There is a gap between current industry ethical standards and the difficult conditions in the poor rural areas where CMINC operates. CMINC is addressing this gap by adopting an ethical policy based on Transparency that extends compliance with international standards to our unusual environment.
Current standards are successful, but they are generally based on a consensus from the relatively wealthy countries that consume most of the world’s gold. The standards work best when gold is supplied from a mine operated by a single entity (whether private company or artisanal cooperative) where the entity has a strong commercial incentive to secure custody of its gold from extraction to delivery. The entity can thus claim full responsibility for standard compliance.
Community mining challenges these standards because a) each family is responsible for sourcing its own gold, b) the families are dispersed across vast remote areas with difficult transport and communications, and c) new ethical rules take considerable time to publicize, let alone teach and understand.
These challenges WILL cause misunderstandings and mistakes. As Community mining grows, it will also always be, and perhaps should always be, subject to criticism and allegations of ethical violations, whether substantiated or not.
Ethical Policy Statement:
“Given its difficult operating environment, CMINC understands that ethical misunderstandings and errors will occur. CMINC is committed to addressing such misunderstandings and errors as opportunities to learn and improve its operations. We thus welcome any information regarding possible ethical breaches.”
In practice, CMINC documents ethical incidents involving third parties, village miners, and/or CMINC staff. The incidents are classified into categories: Sourcing (money laundering) S, Labor L, Mercury M, Bribery & Corruption C, and Intimidation I.
CMINC is also developing a system for the public to report suspected ethical breaches. In cases where there is insufficient information and/or credibility for CMINC itself to investigate an allegation, CMINC plans to grant access to its records and operations to a respected third party auditor who can conduct investigations in Cameroon. With CMINC’s full support, a reporter can ask for a quotation and hire the auditor for an independent investigation of the allegation.
A redacted summary of past ethical incidents is presented below:
Incident 1L – When evaluating a possible village mine for admission to CMINC, a child was seen in a washing pit. Investigations showed that the village school had been closed due to a funder problem. The child was not working but being supervised by parents. A US$500 donation was left at the villagers’ discretion which they eventually used to build parts of a new school.
Incident 2C – When visiting a partner mine, a CMINC team is stopped by local security authorities, forced to stay overnight and to purchase drinks for them. The team is then asked for a bribe to be allowed to continue their journey. The CMINC team refused and leaves. The villagers of the partner mine visit CMINC in Yaoundé to explain that they do not support the security authorities, and offer to transport their gold themselves to CMINC. CMINC cannot accept this gold under its Anti-Money Laundering Policy, and has been searching for a solution to the situation. In the meantime, collections have been suspended.
Incident 3M – A test for Mercury was conducted on a sample received from a village. The test was positive but was conducted in Yaoundé and was not sophisticated enough to provide a certificate of content and may be unreliable. CMINC gave a stern warning to the villagers and is following up on the incident include a) developing Mercury awareness material for distribution and b) exploring options for better Hg testing locally.
Incident 4CI – A Member of Parliament (MP) and a foreigner resident in Cameroon appeared at a partner mine and claimed the mine as their own. The foreigner demanded that all the villagers leave. CMINC investigated and discovered that the MP and foreigner were operating other mines in the area with faulty documents. On behalf of the villagers, CMINC produced documentation supporting the villagers rights to the authorities. The foreigner apologized. There are rumors that a disgruntled village member may have gone to the MP with information regarding the villages mining potential with CMINC in the hope of discrediting the Village chief and securing funds for himself.
Incident 5CI – A local Public Prosecutor (PP) filed an injunction involving an up coming draft report from the local mining authority which alleges a series of false environmental violations at a partner village mining site. CMINC meets with the authority and the villagers several times. The report is changed correctly describing the situation. There are rumors that the PP intended to use the court action to extort funds from the villagers.