Western advocacy led to policies focused on derisking supply chains and virtue signaling toconsumers, rather than improving artisanal miners’ living conditions or addressing the conflict’s rootcauses.

(Kamundala, 2017)

e ASM sector is an important source of livelihood,creating employment and providing income for hundreds of thousandsof people, and on which several millions of other people depend(World Bank, 2008; Pact, 2010; Kamundala and Mukasa, 2017;Chipangura, 2019; Kemp and Owen, 2019; Sovacool, 2019).

The most emblematic dispute occurred on the hillside of Bisie, in the Walikale territory (NorthKivu) between the company Alphamin Bisie Mining SARL (ABM) and the local artisanal miners, sometimessupported by Mai-Mai NDC Sheka (then NDC Rénové), as it lasted nearly 15 years (2002-2016). 73 In 2017,the dispute between the two parties was completely solved through the signature of an accord thatforesaw voluntarily transition to a new location or vocation for Bisie’s miners

This said, experts have criticised in articles and forums that it was the minerswho were carrying the burden of the due diligence costs

Mining authorities and traders78 told the Group that from September 2021 to atleast March 2022, illicit cross-border trading in untagged coltan 79 from mines inMasisi territory into Rwanda had increased. This was confirmed by the InternationalTin Association (ITA) (see annex 44). Four private sector sources described how theincreased smuggling was due to, inter alia, the creation of a new joint venture, CongoFair Mining, in December 2020 and changes in buying practices on the part of coltantrading houses in Goma (see annex 45).79. A criminal network of traders, including some COOPERAMMA members, withthe support of Robert Habinshuti Seninga (see S/2021/560, para. 64),80 transportedhundreds of kilograms of coltan from mines in Masisi territory to Go ma, together withvarying quantities of tourmaline from the Rukaza mine (see S/2021/560, para. 62).From Goma, the minerals were being smuggled into Rwanda for onward sale (seeannex 46). This compromised the integrity of some coltan supply chains in Rwandacovered by the International Tin Supply Chain initiative (ITSCI) for responsiblesupply chains of ITA. Rwandan authorities told the Group that no smuggled mineralshad been intercepted in Rwanda in 2020 or 2021.80. Congolese authorities took steps to intercept the illicit trading. In February2022, they apprehended several hundreds of thousands of dollars’ worth of untaggedcoltan intended for transport to Goma. One load was accompanied by an FARDCmember (see annex 47)

Manual of Traceability Proceduresin force in the DRC

Complementing their disclosures