Evaluating due diligence programs for conflict minerals: A matched analysis of 3T mines in eastern DRC
This report evaluates the impact of due diligence programs (DDP) on 3T mines (tin, tantalum, and tungsten) in Eastern DRC. It finds reductions in interference by armed forces, increased state presence, but no significant changes in child labour rates. Economic improvements are noted, but DDP does not eliminate all mining-related harms.
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OVERVIEW
Introduction
This report evaluates the impacts of Due Diligence Programs (DDP) on conflict minerals, specifically tin, tantalum, and tungsten (3T) mines in Eastern Democratic Republic of Congo (DRC). The analysis compares outcomes between 3T mining areas with and without DDP, using matched samples of mine sites and households.
Hypotheses
The report hypothesises that DDP should reduce interference from both non-state armed groups and the Armed Forces of the Democratic Republic of Congo (FARDC), while increasing legitimate state tax collection. It also aims to reduce illegal taxation and serious labour abuses, including child and forced labour. Furthermore, DDP is expected to improve economic conditions by increasing productivity at mines, which would in turn raise incomes for miners and their communities.
Sample characteristics
Data was collected from 104 mines in South Kivu and Maniema provinces, with 73 DDP-covered mines. The mines predominantly produce cassiterite, with a smaller percentage extracting gold, wolframite, and coltan. Employment in these mines varies, with the average number of workers being higher in Maniema than in South Kivu.
Empirical approach
The study uses a matching algorithm to ensure that comparisons between DDP and non-DDP mines are as fair as possible. By matching mines and surrounding communities with similar geographic, economic, and conflict-related characteristics, the analysis isolates the impact of DDP from other factors that might influence outcomes. The data collection process was carried out under challenging conditions due to the volatile security environment. Enumerators were tracked via satellite and received clearance from local authorities before entering mining areas, to minimise the risks posed by armed groups and unstable conditions.
Results
FARDC Interference and State Presence: DDP areas saw a 27% reduction in interference by the FARDC, whose members are often involved in illicit taxation and forced labour at mines. Meanwhile, households in DDP areas reported a 58% increase in the presence of state agents from the Mining Division and SAEMAPE. These agents are responsible for regulating mining activity, providing technical support, and collecting taxes. Despite this increase in state presence, perceptions of safety did not improve significantly between DDP and non-DDP areas.
- Conditions of extraction: The report finds no significant reduction in child or forced labour in DDP areas compared to non-DDP areas. Roughly 33% of DDP mines still report child labour, a rate comparable to that of non-DDP mines. Children at these sites are involved in hazardous tasks such as digging and washing minerals. Forced labour, though less common, is also reported, but at similar levels across DDP and non-DDP mines.
- Economic well-being: DDP areas show some signs of improved economic well-being, with households reporting higher consumption levels for basic goods such as food and mobile phone credit. However, these improvements are not directly linked to increased productivity or higher mineral prices. Instead, they may be the result of higher employment levels in DDP mines, as no evidence suggests that DDP mines are more productive or pay higher wages than non-DDP mines.
- State taxation issues: Despite the increased presence of state regulators, DDP areas still experience challenges with taxation. Double taxation and the levying of arbitrary, unlawful taxes remain common issues, with state agents charging miners for services and documents that should not incur fees. These practices undermine the potential economic benefits of DDP, as they reduce the income available to miners and their communities.
Conclusion
DDP has made progress in reducing FARDC interference and increasing state oversight in 3T mines, but significant challenges remain. Child and forced labour continue to be issues in DDP areas, and the practice of double taxation by state agents diminishes the positive impacts on miners’ livelihoods. While there are signs of economic improvement, particularly in household consumption, the mechanisms behind these changes are not yet clear. Overall, further improvements in labour conditions and economic transparency are needed to fully realise the potential benefits of DDP.
Things to learn
Actions to take
ESG issues
SDGs
SASB Sustainability Sector
RELEVANT LOCATIONS
RELATED TAGS
- 3T minerals
- armed groups
- child labour
- conflict minerals
- Democratic Republic of Congo
- Dodd-Frank Act
- due diligence programs
- forced labour
- illegal taxation
- labour rights
- mining governance
- OECD Due Diligence Guidance
- responsible sourcing
- SI Conflict Minerals
- supply chain management
- tin tantalum tungsten