligence activities in your company. The survey will remain open until the 10th of April 2015.

If you are an industry association or large-scale company in one or more of the above mentioned industries, please disseminate this study to the SMEs in your membership groups or supply chains using the ‘SME email template’ in this shared folder, which is available in English, German, French and Mandarin. If you would also like to participate in a 30-minute interview on the issue of “conflict minerals” due diligence, please email the study’s lead researcher, Dr. Yolande Kyngdon-McKay of Estelle Levin Ltd (ELL) before the 24th of April to schedule a time:

The information collected in this study will be used to inform the development of targeted policy and programs to assist SMEs in their implementation of “conflict minerals” due diligence, which will ultimately benefit all stakeholders in mineral supply chains.

ELL to co-host Webinar: “An Overview of the Fairtrade Standard for Gold and Precious Metals

January 28, 2015

Estelle Levin Ltd. is pleased to announce that it will be co-presenting a Webinar providing “An Overview of the Fairtrade Standard for Gold and Precious Metals” as part of the Schulte, Roth and Zabel Advanced Conflict Minerals Rule Compliance Series. The webinar will be conducted in partnership with Fairtrade.

Amy Ross (Fairtrade) and Estelle Levin (ELL) will provide a detailed overview of the Fairtrade Standard for Gold. Amongst other things, they will examine how the standard can seek to resolve important problems facing gold miners, including; how to tackle complex and non-transparent supply chains and the often hazardous working conditions in which gold miners ply their trade.  They will also consider how the evolution of the Fairtrade standard for gold has reinforced workers’ rights by introducing wage minima, strengthening miners’ organisations, improving working conditions, supporting collective bargaining and drawing a line under the use of hazardous chemicals. We will also consider the development of the standard as we look towards the future: How can we improve the existing standard? How can we encourage adhesion to its core principles? In what ways can we strengthen local and international support for Fairtrade gold?

We will be on hand to answer any questions you may have in a live Q and A session at the end of the Webinar.

Be part of something big: join the debate, inform the debate…

This talk is free to join and all are welcome! Participants from the following backgrounds are particularly encouraged to join the discussion: Conflict Minerals Rule compliance, including legal, CSR, EHS, sustainability, finance, IT, manufacturing, procurement and engineering personnel.

When: Thursday, February 19th, 2015

Time: 12:00 -12:45 pm ET

Where: Online Platform

Register here before Wednesday, February 18th, 2015, 12:00 ET 

 For more information about the Fairtrade Standard for Gold you can also visit the Fairtrade website 


ELL to co-host discussion at World Parks Congress 2014

November 3, 2014

Estelle Levin Ltd. is excited to announce our co-hosting of the upcoming 2014 World Parks Congress discussion ‘Mining in Protected Areas and Critical Ecosystems: Managing the environmental impacts of artisanal and small-scale miners and industrial producers‘. In partnership with the South Australian Department of Environment, Water and Natural Resources, ELL will consider obstacles to the effective management of mining activities in protected areas and critical ecosystems. This discussion will examine the economic motivations and environmental harms of different production spheres in the mining industry, including the ASM sector and industrial producers, and analyse possible methods for ensuring the integrity of protected areas in the face of actual and potential mining activities.

The ultimate goal of this discussion is to reach an agreement to form a task force that will assume the important ongoing work of ASM-PACE and facilitate more effective management of protected areas into the future.

When: Tuesday 18 of November
Time: 10:30am – 12:00pm
Where: Protected Planet Pavilion, World Parks Congress, Sydney, Australia

For further information, please contact:
Yolande Kyngdon-McKay: yolande(at)
Jason Irving: jason.irving(at)

Video Interviews on Ape Conservation and Extractive Industries

October 14, 2014

The Arcus Foundation has published several video interviews on ape conservation and extractive industries to go with the recently published book ‘State of the Apes – Extractive Industries and Ape Conservation’. In one of the interviews, ELL director Estelle Levin speaks about artisanal and small-scale mining (ASM) in protected areas and critical ecosystems (PACE) and reflects on the book as a starting point for action. You can watch the video of the interview here:

The book itself, is the first in a biennial series published by Cambridge University Press. It brings together contributions from a range of experts to present an overview of how extractive industries inter-relate and affect the current and future status and welfare of great apes and gibbons. ELL contributed a chapter on ASM, proposing various strategies to mitigate ASM’s impacts on ape habitats. A summary can be found here:​.

Our ASM PACE studies on GabonDRCLiberia and Sierra Leone​ all feature issues of ASM in great ape habitat.​


Blog series ‘Living in the Shadows of Ebola’

October 7, 2014

I am excited to announce a series of blogs called ‘Living in the Shadows Ebola’, that our associate Babar Turay will be writing on the effects of ebola on Sierra Leone, and in particular its diamond mining district of Kono.

The first blog of the series has just been published, and you can read it here.

In 2004, I travelled to Sierra Leone to do research for my UBC Geography Masters thesis, “From Poverty and War to Prosperity and Peace? Sustainable Livelihoods and Innovation in Governance of Artisanal Diamond Mining in Kono District, Sierra Leone.” I worked closely with Babar Turay, to whom I owe much of my understanding of the culture and political economy of diamond supply chains in West Africa as well as my passion for the people of Sierra Leone. Based on a strong friendship and enjoyable working relationship, Babar and I have worked repeatedly together for a breadth of clients including the Diamond Development Initiative, Target Resources, Transfair USA, the ASM-PACE programme, and others, and I have freely proposed him to others to include in their work knowing the quality of his work.

In 2007 my (now!) husband, David Nally, accompanied Babar and me in our work to scope possibilities for establishing Fairtrade and Fairmined gold ASM organisations in the country for the Alliance for Responsible Mining, kindly facilitated also by the Foundation for Environmental Sustainability and Security. David is a human geographer at the University of Cambridge with research interests in international development and the politics of agrarian change. He and Babar had much to learn from each other (not least on how to get the best out of me!). I would like to thank David for helping to edit this blog by Babar.

Babar now works for USAID and on occasion for ELL. He is living with the horrors of ebola all around him and with the fact of no work since his employer has pulled their programme. He has written this blog to help us understand what it is meaning for him personally, but also for his society. Please pass it on.

Thank you, Estelle

ELL Consults the Zoological Society of London on Extractives Activities in World Heritage Sites

October 3, 2014

Estelle Levin Ltd. (ELL) is excited to announce our new project with the Zoological Society of London (ZSL), which examines the extractives industry’s impact on World Heritage Sites and ascertains its willingness, on the aggregate, to strengthen no-go commitments for such properties.

ZSL has recognised that the activities of the extractives industry can pose significant threats to the conservation of WHSs and other protected areas around the world. These threats are likely to grow in line with the world’s ever-increasing demand for mineral and hydrocarbon resources.

While there are companies in the extractives sector that have made no-go commitments for WHSs, including the 22 member companies of the ICMM, Shell, and Total, the industry has not uniformly adopted and operationalised such policies. This is also the case for the financial sector—while many banks, including JP Morgan Chase, Goldman Sachs and Morgan Stanley, have instituted policies that preclude lending to extractives companies if their operations occur within or directly impact WHSs, many are yet to do so.

In initiating this research project, ZSL has acknowledged that much still needs to be done to advance greater cross-sectorial support for the World Heritage Convention across the spectrum of relevant stakeholders, and further advocate no-go commitments within the extractives industry. Such progress can be facilitated via the examination of environmental impacts and the surveying of stakeholder perspectives on extractives activities in WHSs, to identify key challenges and build consensus around potential solutions to safeguarding the integrity of WHSs and other protected areas.

ELL and ZSL will be surveying extractives companies and financial institutions during this research. We also encourage other interested stakeholders, including the general public, to have their say on how much space should be allocated to nature, by completing the short ‘Space for Nature’ survey:

ELL and Enventure Technology Services announce their strategic collaboration to deliver conflict minerals solutions from mine to market.

September 24, 2014

Specialist consultancy firm Estelle Levin Ltd. (ELL) and Enventure Technology Services, one of the world’s leading providers of data management solutions, are excited to today announce their collaboration in the delivery of end-to-end solutions to assist companies meet their conflict minerals compliance obligations. This collaboration supports ELL and Enventure’s mutual ambition to empower upstream and downstream stakeholders to successfully and efficiently fulfill their compliance obligations and greater corporate social responsibility mandates.

ELL has joined with Enventure to provide conflict minerals compliance services to Enventure’s current and future clients, including: Dodd-Frank compliance services; gap analyses; compliance roadmaps; conflict minerals training, audits and reporting; supply chain due diligence and OECD DDG conformance; and risk assessment and management. This collaboration is perfectly timed. An increasing number of companies around the world are contending with current or impending conflict minerals compliance obligations. In the United States, approximately 6000 SEC-reporting companies were required to report their Reasonable Country of Origin Inquiry findings by 2nd of June 2014, and many have since been required to conduct additional supply chain due diligence. On March 5th, the European Union proposed regulations for the responsible importation of tin, tungsten, tantalum and gold, which will likely soon place due diligence requirements on EU-based companies. Demand for the high-quality services provided by ELL and Enventure Technology Services is therefore both immediate and ever growing, and this exciting new partnership renders both firms perfectly poised to assist companies fulfill all of their conflict minerals compliance obligations.

Enventure has assisted several US corporations to meet the conflict mineral compliance declaration deadline of 2014. Enventure has conducted several supplier education webinars and has audited several thousands of suppliers on identifying the reasonable country of origin of the conflict minerals present in their product lines.  There is a big gap in the industry to establish a strong process for due diligence as per the approved global frameworks.  The Estelle Levin Ltd.-Enventure Technology Services collaboration will address this gap and simplify the process of due diligence for clients.

For more information on Enventure Technology Services please see our partners page or

ELL: Yolande Kyngdon-McKay at

Enventure Technology Services: Abhishek at

ELL and Bureau Veritas (Italy) offer conflict minerals training for the jewellery sector

September 22, 2014

This training will help your organisation understand what responsible sourcing means for you. Taking a broad view of responsible sourcing, it will use ‘conflict minerals’ as a case study to help companies consider how risk management can mean commercial advantage. It will illustrate the risks related to minerals originating from conflict-affected and high-risk areas and present the best practices to manage such risks, according to internationally recognized schemes. It will help you develop or reconceive your responsible sourcing strategy to achieve higher social impact to greater commercial advantage.

This 2-days training course will start on Thursday,  the 27th of November and finish on Friday, the 28th of November. The course will be held at Grand Hotel Villa Torretta, a prestigious noble residence located on the outskirts of Milan. Participants accommodation, including meals and overnight stay, is arranged in the venue as well.

For more information on the training and how to enroll, please see our LEAFLET and Bureau Veritas’ training description

The deadline for confirming participation and registration is: Monday 3rd November 2014

Bureau Veritas (BV), is a world leader in inspection, verification, and certification services, see our partners page for more details


Photo Credit: Alain Chishugi

Fairtrade launches public consultation on the Fairtrade Standard for Gold and Precious Metals

September 17, 2014

Fairtrade has just published a revised version of the Fairtrade Standard on Gold and Precious Metals for public consultation, and invites all interested stakeholders to submit comments and suggestions.

The revised version of the Fairtrade Standard introduces a new set of requirement helping miners and traders (including downstream buyers) demonstrate conformance with conflict-mineral regulations, particularly the recommendations of the OECD Due Diligence Guidance and the requirements of the Dodd-Frank Act, Section 1502 (law applicable to U.S. issuers) and draft E.U. Regulation.

Furthermore, a few changes are made to certain requirements to ensure the standard is constantly adapted to the Artisanal Small-Scale miners’ realities and needs. These changes relate to the participation of workers in the governance of mining organisations, traceability requirements, the use, management and eradication of toxic substances, and the protection of human rights.

The consultation was launched this week and feedback is welcome until the 17th of October:

Further background information on the Standard Revision is also available here:

Apologies for any cross-postings. Please distribute widely.


ELL helps develop Guidelines for Extractive Industries and Biodiversity Conservation in the SADC Region

September 10, 2014

ELL has conducted a Regional Assessment of Biodiversity Conservation and Extractives Industries in Eastern and Southern Africa for IUCN Kenya and the Biodiversity and Protected Areas Management Programme (BIOPAMA).

The ultimate goal of the project was to develop a discussion paper that explores the key challenges facing SADC (Southern African Development Community) member states in their regulation of the environmental impacts of the extractives sector. The resulting discussion paper provides insights into what actions these countries could take to facilitate the strategic protection of domestic and intra-regional biodiversity. The final discussion paper is now available for download here.

ELL’s work on this project included the following:

  • Collating best practice examples and lessons learnt in relation to the regulation of the environmental impact of the extractives industry with a particular focus on the SADC (Southern African Development Community) region;
  • Examining case study examples of extractives industry governance;
  • Identifying gaps in current policies and legislative frameworks related to extractive industries and biodiversity in the region;
  • Examining case study examples of best practice extractives industry responses to environmental conservation in the SADC region;
  • Developing a foundational document that will inform the content of the Regional Best Practice Guidelines for the Exploitation of Mineral and Hydrocarbon Resources in the SADC Region

The findings of the study will be presented at the SADC Regional Workshop, organised by BIOPAMA and the SADC Secretariat, which will be held in Johannesburg on 2-4 September 2014 and will be attended by representatives from all SADC member states. The workshop will gather further input on the draft guidelines from governments, industry and civil society, and will aim to find mutually acceptable solutions, considering a whole range of interests, such as mineral and hydrocarbons extraction, job creation and poverty alleviation, as well as biodiversity conservation.

You can find out more about the programme and the workshop here.

ELL consults international stakeholders on mineral traceability and certification in DRC

July 24, 2014

(Version française ci-dessous)

ELL has just begun work with the PROMINES project of the government of the Democratic Republic of Congo to study mineral traceability and certification systems in the country.

As part of this project, we are engaging international stakeholders (downstream industry, certification and traceability systems beyond DRC, EU, US and regional legislators, civil society, as well as donors and multilateral bodies) in a series of consultations, including right now, at the very outset.

We want to know what needs changed from the people affected by mineral traceability and certification systems in DRC to ensure that downstream industry can source tin, tantalum, tungsten and gold from DRC with confidence, but in ways that is a.) possible for DRC to achieve and b.) aligned with the ICGLR’s Regional Certification Mechanism.

We would like to invite you to participate in these consultations. Here is our main question:

What do you consider to be the main issues around mineral certification and traceability in DRC, and what should be done to address these?

Need more help? Here’s more questions to inspire you. How can existing (or potential) initiatives be made more feasible, more credible, more cost-effective, and more aligned with what international legislation, the ICGLR RCM and/or the OECD Due Diligence Guidance require? What is working that can be built on? What is not working that must be changed? What opportunities exist that we may not be aware of and may wish to learn more about? Who else should we be talking to? What experiences do you have that could inform our research and guide the Government of DRC’s decision-making on this?

If you would like to participate and share your views, please respond in as little or as much detail as you have time for, emailing your ideas to info(AT) by Tuesday July 29th or as soon after as you can manage.

We want to ensure your views guide our field work in DRC, which begins on August 4th. Your opinions will be presented to the Government of DRC during our planning meeting next week and in subsequent meetings and reports, in line with your preferred level of attribution. In your e-mail please let us know if you are you willing to be:

  • Cited and named in our report to the client, or
  • Cited and identified by affiliation (e.g. refiner, donor, international NGO, certification initiative, etc.) in our report to the client, or
  • Totally anonymous

NOTE! This is not your only opportunity to participate! We will be carrying out more detailed consultations with international stakeholders based on initial findings in August and September. Let us know if you’d like us to contact you then.

Thank you very much in advance for your participation and input! Please feel free to forward this to anyone else who might have a valid opinion.

You can find out more about this World Bank and DFID funded project here.


ELL vient de commencer un projet avec PROMINES du gouvernement de la République Démocratique du Congo pour étudier des systèmes de traçabilité et certification de minerais dans le pays.

Dans le cadre de ce projet, nous engageons des acteurs internationaux (industrie en aval, initiatives de certification et de traçabilité au-delà de la RDC, les législateurs de l’UE, les États-Unis et régionaux, la société civile, ainsi que les donateurs et les organismes multilatéraux) dans une série de consultations, y compris à l’heure actuelle, dès le début du projet.

Nous voulons savoir ce qui doit changer pour les personnes touchées par les systèmes de traçabilité et de certification des minéraux en RDC, afin d’assurer que l’industrie en aval peut se procurer l’étain, le tantale, le tungstène et l’or de la RDC avec confiance, mais d’une manière qui est a) Possible pour la RDC à atteindre et b.) alignée avec le Mécanisme Régionale de Certification de la CIRGL.

Nous aimerions vous inviter à participer à ces consultations. Voici notre question principale:

Qu’est-ce que vous considérez les principales questions autour de la certification et la traçabilité des minéraux en RDC, et qu’est-ce qu’il faut faire pour remédier les problèmes?

Besoin d’aide? Voici plus de questions pour vous inspirer : Comment peuvent initiatives existantes (ou potentiels) être rendues plus possible, plus crédible, plus rentable, et plus conforme à ce que la législation internationale, le MRC de la CIRGL et / ou le guide OCDE sur le devoir de diligence exigent? Qu’est-ce que fonctionne et sur quoi est-ce que on peut construire? Qu’est-ce que ne fonctionne pas et doit être changé? Quelles sont les possibilités dont peut-être nous ne sommes pas au courant et dont nous souhaitons en savoir plus? Qui d’autre devrions-nous en parler? Quelles expériences avez-vous faites qui pourraient éclairer notre recherche et guider la prise de décision du gouvernement de la RDC à ce sujet?

Si vous souhaitez participer et à partager votre point de vue, s’il vous plaît répondez avec aussi peu ou autant de détails que vous souhaitez, et envoyez-nous vos idées à info(at) jusque Mardi, 29 Juillet ou le plus tôt possible.

Nous voulons assurer que vos vues guideront notre travail sur le terrain en RDC, qui commence le 4 Août. Vos avis seront présentés au gouvernement de la RDC au cours de notre réunion de planification dans la semaine prochaine et dans les réunions et les rapports ultérieurs, en ligne avec le niveau de l’attribution souhaité. Dans votre e-mail s’il vous plaît laissez-nous savoir si vous êtes-vous prêt à être:

  • Cité et nommé dans notre rapport au client, ou
  • Cité et identifié par affiliation (par exemple, raffineur, donateurs, ONG internationale, l’initiative de certification, etc) dans notre rapport au client, ou
  • totalement anonyme

NOTE! Ce n’est pas votre seule chance de participer! Nous allons mener des consultations plus approfondies avec les parties prenantes internationales en Août et Septembre, fondées sur les conclusions initiales. Faites-nous savoir si vous souhaitez que nous vous contactions alors.

Merci beaucoup par avance pour votre participation et contribution! S’il vous plaît, n’hésitez pas à transmettre ce message à d’autres personnes qui pourraient avoir une opinion valable.

Vous pouvez trouver plus d’information sur ce projet financé par la Banque mondiale et DFID ici.



Photo credit: Alain Chishugi

ELL Contribution to WWF Mining Consultation Workshop published in Report

July 23, 2014

In February this year, WWF UK hosted a European regional consultation workshop on Mining and Sustainability, as part of WWF’s international process to develop an organisation-wide policy on mining and an associated engagement strategy. External stakeholders were invited to present on five panels, discussing Mining and Good Governance, Mining and Private Sector Standards, Mining and the Financial Sector, Mining Certification and Supply Chain Due Diligence, as well as Mining, Biodiversity and the Bigger Landscape.

In this fifth session, Estelle Levin, Director of ELL, presented policy-level findings of the Artisanal and Small-Scale Mining and Protected Areas and Critical Ecosystems (ASM-PACE) programme, which seeks to find solutions to the nexus of conservation, conflict, and artisanal mining. Estelle highlighted that the preferred option undertaken by governments to deal with ASM in PACE, eviction, is rarely successful in the long term.

Estelle highlighted that miners could be made stewards of the environment and that responsible mining practices inside protected areas are possible through incentivising good practice. Some options for managing ASM in protected areas include re/de-gazettement, negotiated access, training in environmental awareness and management, responsible sourcing initiatives, economic strengthening to incentivize alternative livelihoods, or a combination of some of the above. ASM could also be seen as an opportunity to raise funds for conservation, particularly in privately managed protected areas. Eviction should best be avoided, and where it has to be conducted, the process should be planned carefully using human rights based approaches and with the foresight of impact assessments.

Estelle recommended to engage with miners and apply land use planning approaches when ASM occurs in or near protected areas. However, the inclusion of ASM in spatial planning to create ‘mining-mindful’ conservation strategies remains a gap. There is also a need for innovative approaches to restore mined-out areas and encourage more responsible mining methods.

The full Workshop report has now been published and also includes summaries of the contributions by the UK Government, OECD, UK DFID, Chatham House, EBRD, International Council on Mining and Metals, UNEP, Birdlife International, Zoological Society of London, RSPB Nature and Minerals Programme, World Gold Council, Rio Tinto, Anglo American, Investec, JP Morgan, Aviva, HSBC, Morgan Stanley, Responsible Jewellery Council, the EU, Fauna Flora International, Oxford University, Natural Resources Charter, Fairtrade Labelling Organisation, WCS, Synergy, ELL, Adams Smith International, Natural England, Fairtrade Gold, Biodiversity Consultancy and WCS.

The WWF Workshop report can be downloaded here. For any comments, please get in touch with WWF UK. You can find out more about ASM-PACE on this website.

ELL partners with the Society for the Conservation of Nature of Liberia and the Royal Society for the Protection of Birds on conservation and responsible mining project in northern Liberia

June 30, 2014

The GolaMa project is a key part of the vision of the sustainable management of the Greater Gola landscape in the Upper Guinea Forest Biodiversity Hotspot, which has been internationally recognised as a top priority for conservation efforts. This project is carried out in a critical ‘corridor’ linking the Gola Rainforest National Park in Sierra Leone with the proposed areas of Gola Forest National Park and the Foya Forest Reserve in Liberia.

The project aims at enabling communities resident in the “corridor” to manage their forest and use its resources sustainably. The 400 households in the project area are highly dependent on natural resources and forest products, such as fuel wood and bushmeat. Their main source of subsistence is agriculture, with no or very restricted access to education, health or to international aid.
The project aims at increasing the wellbeing of these communities within the area, while at the same time reducing threats to the forest, such as agricultural encroachment, mining and bushmeat hunting. This will allow the forest to form a ‘wildlife corridor’, enhancing the biodiversity value of the surrounding protected areas.

The GolaMa project’s specific objectives are to:
(i) establish Community Forest Management Agreements and financial sustainability business plans
(ii) ensure forest communities are benefiting from new, sustainable, alternative income generating activities under these agreements while contributing to forest protection,
(iii) to reduce bushmeat hunting/trading of protected species in the project area
(iv) establishing self-regulated sustainable artisanal mining practices, and
(v) determine the potential of carbon trading to provide sustained finance

ELL is working with RSPB, the Society for the Conservation of Nature of Liberia (SCNL, local BirdLife Partner) and the Government of Liberia to implement objective 4 and identify strategies for responsible artisanal mining practices in the project area. For this purpose, ELL will conduct a resource endowment assessment and a baseline of current ASM practices in order to propose suitable management practices, including the feasibility of responsible mining and identifying potential alternative sites for ASM activity within appropriate zones of the project area. Based on the results of these assessments, ELL will develop recommendations and a strategy for empowering local communities to supervise and manage responsible mining in the long term, and support these efforts through capacity building and technical assistance.

The GolaMa project is funded by the European Union, Grant DCI-ENV/2013/323889. For more information, please visit the Liberia page of the Gola Rainforest National Park.


Photo credit: Anne Gardner, RSPB


ELL supports Fairtrade in aligning the Fairtrade Gold Standard with Conflict Minerals Initiatives

May 20, 2014

Over the course of the next months, ELL will be working with Fairtrade International to align the Fairtrade Gold Standard with requirements and initiatives regarding conflict minerals. The overall goal of the project is to protect and unlock markets for Fairtrade producers by ensuring the Fairtrade Gold Standard helps miners, traders and their downstream buyers demonstrate conformance with the OECD Due Diligence Guidance.

Our work will primarily focus on providing guidance for the revision of the Fairtrade Gold Standard, but will also include components of capacity building of the Fairtrade team to understand the threats and opportunities with regards to conflict minerals and support to Fairtrade’s communication and fundraising teams, as well as an ongoing role in representing Fairtrade at relevant conflict minerals events where necessary or desirable.

Specifically, our activities will consist of the following steps:

1. Determine a pathway to harmonisation of the Standard with downstream initiatives

2. Present Proposed Revisions to Fairtrade and Consult Relevant Conflict Minerals Initiatives

3. Support the revision of the Fairtrade Standard per the Findings of Step 1 and 2

4. Input to Fairtrade Standards Unit on managing comments from Public Consultation

5. Develop toolkits and checklists for Artisanal and Small-Scale Mining Organisations (ASMOs) and Fairtrade Producer Support

6. Units to ensure revisions can be operationalized by end 2014



ELL Director to speak at Responsible Jewellery Council’s CSR Conference

May 7, 2014

When members and stakeholders of the Responsible Jewellery Council (RJC) will be coming together for their Annual General Meeting on 15th of May, they will attend to more than just the annual proceedings: For the first time, RJC is organising a conference on Corporate Social Responsibility (CSR) in the diamond, gold and platinum group metals supply chain.

Three panel discussions are planned for the afternoon of the conference, involving industry leaders, civil society and experts. Estelle Levin will be speaking on Human Rights and Responsible Supply Chains, together with Adam Greene (Principal Officer, Bureau for Employers’ Activities, International Labour Office), Philip Hunter (Program Director, Verité) and Claus Teilmann Petersen (Vice President, Group CSR, Pandora). The discussion will evolve around the UN Guiding Principles on Business and Human Rights, risks of forced labour and human trafficking in the jewellery supply chain, artisanal and small-scale mining and Human Rights in jewellery manufacturing.

Of the two other panels, one will focus on future imperatives in the sector, including discussions on the EU responsible trading strategy for minerals from conflict zones, the Indian diamond sector and its challenges, and perspectives of SMEs and consumers. The other will discuss the creation of value through CSR, touching upon topics such as a producer’s perspective on sustainability, Signet Jeweler’s commitment to responsible sourcing and RJC, and the creation of value from CSR for consumers and the supply chain.

UPDATE 19.05.2014: Estelle’s presentation is now online and can be downloaded here.

ELL and Bureau Veritas inaugural Conflict Minerals Training takes place in Cambridge.

March 19, 2014

The inaugural Estelle Levin Ltd (ELL) and Bureau Veritas (BV) Conflict Minerals training took place last week at Hughes Hall,  Cambridge,  with 16 staff and associates from ELL and BV in attendance. Participants came from Africa, Australia, Europe,  and the USA.

Hughes Hall, University of Cambridge.

Hughes Hall, University of Cambridge.

The training enabled cross-learning between BV’s experts in assurance and certification, and ELL’s experts in conflict minerals and responsible sourcing. It also ‘tested’ the BV-ELL Conflict Minerals Training Course which has been designed for manufacturers, suppliers, and vendors.

The course is designed to build capacity for action on conflict minerals  regulations, due diligence system implementation, reporting and compliance, in streamlined modules in a classroom  setting.

Following the success of this first course a further training will take place in New York in May 2014, for both BVCNA staff as well as interested clients, with a bespoke course taking place in Italy in June 2014 for Bureau Veritas Italy’s luxury  brand  clients. Bureau Veritas (BV), is a world leader in inspection, verification, and certification services, see our partners page for more details

ELL announces conflict minerals training partnership with Bureau Veritas

January 29, 2014

ELL is proud to announce its partnership with Bureau Veritas (BV), the world leader in inspection, verification, and certification services, to offer formal conflict minerals training courses. The ELL-BV Conflict Minerals Training was developed for manufacturers, suppliers, and vendors alike, and is designed to build capacity for action on conflict minerals regulations, due diligence system implementation, and the reporting process in streamlined modules and a classroom setting. ELL-BV offers two training courses: an executive overview of conflict minerals regulations and a longer course on understanding and implementing conflict minerals requirements.

Additionally, ELL and Bureau Veritas have partnered to produce a white paper covering current conflict minerals requirements, the compliance process, a detailed treatment of the OECD Due Diligence Guidance, and more. Please follow the link for quick access to our free document, On Conflict Minerals Challenges and Moving Beyond Compliance.
Apart from our training partnership with BV, ELL also provides strategic advice on a wide range of conflict minerals and responsible sourcing initiatives, as well as services in conflict minerals due diligence and Reasonable Country of Origin Inquiry. Visit our conflict minerals page for more information on our conflict minerals services.

ELL director appointed as member of the World Commission on Protected Areas

January 6, 2014

ELL director, Estelle Levin, has been proposed and approved as a member of the World Commission on Protected Areas (WCPA). The WCPA is a voluntary network of professionals with the mission to promote the establishment and effective management of marine and terrestrial protected areas. The Commission supports governments, policy makers and other stakeholders in planning and establishing protected areas across all sectors, provides guidance and tools to strengthen the capacity and effectiveness of protected area managers and aims to increase the investment in protected areas by public and corporate donors.

The Commission is administered by the International Union for Conservation of Nature (IUCN) and comprises of almost 1700 members spanning 140 countries, including protected area managers, academic experts, officials, leaders of relevant NGOs, community, indigenous, private and public land owners, and IUCN commission members.
As a member, Estelle will contribute actively to the objectives of the WCPA, building on the lessons learned in managing artisanal and small-scale mining in and around protected areas through the Artisanal and Small-Scale Mining in Protected Areas and Critical Ecosystems (ASM-PACE) programme, co-founded by ELL and WWF in 2010. Estelle will contribute her expertise on managing ASM in PACE to the WCPA, with a focus on sharing best practices and ideas for sustainable, viable win-win solutions involving all stakeholders

ELL director appointed as Industry Fellow at CSRM

January 3, 2014

ELL director, Estelle Levin, has been appointed as an Industry Fellow at the University of Queensland’s Centre for Social Responsibility in Mining (CSRM). For the next two years, she will be contributing to the work of CSRM, a multi-disciplinary research institution focussing on improving social performance in the global mining industry.

The Centre works on the economic, social and political issues related to mineral extraction and development through qualitative and quantitative social research, customised studies and research-based consulting, as well as education and training activities. Research areas include community engagement, resettlement, conflict management, social and cumulative impact assessments, indigenous peoples and cultural heritage, gender and human rights, as well as governance processes such as management systems and standards, socio-economic monitoring, policy and regional governance. CSRM collaborates with a wide range of stakeholders such as large mining companies, small and medium-size enterprises, industry associations, governments, international organisations, NGOs, community representative groups as well as other academic institutions. Estelle says, “It is an honour to be part of the CSRM fellowship. I look forward to contributing to CSRM’s work at the University of Queensland and beyond, and to the collaborations and mutual learning that this opportunity will bring.
For more information on CSRM, please visit and

ELL report on Mineral Supply Chain Due Diligence Audits published

November 18, 2013

You can now learn all about mineral supply chain due diligence audits and risk assessments for conflict minerals in the Great Lakes Region through our analysis report, which has been published on the OECD website. The comparative analysis was used by the ICGLR’s Audit Committee to inform the design of the third party exporter audits required by the ICGLR’s Regional Certification Mechanism (RCM).

The analysis report explores opportunities for alignment between the RCM’s third party exporter audits and the audit methodologies of other conflict minerals and responsible sourcing initiatives, such as the OECD Due Diligence Guidance, Section 1502 of the US-Dodd Frank Act, upstream initiatives like Certified Trading Chains, iTSCi, the World Gold Council’s Conflict Free Gold Standard, and Fairtrade and Fairmined Standards, as well as downstream initiatives including the Conflict Free Smelter Programme, the Responsible Jewellery Council’s Code of Practices and Chain-of-Custody Standards, the LBMA’s Responsible Gold Guidance and the DMCC’s Responsible Sourcing Protocol.

The report is the result of consultations with the major initiatives, desk work, and one month of fieldwork in DRC and Rwanda conducted in August 2013. In order to further develop the audit methodology, ELL also worked directly with the ICGLR’s multi-stakeholder Audit Committee facilitating a workshop in Nairobi in October 2013.

The work was facilitated through BGR and the German ICGLR support programme.


ELL associate Alain Chishugi’s take on the 6th ICGLR-OECD-UN GoE meeting

November 15, 2013

Seizing the opportunity to learn about the newest developments in implementing responsible mineral supply chains and to exchange his on the ground experience and knowledge of mine sites in the DRC with other experts, ELL associate Alain Chishugi made the short trip from Bukavu to Kigali to attend the 6th ICGLR-OECD-UN GoE meeting this November. The following is an excerpt from his report.

The multi-stakeholder forum brought together 300 experts and stakeholders to discuss the implementation of due diligence in mineral supply chains in the Great Lakes Region, and intended to achieve the following goals:

  • Understanding the successes, challenges and opportunities related to the implementation of due diligence for tin, tantalum, tungsten (3T) and gold supply chains in the Great Lakes region
  • Solving the difficulties discussed at previous meetings
  • Promoting due diligence initiatives and activities currently piloted on a local level
  • Accelerating the implementation of due diligence by strengthening existing programmes on the ground and the regional certification mechanism, as well as supporting coordination and cooperation
  • Developing a strategy to encourage responsible mineral supply chains in conflict-affected and high-risk areas

Challenges in implementing due diligence

Synthesizing the various presentations, discussions and meetings, I consider the main obstacles to the implementation of due diligence in the Great Lakes region to be related with the security situation in the region, the lack of harmonisation of member state’s legislation and their enforcement, as well as the lack of funds for organisations to implement due diligence initiatives on the ground.

According to the presentation by the UN Group of Experts on the DRC, the recent defeat of the M23 rebel group after a joint offensive by the Congolese army and MONUSCO’s intervention brigade was a positive step towards the restoration of peace in DRC. While efforts are being made to restore the state’s authority, armed groups remain in the DRC’s territory, mainly in the Kivus and northern Katanga. The UN Group of Experts considered other parts of the Great Lakes Region to be stable, but likewise mentioned the issue of fraud persisting in the Region’s minerals trade, especially regarding minerals originating from the eastern parts of DRC flowing through Rwanda, Burundi and Uganda.

Participants considered the implementation of the Regional Certification Mechanism in Rwanda and DRC as an important step, allowing actors along the mineral supply chain to verify the source of their minerals. Representatives of Burundi also stated their efforts to implement the certification mechanism. However, the mechanisms currently in place face obstacles, such as smuggling, different taxation laws, insecurity in the east of DRC and an alert mechanism that is not effective yet. Further technical issues of the Certification Mechanism were discussed at the meeting, such as the confiscation of minerals deemed to originate from an unreliable source and the characteristics of actions/sanctions taken thereafter. The question of how upstream and downstream companies should react if they learn that the minerals they used were from an unreliable source and how this information would be dealt with has been put to the multipartite commission for further discussion.

The US State Department stated its support to all initiatives aiming at implementing the requirements of the Dodd Frank Act and the OECD Due Diligence Guideline and acknowledged the efforts made by the ICGLR member states to date. However, its representatives also warned that ICGLR member states who do not adhere to the regional mechanisms with regards to traceability to curb the illicit exploitation of minerals will be left behind and potentially face punishment, although it was not made clear what kind of action will be taken.

Encouraging responsible mining and sourcing

The DRC currently applies various strategies to develop responsible minerals trade. In his presentation, the national coordinator of the ICGLR in DRC elaborated on the process of mine site validation currently under way in the country. The validation takes place prior to the introduction of tagging systems, which will allow the mine sites to be approved through the ICGLR’s certification mechanism. Such efforts are implemented for example in Kalimbi/Nyabibwe, Mayi Baridi and Maniema, where the government has joined forces with MONUSCO, JMAG, to validate a large number of mine sites as « green flagged » or « red flagged ». However, mining operators from North Kivu stated that to date no mine site had been qualified as « green » to start the tagging process, and argued that such situation poses a challenge for economic development in the areas of North Kivu where security is guaranteed.

Contributions by civil society organisations such as PACT and Amnesty International focused on the respect for human rights as an important element to take into consideration when implementing due diligence systems. Both organisations underlined the importance of addressing the worst forms of child labour in the implementation of the OECD Due Diligence Guidance. With regards to the DRC, it may be worth supporting the dissemination and enforcement of the new labour code and to help those concerned to formalise and comply with the law. Amnesty International suggested that representatives of the ILO should participate in the OECD working group in order to facilitate the inclusion of such aspects. However, lack of funds may pose a challenge to the ambition of bringing in more organisations.

The effectiveness and efficiency of the current tagging and traceability system was the focus of further discussions. Some participants felt that the system implemented by ITRI is currently the only reliable system in place and that installing an alternative system would increase the risk for fraud. One that ‘cherry-picks’ off the major mine sites would also put at risk the inclusion of smaller mines in the risk managed system, as the smaller mines could not affordably be included without the revenues generated by larger mines. Others felt that the current system would need to be updated and more work is necessary with regards to security and legislation for it to be sustainable in the long term.

Conclusion and outlook

The meetings proved a commitment of all stakeholders, regional and international, to implement due diligence in mineral supply chains in the Great Lakes Region and were an excellent opportunity to exchange experiences and get a better understanding of each other’s challenges.

Positive points include the interest and commitment expressed by representatives of ICGLR member states in implementing due diligence systems along the lines of the OECD Due Diligence Guidance and in launching the ICGLR’s certification mechanism. This commitment fosters trust and provides an opportunity for organisations and partners to invest in regional stability and to further improve local initiatives and pilots on the ground.

However, some challenges remain. The stability proclaimed in DRC after the defeat of M23 risks accelerating local dynamics in unforeseeable ways. Also, the process of implementing a universal traceability system will require large logistical, financial and technical measures if it is not to risk nurturing and perpetuating the informal trade networks. We should expect pressure on tagging organisations to apply their work to further mine sites – in my experience, there are not more than 10 mine sites applying the tagging system in the DRC, owing to a range of constraints.

Alain Chishugi is ELL’s Associate in DRC. Alain is experienced in mine site validation and establishing due diligence systems in accordance with the OECD Due diligence Guidance for minerals from Conflict-affected and High-risk areas for a variety of companies based in the country. Alain is an expert in artisanal mining and has conducted extensive field research in the areas of gold, tin, coltan and tungsten mining and trade in the DRC. He has worked on highly sensitive issues such as illegal mining in protected areas and cohabitation of artisanal and large-scale mining in post-conflict and conflict-affected communities.

ELL director joins Fairtrade Gold Technical Advisory Group

November 14, 2013

ELL director Estelle Levin attended the first meeting of the newly formed Fairtrade Gold Technical Advisory Group (TAG) today.

The TAG was created to support Fairtrade in their vision to deliver developmental opportunities to artisanal and small-scale gold mining communities and their plan to expand the Fairtrade Gold programme from Latin America to Africa during the next five years.

The TAG’s mandate is to provide strategic recommendations to Fairtrade’s Gold Strategy Working Group, suggesting effective interventions to maximise positive impacts on the ground for responsible ASM organisations who work towards or are already certified by Fairtrade. The TAG will further help to create a better understanding of the artisanal gold mining industry, address complexities in providing technical support to gold producers and develop strategies to ensure the supply of Fairtrade Gold in the long-term.

Generally, the TAG will give advice regarding the social, economic and environmental challenges faced by artisanal and small-scale miners and their difficulties with regards to technical practice and market access. The focus of the TAG’s work will be on Fairtrade’s priority areas of producer support:

Eliminating the use of mercury in Fairtrade certified mining operations;
Addressing the issues around child labour and forced labour in certified mines;
Fostering replicability and scalability and capacity-building to establish ‘centres of mining excellence’ that can act as training centres for local mines;
Incorporating conflict minerals and due diligence strategies
Addressing commercial obstacles to selling Fairtrade Gold
On-going revision, reflection and review of the standard for gold and associated precious metals
The TAG consists of members working on a pro bono basis, who have broad technical knowledge and experience in responsible artisanal and small-scale mining and the issues related with it. The TAG will meet 3 times a year.

Estelle Levin chairs Fairtrade Gold roundtable

October 10, 2013

Bringing together actors from across the whole gold supply chain, the Fairtrade Gold roundtable organised by Fairtrade International on 9th and 10th of October gave jewellery industry stakeholders a rare opportunity to personally meet representatives from Fairtrade certified mining organisations. Though intrinsically linked through the trade in gold and their interest in responsible mining, many of the actors – jewellers, retailers, refiners, traders and miners – had never met personally before.

The roundtable intended to highlight the opportunities that Fairtrade Gold brings for both the industry and gold mining communities and put forward Fairtrade Gold as a concrete model for the precious metals and jewellery sector to proactively address social, economic and ecological challenges within their supply chains.

The revised Fairtrade Gold Standard, which will be published in early November, as well as new models of engagement for the jewellery and precious metals industry were presented by representatives of Fairtrade International. Chaired by ELL director, Estelle Levin, the stakeholders then explored impediments and opportunities for greater commercial success of Fairtrade Gold at each tier of the supply chain. Solutions and next steps were proposed for challenges such as lack of consumer and industry awareness, risks and rewards for large and small businesses, ways of mutual support between Fairtrade and the industry, as well as alignment of each Fairtrade mining organisation’s gold supply with industry demand regarding volumes, materiality and technical specifications.

The highlight of the two-day roundtable was presentations by the leaders of the Fairtrade certified mining organisations from Bolivia, Colombia and Peru. Their stories gave industry representatives and other stakeholders a first hand account of the lives of artisanal miners, the challenges they face, and the opportunities that Fairtrade has brought for them, their mining businesses and their communities.

Gayatri Morales, representative of the Bolivian mining cooperative Cotapata, explained that Fairtrade certification and the premium have not only brought the cooperative and the community more income and higher living standards, but also allowed the miners to take on social and environmental responsibility for their activities. The cooperative now operates garbage collection facilities, uses an electric plant instead of diesel, and introduced retorts for the burning of mercury amalgamation. Moreover, the miners have organised the cooperative in a democratic and participatory way and are proud of their transparent management and finances.

For the representative of the one of the two Peruvian mining companies, Eugenio Huayhua Vera of Sotrami Fairtrade certification has brought similar advantages, even though he agreed that adhering to the original Fairtrade standard was not an easy process at the beginning. With the additional income from the premium, the mining organisation has been able to introduce health and safety equipment for the miners. It has also allowed them to take up social responsibility in their communities, creating impact way beyond the mining pits: The organisation has invested in local infrastructure, such as roads, electricity and water, and has built and equipped health centers and schools in the villages.

The representative of the second Peruvian mining company, Santiago Ramirez Castro of Macdesa, stated similar benefits of Fairtrade Gold. His organisation has agreed to get Fairtrade certified early next year, as its members recognise the benefits that certification will bring to their community.

Aristarco Mosquero, representative of the Colombian mining organisation, Corporación Oro Verde, underlined the importance of Fairtrade certification for environmental sustainability and the protection of critical ecosystems. For the miners of Oro Verde, the Fairtrade premium is more than a development opportunity, but helps them to preserve the environment and biodiversity in their area as well as their community’s cultural heritage for future generations.

All miners’ representatives felt that one of their most important achievements was to show the world that socially and environmentally responsible artisanal and small-scale mining is possible.