The Canadian International Resources and Development Institute (CIRDI) has provided input to the Code of Risk Mitigation for Artisanal and Small-Scale Mining Engaging in Formal Trade (CRAFT) in response to a Request for Public Comment. CIRDI’s comments provide clarity to the market standard designed to mitigate the risk of downstream actors buying gold produced from artisanal and small-scale mining (ASM).
“Our input to the Code focuses on the implications for gender equality in the ASM sector, as well as for the unique role of indigenous communities in the sustainable stewardship of natural resources,” says Priya Bala-Miller, CIRDI Program Development Manager. “In this regard, the CRAFT Code represents a tremendous opportunity for transformative, sustainable and long-term market access for ASM communities.”
The CRAFT Code rightly recognizes that political will to limit exposure to minerals originating from areas of conflict and violence is on the rise in key markets. These efforts include the OECD Due Diligence Guidance, U.S. Dodd-Frank Act and the EU Conflict Minerals Regulation.
In this context, the CRAFT standard is a thoughtful response to ensure that ASM is not marginalized by the efforts of downstream supply chain actors to scale up their risk-based due diligence and traceability systems. CIRDI’s experience working with ASM communities in Colombia, Ecuador, Guyana, Ghana, Kenya, the Dominican Republic, and Indonesia informs our view that existing efforts to enhance sustainability do not reflect the contextually-specific challenges faced upstream by ASM in largely informal parts of global supply chains.
“CRAFT’s immediate development outcomes should explicitly state a clear business case for downstream buyers who should bear the cost burden,” says Bala-Miller. “Given that the Code seeks to mitigate the lack of a uniform market entry standard for ASM producers regardless of status, membership, and access to licensing, the heterogeneity permitted in the Code’s application process poses some constraints.”
An example of this concern lies in the broad interpretation of third-party verification standards for due diligence over CRAFT reports. The market advantage of such heterogeneity is not clear and could be rationalized further to avoid confusion in the ASM market.
CIRDI looks forward to seeing the further development and refinement of the CRAFT Code in ways that ensure that artisanal and small-scale miners are able to access formal supply chains, have the support that is necessary to improve their mining and processing practices, improve working conditions, and ultimately alleviate poverty.
CIRDI strongly recommends establishing performance criteria that speak to material gender issues in conflict-affected and high-risk areas. In addition, a stronger emphasis on the rights of indigenous peoples, particularly in terms of alternative systems of justice and ancestral property rights, would go a long way to strengthening the Code’s applicability and uptake.
For further information on how CIRDI is working to advance human rights and gender equality in natural resource governance contact Priya Bala-Miller at firstname.lastname@example.org