Audits Methodology Report

COMPLIANCE
AUDITS OF MINING COMPANIES
IN RWANDA TO THE CTC‐STANDARD SET

Inception Report: Certification Audits
Compiled by:
Dr Nellia Mutemeri (Mining Consultant)
Postnet Suite 135, P Bag X1, Melrose Arch 2076
Johannesburg, South Africa
Mobile: +27‐(0)71‐606 1996
Fax: +27‐(0)86‐541 5716
E‐mail: mutemerinellie@gmail.com

For the Attention of:
Federal Institute for Geosciences and Natural Resources (BGR), Hannover, Germany

Dr Philip Schuette
Dr Gudrun Franken
Dr Juergen Vasters

cc:
Dr Michael Biryabarema, Rwanda Geology and Mines Authority (OGMR)
Francis Kayumba, Rwanda Geology and Mines Authority (OGMR)
Patricie Mwambarangwe, CTC Rwanda
Patrice Ntiyamira, Rwanda Bureau of Standards (RBS)
Eugenie Niwenkunda, Rwanda Bureau of Standards (RBS)
Vital Habinshuti, Ministry of Commerce (MINICOM)
Fidele Uwizeye, Ministry of Forestry and Mines (MINIFOM)

Date: 23rd October 2010
Table of Contents
1. Introduction and Background ...............................................................................................3
2. Scope of Work and Methodology of Audit...........................................................................4
2.1 Inspection of Documents ....................................................................................................6
2.2 Key Informants ...................................................................................................................7
2.3 Inspection of Relevant Sites................................................................................................7
3. Evidence Collection and Evaluation.....................................................................................8
3.1 Questions.............................................................................................................................9
3.2 Indicators...........................................................................................................................13
3.3 Level Descriptors ..............................................................................................................16
4. Scheduling...........................................................................................................................22

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Compliance Audits of Mining Companies in Rwanda to the CTC Standards Set – Certification Audits Inception Report, October 2010
BGR‐OGMR nmutemeri consulting
1. Introduction and Background
This is the first report in the implementation of the certification audits of the project entitled
“Certified Trading Chains (CTC) in mineral production: pilot project Rwanda”. The project is
jointly being implemented by partner institutions Rwanda Geology and Mines Authority
(OGMR) and the German Federal Institute for Geosciences and Natural Resources (BGR) with
an emphasis on a subproject entitled “Building Best Practice in Rwandan Mineral Production“.
The project aims to foster ethical standards and good practice in mineral production in the
mining industry in Rwanda, including certifying the origin of minerals used by industry end
users. The compliance of Rwandan mineral producers has been assessed by an independent
third party auditor in the frame of a “baseline audit” and a “certification audit” against the
CTC certification standard set.
This inception report presents the approach which will be used to carry out the “Certification
Audits” phase of this project. It is informed by observations and recommendations from the
“Baseline Audits” and as well as other developments that have taken place since the baseline
audits were carried out. These included the following:
 Review of the CTC standard set
 Outcomes of the discussion of the CTC Working group which includes BGR, OGMR,
Rwanda Bureau of Standards (RBS), Ministry of Commerce (MINICOM), and the
Ministry of Forestry and Mines (MINIFOM)

The report covers the following:
 Background to the CTC project
 Methodology and approach
 Scheduling of the audits
 Recommendations

The auditor will be supported by the BGR team and staff of the OGMR. The key people are Dr
Philip Schuette, Dr Juergen Vasters, Dr Gudrun Franken and Dr Michael Biryabarema.

The following are key in directing the Certification Audits:
 OGMR staff:‐ Dr Michael Biryabarema (OGMR Director) will be the key contact in
OGMR. He will facilitate contact and support from some of his staff. Together they
will provide the auditor with information from the reports submitted by mining
companies to OGMR. He will also provide persons that will accompany the
consultant on mine visits for the audits.
 Executive management of mining companies:‐ The scheduling for contact with the
mining companies was facilitated by OGMR. The senior management of each
company will be met on the first day of the company’s audit. At this time the Audit
Plan will be discussed. It will be up to the company to delegate a guide who will take
the Auditor through the company documentation and for site inspections.
Confidentiality agreements will be signed with each of the companies being audited.
 CTC Working group, including OGMR, BGR, RBS, MINICOM, MINIFOM. Representatives
of these organisations may accompany the auditor as observers The Working group
will oversee the certification which will be implemented by RBS.
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2. Scope of Work and Methodology of Audit
The “Certification Audit” will include the following:
 Design of an Audit plan (see Table 1) which will include the audit objectives, scope and
extent, details of the activities and the scheduling.
 Audit
o On‐site audit activities
 Interviews with key informants using the questionnaires developed for
each standard
 Review of documents sited in the indicators as important for acquiring
a portfolio of evidence
 Inspection of sites relevant to acquiring information sited in the
indicators as relevant to the portfolio of evidence
o Off‐site audit activities
 Interviews with key informants using the questionnaires developed for
each standard
 Inspection of documents supplied by relevant authorities sited in the
indicators as important for acquiring a portfolio of evidence
o Data analysis: For each company the information (portfolio of evidence) will be
processed so that it can inform the level of compliance assigned to each
standard according to the level descriptors developed for the standards.
o The audit will include the mining company itself as well as its direct business
partners with respect to the mineral trading chain in Rwanda.
 Report compilation:
o An audit report will be compiled for each mining company. This report will
have the following information:
 Methodology
 Company information
 Summary of audit findings and performance evaluation. The ratings will
be arrived at from the level descriptors of each standard.
o A summary report of the whole assignment will be compiled and will include:
 Background and methodology
 Environment of audit realisation
 Encountered difficulties
 Recommendations for future audits
 A summary of each company audit report, excluding confidential
information, with the level of disclosure authorised by the company.
Audit activities and report compilation will be aligned to ISO 19011 – 2002.
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Table 1: Audit plan (generic)

AUDIT PLAN
Auditee Company:
Audit client: CTC Working group (BGR, OGMR, RBS)
Independent Auditor: Dr Nellie Mutemeri
Guides: Management and staff
Observers: CTC working group.
Proposed dates:
Audit Objective: CTC certification audit
Audit scope: Location, commodity, time limits
Audit activities:
1. Opening and closing meetings
2. Company information: Checklist
3. Document review:
a. About Mine
i. Registration of business entity
ii. Description of business, commodities etc.
iii. Mining licence/contract
b. Personnel
i. Personnel records (including remuneration)
ii. Training records
c. Operations:
i. Policies and procedures
ii. Minutes of management meetings
d. Mining and processing activities
i. Production records
ii. Financial records
iii. Pricing protocol
iv. Payment, e.g. reconciliation, fund transfers
e. Trading activities
f. Social responsibility
i. Community initiatives
ii. Social infrastructure
iii. Local supply chain development
g. Compliance
i. OGMR returns/reports
ii. Tax returns and royalties
iii. Occupational and health insurance

4. Key Informants:
a. Mine management
b. Relevant staff
c. Community leadership
d. Local authorities
e. ASM representatives

5. Site inspections:
a. ASM production facilities (representative number)
b. Mine production facilities
c. Processing facilities
d. Waste disposal and hazardous material handling
e. Other mine infrastructure
f. Community initiatives

6. Scheduling:
Date Activity Remarks
Briefing meeting on Audit plan with mine
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management
Review trading documents & collect further data
at trader/freighter/importer
 Document review at mine
Inspect processing facility
 Inspect producing ASM mining sites Representative number of sites
 Interview ASM and/or ASM representatives
 Inspect ASM production and payment
records
Inspect community interventions This could be social infrastructure or a community
group
Meet with local authorities and/or community District/Village
leadership

The approach of the audit is detailed in the following sections.

2.1 Inspection of Documents

The following documents will be inspected to gather evidence for the standards:
 Company registration documents
 Licenses
 Employee records
 Explosives handling
 Production records
 Remuneration records
 Training records
 Environmental Impact Assessment (EIA), Environmental Management Plan (EMP and
Environmental Impact Declaration (EID) documents
 Subcontractor agreements
 Subcontractor production/delivery records
 Explosives records
 Consumables stock records
 Policies and procedures, e.g. health and safety, environment, security, gender,
corporate social responsibility
 Company financial and management accounts
 Contractor worker records
 Processing plant records

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Table 2: Sample document for collecting company information.

COMPANY INFORMATION

Date of response:

Person completing form:

Name of company:

Date of registration:

Ownership:
Operation being audited: Name: Location:
Mining licence details: Type: Issue date: Expiry date:
Special license conditions:

Commodities mined:
Number and names of
operational mining sites:
Number of ASM workers: Male: Female:
Number of salaried
employees: Male: Female:

2.2 Key Informants

The key informants can be divided into the following categories:
 Management of the mining companies
 Workers of mining companies, i.e. mine site supervisor (also known as subcontractor),
security, store manager for managing concentrate receiving, miners, processing
technicians, machine operators etc.
 Companies participating in the mineral trading chain
 Government authorities and agencies
 Community directly affected by mining
 Community leaders
 Local government administrators
 Other interested parties

2.3 Inspection of Relevant Sites
The sites that should be visited and inspected include the following:
 The mining company head offices if separate from mine operation/concession offices
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 Mining concession areas
o Mine company premises in the concessions
 Offices
 Processing plants
 Mineral storage
 Explosives store:
 Concentrate delivery area
 Concentrate store
 Mineral processing area
 Fuel storage
 Water source
 Mining production site
 Buyer/trader/freighter premises
 Waste disposal area
 Hazardous material storage
o Community intervention, e.g. social infrastructure

3. Evidence Collection and Evaluation

The topics to be covered in the evidence collection of the audit will include:
 Environmental and social impacts
 Management and technical aspects of the production processes
 Traceability of commodities and plausibility of production

These will be looked at from the perspective of:
 Processes and procedures
 System design and management
 Evidence addressing indicators for each of the standards

As in the “Baseline Audits” questions and indicators (see Tables 4‐8 and Tables 9‐13,
respectively) were prepared to facilitate the collection of performance evidence for the
standards from key informants, site inspections and document reviews. A form was designed
to ensure that the correct information was collected for the mineral plausibility check for CTC
Standard 1.1 (see Table 3). Evidence will also be collected to verify the capacity of the mine to
produce the amount of mineral concentrate indicated on the production and sales records.
This should include the ASM production and payment records, which should indicate the
number of ASM employed. In addition the level of inputs directly related to the mineral
production will also be reviewed, include consumables.

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Table 3: Structure for collecting data for plausibility check of produced and traded mineral
concentrate from a mine.
Date or Date or
consignment consignment Data sources Remarks
ASM concentrate production (kg) ASM production records
Value of mineral received by ASM
(USD) ASM payment records
Mine concentrate production (kg) Company production records
Weight of Concentrate processed at
mine (kg) Company production records
Grade of concentrate dispatched
from mine (%) Analytical certificates
Weight of Concentrate dispatched
from Mine (kg) Dispatch documents
Weight of Concentrate received by
trader (kg) Good receiving documents
Weight of Concentrate received by
freighter (kg) Freighting documents
Weight of Concentrate received by Freighting
importer (kg) documents/company records
Grade of concentrate received by
trader/freighter/importer (%) Analytical certificates
Value of concentrate received by
trader/importer (USD) Trader/importer records
Amount Paid by trader/importer Mine financial records;
(USD) Trader/importer records
Amount received by mine (USD) Mine financial records
LME average price (USD) Trader/importer records

To evaluate the performance of each company and determine the rating for each standard,
the evidence collected will be analysed with reference to Level Descriptors for each standard.

3.1 Questions

Table 4: Questions and possible sources of information relating to each standard of Principle 1
of the CTC Standard set. The corresponding respondents and sites where the information was
to be obtained are indicated.

MM = Mine Manager, MCHO = Mining Company Head Office, MSS = Mine Site Supervisor, MS
= Mining Site, OGMR, BT = Trader Buyer, BE = End User Buyer, F = Freighter, SL = Sampling
Lab, MINICOM = Ministry of Trade and Industry, RRA = Rwanda Revenue Authority, M =
Miners, LG = Local Govt., P = Publisher, MCW – Mining Company Workers, CM = Community
Members

Standard Questions Respondents/Sites
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1.1 Origin and production volume What evidence (documents) can you provide that can MCHO, MS, MSS,SL,
of minerals from the pilot mine site be used to trace the origin and volume of minerals BT, BE, F, OGMR,
throughout the trading chain are from mine site throughout to the trading chain? Can MINICOM, M
traceable. you provide information that indicates plausibility that
all the minerals you are trading are produced by the
mine being audited, including security safeguards
during material handling, transportation, exportation
and importation, and documentation from the buyers
and freighters of your minerals? Would you permit a
third party to take samples for Analytical
Fingerprinting (AFP)
1.2 Meet fiscal obligations required What documentary evidence can you provide to MCHO, RRA, OGMR
by host government law. indicate that you are fulfilling the fiscal obligations
required by government? Can we inspect records of
the remittances to government by mining company in
accordance with government fiscal requirements?
How can this be verified with the relevant government
authority?
1.3 Publish all payments made to What documentary evidence do you have of publishing MCHO, P, OGMR
government according to all the payments made to government? Can you show
internationally accepted standards. how the way you publish measures up against a global
system like the EITI?
1.4 Actively oppose bribery and Provide proof that your company actively opposes MCHO, MS, MSS,
fraudulent payments bribery and fraudulent payments. Do you have MCW
company policies and procedures and other
documents that show how you guard against bribery
and fraud being perpetrated by you employees or
people that your company deals with?

Members

Standard Questions Respondents/Site
2.1 Pricing and distribution Provide evidence that employees or payments to MCHO, MS, MSS,
systems for artisanal miners and sub‐ contractors are equal or higher that comparable enterprises. MCW, M
contractors, as well as salary levels Provide evidence that the subcontractors and miners receive
for employees are fair, legal, and a fair, regular and timely compensation for their mineral
regulated. production.
2.2 Ensure that no child labourers Provide evidence that your company actively guards against MCHO, MS, MCW,
(age under 16) work on company the hiring of child labour? Do you have company policies and MSS, LG
sites. procedures and other documents that show how you guard
against use of child labour?
2.3 Support workers’ What evidence can you provide that your company supports MCHO, MS, M,
organizations and collective workers' organisations and collective bargaining? Do you MCW
bargaining. have company policies and procedures and other documents
that show that you have been supporting the formation of
workers organisations and their capacity for collective
bargaining?
2.4 Provide essential protective Provide evidence that you provide protective and MCHO, MS, M
and production services to support production to support the artisanal miners working on your MCW
the work of artisanal miners. concession. Can site inspections verify that workers use
protective clothing and that they are being assisted with
production?
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2.5 Ensure occupational health in Provide evidence that you do all you can to ensure MCHO, MS, MSS,
all company operations as well as occupational health and insurance in all your operations. M, MCW
insurance for Does your have company occupational health and safety
workers policies and procedures and are there other documents that
show how you try to ensure health and safety of workers?
Show that you have valid occupational insurance to cover
your workers and that they are assisted to receive
appropriate treatment?
2.6 Provide training for workers on What documentary evidence can you provide to show that MCHO, MS, MSS,
safety, health and effective use of on‐ you train employees and contractors on safety, health and MCW
site facilities effective use of on‐site facilities? Do you have regular
training programs for occupational health and safety and for
proper use of equipment and mine facilities?

of the CTC Standard set. The corresponding respondents and sites where the information will
obtained are indicated.
Lab, MINICOM = Ministry of Trade and Industry, RRS = Rwanda Revenue Authority, M =
Members

3.1 Provide sufficient and Provide proof that you provide sufficient and adequate MCHO, MS, MSS,
adequately trained security forces. security for your premises. Do you have company security MCW, CM, LG
policies and procedures and are all workers fully aware of
them and their importance? Is there evidence of regular
security briefings and incident reporting? Are security
personnel fully aware of the need to observe human rights
and not abuse their position with regards to workers and
nearby communities?
3.2 Undertake security risk Provide evidence you carry out risk assessments on all your MCHO, MS, MSS,
assessments. operations. Is there evidence that risk assessments are used MCW
to inform security policies and procedures?

Members

4.1 Interact regularly with What evidence can you provide that shows that you interact MCHO, MS, CM LG
communities and local governments regularly with communities and local government to address
to address grievances and other grievances and concerns? Is there evidence of
common concerns. communication with local authorities and representatives of
communities? Do communities corroborate effective
communication and the address of grievances and concerns?
4.2 Support local enterprises to Provide evidence that you support local enterprises to MCHO, MS, LG, CM
supply company operations. supply company operations. Can this be corroborated by
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supported enterprises? Is there a company strategy on
supporting local enterprises and does this have targets on
the company’s spend on local suppliers?
4.3 Support integrated Provide documentary proof that you implement integrated MCHO, MS, LG, CM
development programs in nearby development programs for communities around your mining
communities for livelihood security, operations, and that these address issues of livelihood
social and physical infrastructure and security, capacity building and social and physical
capacity building infrastructure? Is there a company strategy on supporting
livelihood activities and social infrastructure development
can this corroborated by local authorities and beneficiaries?
4.4 Obtain free, prior and What documentary proof can you provide that consent is MCHO, MS, CM, LG
informed consent before acquiring obtained prior to acquiring land or property for mining
land or property. operations? Are there any surface rights agreements and
documentary evidence of compensation being paid to legal
land right holders? Can local authorities corroborate
adherence to appropriate regulatory practices?
4.5 Understand the situation and Provide evidence that your company strives to understand MCHO, MS, LG,
perspectives of the women in the the perspective of women in the company, and that MCW, CM
company’s area of influence and company operations have gender sensitive approaches.
design and implement company’s Does the company have a written gender policy? Is there
operations in a gender sensitive way. evidence that the company has done gender analysis of its
activities that impact on local communities and that it tries
to mainstream gender in all its activities?

Members

Standards Questions Respondents/Site
5.1 Carry out an environment Provide evidence that the company has carried out an MCHO, MS, MSS,
impact assessment as the basis for environmental impact assessment for all its operations LG, CM
developing an environmental and that this was the basis for environmental
management and protection plan management plan. Does the company understand its
and strategy. obligations with regards to environmental protection?
Is there evidence that the company is monitoring the
environmental impacts of its activities and managing
them, e.g. policies and procedures? Can this be
corroborated by site inspection?
5.2 Properly treat or dispose of What evidence can you provide that your company has MCHO, MS, MSS,
hazardous material and waste from a plan for the treatment and disposal of hazardous M, MCW
its site(s). material and waste from its operating sites? Is there
evidence of implementation proper handling of waste
and hazardous material e.g. policies and procedures,
and is this supported by site inspection?
5.3 Provide a plan for mine closure Provide evidence that you have made financial MCHO, OGMR
and make provision for the full costs provision for the full cost of rehabilitation. Is there
of rehabilitation upon closure mine closure plan?

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3.2 Indicators

The development of indicators and the scale of evaluation are linked to the level descriptors
of each standard. These are summarised in the Tables 9‐13 below.

Table 9: Indicators for standards relating to Principle 1, of the CTC‐standard set ‐ Origin and
volumes of produced goods as well as company payments to host government are
transparent

Standard Indicators
1.1 Origin and production For both producer and buyer: 1. Declaration documents
volume of minerals from
the mine site throughout 2. Documented procedure (illustrated trading chain), supported by a) analysis certificates, b)
the trading chain are weights of consignments, c) payment vouchers, d) signatures of security personnel who
traceable safeguard shipments
3. Sight sealed packed mineral for shipment
4. Shipment documents, including export license
5. Declaration of production to Min. of Forestry and Mines and OGMR
6. Company records of production (mine source), in country freighting, export
7. Documented knowledge of characteristics of own mineral material through third party lab
analysis
8. Evidence of sufficient security and the effective use in expediting shipments
8. Demonstrated willingness to participate in AFP e.g. previous analytical results, written
policy document
1.2 Meet fiscal obligations All: 1. Company's own record of remittances to govt
required by host 2. Govt record of remittances received from company
government law.
1.3 Publish all payments All: 1. Company records of all publication of remittances sighted
made to government
2. Evidence of publication from independent source sighted
according to internationally
accepted standards. 3. According to international best practice, EITI
1.4 Actively oppose 1. Policy document sighted
bribery and fraudulent 2. Evidence that all role‐players referred to have been made aware of it, minutes of meetings,
payments communication etc.

Table 10: Indicators for standards relating to Principle 2, of the CTC‐standard set ‐ The
company does not use child labour and ensures fair remuneration and work conditions as well
as continual improvement of health and safety measures for all employees
Standard Indicators
2.1 Pricing and 1. Documentary evidence of salary employees level benchmarking; or process by which the
distribution systems for payments to ASM and ASM contractors is calculated
artisanal miners and sub‐ 2. Inspection of remuneration of employees showing salaries to be higher than average;
contractors, as well inspection of payment records of ASM to indicate how regularly they are and the
as salary levels for compensation levels compared to the value of material they produce
employees are fair, legal, 3. Verbal indication from ASM that they understand and accept the method by which their
and regulated. payments are made and calculated and paid
2.2 Ensure that no 1. Record of all workers showing their date of births and none are below the age of 16 years
child labourers (age or were under age at the time they were engaged
under 16) work on 2. Evidence that the people responsible for hiring at the mining sites are aware they
company sites. should not hire anyone below the age of 16 years
3. Inspection of sites to ensure that there are no workers under 16 years of age
2.3 Support workers’ 1. Documents (minutes of meetings, communication etc.) indicating that the company has
organizations and been actively fostering efforts by workers to form their own workers' organisation
collective bargaining. 2. Workers are allowed to take time off from work for workers committee meetings
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2.4 Provide essential 1. Documentary evidence that the company has bought and distributed PPEs and
protective safety production equipment to workers
equipment to workers 2. Evidence that all workers have PPEs and production equipment (by inspection)
and production services 3. Evidence that the artisanal miners are being assisted in being productive, through the
to support the work of provision of such services as e.g. blasting, opening up new ground with excavators, closing
artisanal miners up used areas with bulldozers
2.5 Ensure 1. Documentary evidence of a company policy and procedures regarding health and safety
occupational health in all 2. Evidence of awareness of health and safety requirements by workers/miners (verbal,
company operations as training records, observation etc.)
well as insurance for 3. Documentary evidence that the company has taken out insurance to cover all employees
workers for occupational health and safety
4. Documentary evidence that the company provides health and safety training to the
workers/miners (e.g. Training materials, attendance registers)
5. Documentary evidence of the working of the H&S procedures through handling of past
incidents
6. Evidence that the company tries to keep work related injuries at a minimum, e.g. warning
signs, training, management responsibility, sanction for non‐compliance and reward for
compliance etc.
7. Evidence of high level of awareness in workers/miners on the need for proper health and
safety handling
8. Evidence that workers/miners have the knowledge and skills for efficient production
2.6 Provide training for 1. Documentary evidence that company has dedicated staff to give workers/miners regular
workers on safety, health training on health and safety and efficient production methods (e.g. Names of staff, record
and effective use of on‐ of the qualification of the training staff, job description of the staff, HRD records)
site facilities 2. Record that the company staff has given training to miners/workers (e.g. training
manuals, attendance registers etc.)

company ensures security on company sites whilst respecting human rights.

Standard Indicators
3.1 Provide sufficient 1. Documentary evidence of the company security policies and procedures
and adequately trained 2. Documentary evidence that the company has security staff (HRD records of employment)
security forces. or has contracted a security company to provide security at the mining sites and other
areas of the operation that need security (signed valid contract)
3. Evidence that the security company has the capability to provide adequate security
4. Documentary evidence of how the security system is being managed through inspection
of record of handling of past incidents
5. Documentary evidence of low number of security breaches
6. No evidence of human rights abuses (enquiries with local communities and authorities)
3.2 Undertake security 1. Documentary evidence that the company undertakes security risk assessment (e.g.
risk assessments. Security risk assessment reports)
2. Evidence that the company security policies and procedures are derived from the
security assessment exercise (e.g. Training manuals, written procedures, security
management reports)

company consults communities in which it operates and contributes to their social, economic
and institutional development taking into account genders.

Standard Indicators
4.1 Interact regularly 1. Documentary evidence of the existence of Community Forum (CF) representative of the
with communities and community concerned (e.g. Name and copies of registration/constitution of CF, names of
local governments to representatives of the CF (e.g. Committee members)
address grievances and 2. Evidence of communication with CF and that concerns and grievances are being addressed
other common concerns. (e.g. minutes of meetings, letters, public notices, verbal reports by community members
4.2 Support local 1. Company policy on local procurement from SMEs,
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enterprises to supply 2. Documentary evidence of actual procurement (e.g. Purchase orders, contracts, payments
company operations. vouchers/transaction records),
3. Evidence of the support of the development of local suppliers (e.g. Procurement/tender
notices, list of local suppliers etc.)
4.3 Support integrated 1. Company policy on integrated development for neighbouring communities
development programs in
nearby communities for 2. Evidence in company budget of funds set aside for development (e.g. Company financials)
livelihood security, social 3. Record of expenditure on community development projects
and physical 4. Existence of physical structures funded by the company's community development funds,
infrastructure and
capacity building 5. Verbal testimonials of community members that have benefited from the company's
development program,
6. Record of consultation with the CF in the development of the community projects
7. Record that the Community development program developed by the company and the
community fits in with local, regional and national development strategies/plans
4.4 Obtain free, prior 1. Documentary evidence of broad and deep (all stakeholders ‐ interested and affected parties)
and informed consent consultation in the processing of acquiring surface rights by the company (e.g. Minutes of
before acquiring land or meetings, communication, public notices, attendance registers, capacity building of
property. communities to negotiate fairly),
2. Record of the equitable settlement of compensation for acquisition of surface rights
4.5 Understand the 1. Documentary evidence of a gender sensitive approach in all company dealings (employment,
situation and community consultation, community benefits etc.
perspectives of the 2. Evidence of policies to achieve gender equity in the company (e.g. Capacity building and
women in the company’s women's empowerment interventions etc.)
area of influence and
design and implement
company’s operations in
a gender sensitive way.

company seeks continual improvement of its environmental performance.

Standards Indicators
5.1 Carry out an 1. Documentary of the existence of an EIA/EMP of compiled according to international best
environment impact practice, and in line with national requirements (e.g. EIA/EMP documents)
assessment as the basis 2. Evidence that the EIA/EMP documents were informed by proper consultation with all
for developing an interested and affected parties
environmental 3.Evidence of the existence of a system being used to implement and manage the EIA/EMP
management and 4. Record of monitoring and management of all impacts (e.g. procedures, reports to
protection plan and government authorities etc.)
strategy.
5.2 Properly treat or 1. Documentary of the existence of a company policies and procedures on handling waste and
dispose of hazardous hazardous materials
material and waste from
its site(s).
2. Evidence of current management of waste and hazardous materials, (e.g. sighting of well
managed dedicated disposal areas, notices to warn of hazard, manuals on handling hazardous
materials and waste, training session registers, waste separation and recycling areas etc.
5.3 Provide a plan for 1. Environmental management plan indicating the expected cost of rehabilitation
mine closure and make 2. Documentary proof deposit or insurance or surety or financial guarantee for the
provision for the full costs rehabilitation program.
of rehabilitation
upon closure

15
3.3 Level Descriptors

General definitions
The following definitions apply to all CTC standards as shown below:
 Company (producer): legal mineral producing entity and mineral concession license
holder; “producer” also includes mining cooperatives provided they comply with the
above definition.
 Employee: person directly employed by a company (producer) and receiving a regular
salary.
 Subcontractor: head of artisanal mining group supervising artisanal mining activities,
communicating with company staff, and organizing payment of individual artisanal
miners (on behalf of the company) within a given group of miners.
 Artisanal miner: person who is working on the concession area of a given company
(producer) and, indirectly, provides services to and receives payment from the
company through the artisanal mining group leader (the sub‐contractor).
 Workers: includes employees, sub‐contractors, and artisanal miners.

Table 14: Level descriptors for the standards in Principle area 1 ‐ Origin and volumes of
produced goods as well as company payments to host government are transparent.
Explanations for Guideline 1.1: 1 Buyer: entity purchasing minerals from a producer; for
auditing purposes, it is the responsibility of the producer to facilitate auditor access to buyer
documentation relevant for traceability. 2 Declaration of mineral shipments at import sites
only refers to situations where the producer and the importer are in a business relationship. 3
“Appropriate measures” refers to (1) secure mineral storage sites; (2) the presence of adequate
security forces to ensure the physical integrity of a mineral shipment with optional sealing for
company‐internal transportation (e.g., from mine site to processing plant); (3) sealing of individual
mineral transport bags/containers and adequate security presence once the ownership of the material
shifts from one party to another (e.g., from producer to buyer). 4 AFP refers to the Analytical
Fingerprint technique developed at the Federal Institute of Geosciences and Natural
Resources (BGR) as defined in the document BGR (2010), Analytical Fingerprint (AFP), July
2010 update. Explanations for Guideline 1.3: A reference for an internationally accepted
standard is the Extractive Industry Transparency Initiative (EITI).
1.1 Origin and production volume of 4 = Producer and buyer1 plausibly declare amount, type, and origin of mineral
minerals from the mine site throughout shipments clearly, correctly and verifiably at the mine, at points where material is
2
the aggregated, as well as at export and import sites. Producer and buyer take
3
trading chain are traceable appropriate measures to ensure the integrity of mineral shipments and allow for
4
an independent third party to take any mineral sample at any time for AFP
analysis.
3 = The producer plausibly declares amount, type and origin of mineral shipments
clearly, correctly and verifiably at the mine and at points where material is
16
aggregated. The producer takes appropriate measures to ensure the integrity of
mineral shipments and allows for an independent third party to take any mineral
sample at any time for AFP analysis.
2 = The producer’s declaration of amount, type and origin of mineral shipments is
not clear, but the producer takes appropriate measures to ensure the integrity of
mineral shipments and allows for an independent third party verification and to
take mineral samples at any time for AFP analysis.
1 = The producer’s declaration of amount, type and origin of mineral shipments is
not clear and not verifiable; the producer does not take appropriate measures to
ensure the integrity of mineral shipments and/or does not allow for an
independent third party to take any mineral sample at any time for AFP analysis.
0 = The producer does not document any mineral shipments.

1.2 Meet fiscal obligations required by 4 = The company meets all of its fiscal obligations required by host government
host government law. law.
3 = The company meets most of its fiscal obligations required by host government
law.
2 = The company seeks to avoid its fiscal obligations required by host government
law.
1 = The company occasionally avoids meeting its fiscal obligations required by
host government law by referring to other regulations.
0 = The company avoids meeting its fiscal obligations on a regular basis required
by host government law and other regulations.

1.3 Publish all payments made to 4 = The company publishes all payments made to government authorities
government according to internationally according to internationally accepted standards.
accepted standards. 3 = The company publishes most of the payments made to government
authorities according to internationally accepted standards.
2 = The company publishes most of the payments made to government
authorities but not according to internationally accepted standards.
1 = The company does not publish payments made to government yet discloses
payments if requested.
0 = The company does not publish payments made to government and does not
disclose payments to third party observers.

1.4 Actively oppose bribery and 4 = A written company‐wide policy forbids officials, employees, partners and sub‐
fraudulent payments contractors from accepting fraudulent payments or making them to government
officials; the policy is actively promoted and enforced by company management.
3 = A written company‐wide policy forbids officials and employees from accepting
fraudulent payments or making them to government officials; the policy is
actively promoted and enforced by company management.
2 = An unwritten company‐wide policy forbids company personnel from accepting
fraudulent payments or making them to government officials.
1 = The company discourages accepting fraudulent payments or making them to
government officials recognizing all the while that some payments may be
necessary and therefore leaves the decision to site managers.
0 = The company regards fraudulent payments as a part of doing business.

Table 15: Level descriptors for the standards in Principle area 2 ‐ The company does not use
child labour and ensures fair remuneration and work conditions as well as continual
improvement of health and safety measures for all employees. Explanations for Guideline:
2.1: 1 at least once a month. 2 “fair” refers to a pricing system applied by the company which
is verifiable and broadly reflects world market prices for the mined commodity.
2.1 Pricing and distribution systems 4 = Gross salary of employees is at least equal to the salary level of comparable
for artisanal miners and sub‐ enterprises in Rwanda. Payments sub‐contractors receive for their delivered
1 2
contractors, as well as salary levels for products are regular and fair . The company verifies or spot‐checks that artisanal
employees are fair, legal, and miners receive due payments from sub‐contractors.
regulated. 3 = Gross salary of employees is at least equal to the salary level of comparable
17
enterprises in Rwanda. Payments sub‐contractors receive for their delivered
products are regular and fair.
2 = Gross salary of employees is equal or slightly inferior to the salary level of
comparable enterprises in Rwanda. Payments sub‐contractors receive for their
delivered products are somewhat regular and apparently fair (although the pricing
system applied by the company is not verifiable).
1 = Gross salary of employees is equal or significantly inferior to the salary level of
delivered products are somewhat regular and potentially inadequate.
0 = Gross salary of employees is significantly inferior to the salary level of
delivered products are irregular and inadequate.

2.2 Ensure that no child labourers 4 = Company documentation indicates no child labourers under the age of 16
(age under 16) work on company sites. working on its sites, and this is verified by site inspections.
3 = The company claims, without documentation, that no child labourers under the
age of 16 work on its sites, and this is verified by site inspections.
2 = The company acknowledges that, in spite of its efforts, a small number of child
labourers under the age of 16 work on its sites.
1 = There is evidence of a few child labourers under the age of 16 working on the
sites.
0 = There are significant numbers of child labourers under the age of 16 working on
the sites.

2.3 Support workers’ organizations 4 = The company supports workers’ efforts to form a workers’ organization and to
and collective bargaining. engage in collective bargaining.
3 = The company allows the formation of a workers’ organization but does not
actively support it or its efforts to initiate collective bargaining.
2 = The company remains neutral regarding the formation of a workers’
organization; it has not, however, made an effort to support a discussion of
workers’ organizations and collective bargaining.
1 = The company restricts the conditions under which a workers’ organization can
be formed and allowed to operate and is reluctant to engage in collective
bargaining.
0 = The company actively opposes the formation of a workers’ organization and any
initiative at collective bargaining.

2.4 Provide essential protective 4 = The company provides essential protective safety equipment (appropriate for
safety equipment to workers and the specific risks associated with a specific type of work) to workers and production
production services services to support the work of artisanal groups working on its sites.
to support the work of artisanal miners 3 = The company provides most of the essential protective safety equipment
(appropriate for the specific risks associated with a specific type of work) for
workers and some production services to support the work of artisanal groups
working on its sites.
2 = The company provides very little protective safety equipment for workers
(appropriate for the specific risks associated with a specific type of work) and
minimal production services to support the work of artisanal groups working on its
sites.
1 = The company does not provide protective safety equipment (appropriate for the
specific risks associated with a specific type of work) for workers or production
services to support the work of artisanal groups working on its sites though it does
not oppose doing so.
0 = The company obliges artisanal groups to work on their own and resists any
intervention.

2.5 Ensure occupational health in all 4 = Occupational injuries and work‐related health problems are minimal and when
company operations as well as they occur the company takes immediate measures to assist in treating them. The
insurance for company meets all of its obligations for insurance for workers.
workers 3 = Occupational injuries and work related health problems occur occasionally and
when they occur the company takes measures to assist in treating them. The
company meets most of its obligations for insurance for workers.
18
2 = Occupational injuries and work related health problems occur occasionally and
the company is willing to help but does not have a clear procedure for treating
them. The company meets most of its obligations for insurance for workers.
1 = Occupational injuries and work‐related health problems are frequent and the
company takes no responsibility in treating them. The company only partly meets
its obligations for insurance for workers.
0 = The company takes no responsibility for the health and safety of workers. The
company does not meet its obligations for insurance for workers.

2.6 Provide training for workers on 4 = A dedicated training staff offers training courses regularly on safety, health and
safety, health and effective use of on‐ effective use of on‐site production facilities.
site facilities
3 = Company personnel offer training courses regularly on safety, health and
effective use of on‐site production facilities as part of their on‐going responsibilities.
2 = Company personnel offer training courses occasionally on safety, health and
effective use of onsite production facilities.
1 = Maintaining safe practices is the informal responsibility of foremen or other on‐
site operators and the company makes no special provisions to promote safe
practices.
0 = The company has no intention of organizing training for workers.

Table 16: Level descriptors for the standards in Principle area 3 ‐ The company ensures
security on company sites whilst respecting human rights.
3.1 Provide sufficient and 4 = A sufficient number of security forces, whether private or public, are trained to
adequately trained security forces. carry out their work professionally to protect the site as well as to protect the well‐
being and human rights of workers also ensuring it is not at the expense of the
security of nearby communities.
3 = A sufficient number of security forces, whether private or public, are trained
primarily to deter thefts but are not concerned with the safety, well being and
human rights of workers and nearby communities.
2 = A sufficient number of security forces, whether private or public, are present on
the site to deter thefts but have received no professional training.
1 = An insufficient number of inadequately trained security forces, whether private
or public, are present on the site.
0 = The security forces appear irregularly and are ineffective in protecting against
breaches of security and/or are known to abuse human rights of workers and nearby
communities with impunity.

3.2 Undertake security risk 4 = Formal internal risk assessments are conducted regularly by security
assessments. departments and used to develop security policy, train and deploy public and/or
private forces.
3 = Informal risk assessment investigations are conducted by security departments
and used to develop security policy, train and deploy public and/or private forces.
2 = Risk assessment investigations are occasionally conducted but not used to
develop security policy, train and deploy public and/or private forces.
1 = The importance of risk assessments is acknowledged but they are rarely
conducted and when they are, they are not used to develop security policy, train
and deploy public and/or private forces.
0 = Risk assessments are not carried out.

19
Table 17: Level descriptors for the standards in Principle area 4 ‐ The company consults
communities in which it operates and contributes to their social, economic and institutional
development taking into account genders.
4.1 Interact regularly with 4 = The company meets regularly with a body of representatives from nearby
communities and local governments to communities to address grievances and other community concerns; representatives
address grievances and other common are chosen by the communities to represent diverse interests and affiliations.
concerns.
3 = The company meets irregularly with a body of representatives from nearby
communities to address grievances and other community concerns; representatives
are chosen by communities to represent diverse interests and affiliations.
2 = The company has met once or twice with representatives from nearby
communities to address grievances and other community concerns; representatives
are chosen by local leaders.
1 = Company/community interaction is restricted to occasional interaction with one
or two local leaders.
0 = There is no company/community interaction.

4.2 Support local enterprises to 4 = The company supports small and medium enterprises which provide essential
supply company operations. supplies and services to the mining operations and generate income for local
populations.
3 = The company purchases supplies locally where materials are available and has
the intention of contributing to the development of small and medium enterprises
capable of providing needed supplies and services.
2 = The company does not support local but has intentions of doing so.
1 = The company recognizes the value of supporting local supply chain development
but has taken no initiatives.
0 = The company is opposed to supporting local supply chain development.

4.3 Support integrated development 4 = The company’s local development strategy includes support for long‐term
programs in nearby communities for livelihood security, building of social and physical infrastructure and capacity building
livelihood security, social and physical at the local and regional level.
infrastructure and capacity building 3 = The company’s local development strategy is limited to support for long term
livelihood security and construction of social and physical infrastructure at the local
and regional level.
2 = The company’s local development strategy is limited to support for construction
of social and physical infrastructure at the local level.
1 = The company intends, at some point in the future, to articulate and support a
local development strategy.
0 = The company shows little interest in promoting local development.

4.4 Obtain free, prior and informed 4 = Acquisition of lands, trees or bushes, water bodies, and residences in the area of
consent before acquiring land or the site has taken place with full consultation between the company and local and
property. central authorities and all claims have been settled equitably.
3 = Although acquisition of lands, trees and residences in the area of the site has
taken place without consultation between the company and local and central
authorities, no claims or disputes have arisen.
2 = Acquisition of lands, trees and residences in the area of the site has taken place
without consultation with local and central authorities and some claims remain
under dispute.
1 = Acquisition of lands, trees and residences in the area of the site has taken place
without consultation between the company and local and central government
authorities; communities are seeking legal redress for their claims.
0 = Acquisition of lands, trees and residence is carried out by the company with little
regard for the consequences; the company ignores community claims for redress.

4.5 Understand the situation and 4 = Based on investigations on the impact its operations has for women, the
perspectives of the women in the company has developed policies and is implementing a strategy to ensure a positive
company’s area of influence and design impact on women in its workforce and in nearby communities.
20
and implement company’s operations 3 = The company has undertaken investigations on the impact its operations has for
in a gender sensitive way. women, but has not yet developed policies and/or implemented strategies to ensure
a positive impact on women in its workforce and in nearby communities.
2 = The company has committed itself to undertaking an assessment of the impact
its operations has for women in the near future.
1 = The company has no investigations on the impact of its operations on women but
claims to respect gender issues in its company policies and strategies.
0 = The company is not aware of gender issues.
Table 18: Level descriptors for the standards in Principle area 5 ‐ The company seeks continual
improvement of its environmental performance.
5.1 Carry out an environment impact 4 = The company has completed an environmental impact assessment, and has
assessment as the basis for developing developed and is implementing an environmental management and protection plan
an environmental management and followed by regular reviews that aim to improve environmental performance.
protection plan and strategy. 3 = The company has completed an environmental impact assessment but has not
yet developed and/or implemented an environmental management and protection
plan.
2 = The company has committed itself to completing an environmental impact
assessment in the near future.
1 = The company claims to practice environmental protection but has no immediate
plans to complete an environmental impact assessment and does not have a
documented environmental management plan.
0 = The company is not concerned about its environmental impacts.

5.2 Properly treat or dispose of 4 = A systematic plan for the disposal of hazardous materials has been prepared and
hazardous material and waste from its implemented; waste rocks dumps and tailings dams are properly planned,
site(s). constructed, and their performance is monitored.
3 = A systematic plan for the disposal of hazardous materials has been prepared.
Hazardous materials and waste from site operations are reused or recycled, waste
rock dumps and tailings disposal are properly constructed.
2 = Hazardous materials and waste from site operations are disposed of responsibly
but no systematic plan has been prepared.
1 = Hazardous materials and waste from site operations are not disposed of
responsibly. However, the company has concrete plans to undertake hazardous
materials and waste disposal.
0 = Hazardous materials and waste from site operations are not disposed of
responsibly and no systematic plan for hazardous material disposal, waste rock
dumps and tailings disposal is envisaged.

5.3 Provide a plan for mine closure 4 = A mine closure plan exists and the site operation makes provision to cover the
and make provision for the full costs of full costs of rehabilitation and any monitoring or treatment that may be required
rehabilitation after closure; the adequacy of plans and provisions is reassessed regularly.
upon closure 3 = A mine closure plan exists and the site operation makes provision to cover the
full costs of rehabilitation and any monitoring or treatment that may be required
after closure.
2 = A mine closure plan exists and the site operation makes provisions to partially
cover costs of rehabilitation and any monitoring or treatment that may be required
after closure.
1 = A mine closure plan does not yet exist, and no provisions have yet been made to
cover costs of rehabilitation and any monitoring or treatment that may be required
after closure; however; there is intent to do provide a plan and to make provisions
in the future.
0 = A mine closure plan does not exist and no provisions have been made.
21
4. Scheduling

Table 19: Implementation Schedule for Certification Audits. Blue shaded rows indicate
activities carried out outside Rwanda.

Rutongo GMC/ Pyramides WMP/ NRD Phoenix Audit Report Results
MPA RMMC prep. writing presentation

Fri 15‐Oct 1
Sat 16‐Oct 1
Sun 17‐Oct
1
Mon 18‐Oct
Tues 19‐Oct 0.75 0.25
Wed 20‐Oct 0.75 0.25

week 42
Thurs 21‐Oct 1
Frid 22‐Oct 1
Sat 23‐Oct 1
Sun 24‐Oct
Mon 25‐Oct 1
Tues 26‐Oct 1
Wed 27‐Oct 1
week 43
Thurs 28‐Oct 1
Frid 29‐Oct 1
Sat 30‐Oct 1
31‐Oct
Sun
Mon 01‐Nov 0.5 0.5
Tues 02‐Nov 1
Wed 03‐Nov 1
week 44
Thurs 04‐Nov 1
Frid 05‐Nov 0.25 0.75
Sat 06‐Nov 1
Sun 07‐Nov
Mon 08‐Nov 1
Tues 09‐Nov 1
Wed 10‐Nov 1
week 45
Thurs 11‐Nov 1
Frid 12‐Nov 1
Sat 13‐Nov 1
Sun 14‐Nov
Mon 15‐Nov
Tues 16‐Nov
Wed 17‐Nov
week 46
Thurs 18‐Nov
Frid 19‐Nov
Sat 20‐Nov
Sun 21‐Nov
22
Mon 22‐Nov 1
Tues 23‐Nov 1
Wed 24‐Nov 1
week 47
Thurs 25‐Nov 1
Frid 26‐Nov 1
Sat 27‐Nov
Sun 28‐Nov
Mon 29‐Nov 1
Tues 30‐Nov 1
Wed 01‐Dec 1
week 48
Thurs 02‐Dec 1
Frid 03‐Dec 1
Sat 04‐Dec
Sun 05‐Dec 1
Mon 06‐Dec 1
Tues 07‐Dec 1
Wed 08‐Dec 1
week 49
Thurs 09‐Dec 1
Frid 10‐Dec 1
Sat 11‐Dec 1
Sun 12‐Dec
Mon 13‐Dec 1
Tue 14‐Dec 1
Wed 15‐Dec 1
week 50
Thu 16‐Dec 1
Fri 17‐Dec 1
Sat 18‐Dec 1
Sun 19‐Dec
Mon 20‐Dec 1
Tue 21‐Dec
Wed 22‐Dec

Total
days 4.5 4.25 3.75 5 5.5 0.5 3 22.5 0

23

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