Frequently Asked Questions

CRAFT was born from a need to depart from the most critical issuesthat are sometimes associated with mining and marketing minerals originating from ASM. That is why firstly, CRAFT proposes evaluating and taking measures to perform practices that guarantee respect for human rights and guarantee their operations are free from conflict, crime, and environmental contamination.

CRAFT proposes a gradual compliance. This means that it starts by presenting that the activity of the group of miners is legitimate, in other words, it has the legal authorizations or agreements to be able to operate or market. Thus begins the route of formalization and access to formal trade. Then it must show that its operation is free from unfavorable practices related to human rights violations and crimes, and is committed to improving related to the environment, mining safety, etc.

The publication mentions CRAFT as an existing tool to assess due diligence in artisanal and small-scale mining.

The implementation of CRAFT, in most cases, will be the shared responsibility of the producers of the ASM and the CRAFT Schemes. Although the ASM producer always holds primary responsibility as an entity to make verifiable statements and mitigate risks, it is the responsibility of the CRAFT schemesto support ASM producers in their tasks to the extent possible. In the case of buyers as owners of the CRAFT schemes, they are supplying from the ASMproducer, and in all other cases facilitate the engagement of ASM producers with the buyers.

Being a CRAFT scheme means that you are a buyer of minerals, governments or other types of organizations that take the CRAFT as a “base” document respecting its logic, structure and content (requirements), however, in turn you can adapt it to implement it in the supply programs, ASM projects and the development of national or local strategies in order to promote responsible ASM, etc. with the aim of sourcing from the ASM sector and/or contributing to its development.

CRAFT schemes are the supply chain actors who use, incorporate or build upon CRAFT to obtain minerals from ASM or to support the development of ASM.

The CRAFT emerged to be applied to the gold supply chain. However, this does not limit the fact that CRAFT can be taken to apply to other minerals. In fact, CRAFT uses the term PMAE because the requirements related to the OECD Due Diligence Guide that apply to mining activities for gold, could also apply to other mineral chains such as 3T (tugnestene, tantalum and tin), precious stones, cobalt, carbon. The only thing worth noting is that CRAFT v1.0 was developed by actors in the supply chain and experts related to gold.

It is highly recommended to use CRAFT with another mineral with different dynamics than gold. A development process is carried out with actors in the supply chainof that mineral to specify the key requirements that apply to said mineral or commodity. For version 2.0, it is expected that other topics prioritizing other minerals will be included to give greater scope to CRAFT products.

No, CRAFT is a code that facilitates the application of the OECD Due Diligence Guide and in turn establishes a route for improvementin other social, environmental, labor and organizational aspects for miners.

The CRAFT is not an ethical seal, but rather a toolto facilitate the collection of information and declaration of compliance with the criteria related to the OECD Due Diligence Guide, which is more focused on gradually addressing other risks associated with the activity of artisanal and small-scale mining.

It is indeed a standard. We can take as reference the definition that ISEAL provides, “Document that provides, for common and repeated use, rules, guidelines or characteristics for products or related processes and production methods, with which compliance is not mandatory”.

We prefer to call the CRAFT Code a “code” so as to avoid confusion about its voluntary nature. It is very common for mandatory (inter) national standards to be called standards (cf. ISO standards).

Miners

To begin to comply with the CRAFT, the minimum requirement is to be legitimate.The legitimacy of artisanal and small-scale mining is a difficult concept to define because it involves a series of specific factors for each situation. For the purposes of the OECD Guide, legitimate is understood, among others, to artisanal and small-scale mining that is in accordance with applicable laws. When the legal framework is not enforced, or in the absence of such a framework, the assessment of the legitimacy of artisanal and small-scale mining will take into account the good faith efforts of artisanal and small-scale miners and companies to operate within the applicable legal framework (if any), as well as their participation in formalization opportunities as they become available (taking into account that, in most cases, artisanal and small-scale miners have a very limited, insufficient or non-existent capacity, technical ability or financial resources to do so) … “(OECD 2016b)

“… In any case, artisanal and small-scale mining, like all kinds of mining, cannot be considered legitimate when it contributes to the conflicts and serious abuses associated with the extraction, transport or trade of minerals, from according to the definition in Annex II of the Guide. “

The application of the CRAFT allows artisanal and small-scale mining to show their efforts towards formalization and improvement interest.

The main incentives are to progress towards formalization, achieve a better reputation in the sector, meet theexpectationsof buyers, access the formal market under transparent conditions, develop management systems, define a path of positive change in its activity.

(Inter)national regulations and actions related to responsible supply chains are becoming more frequent, rigorous and mandatory. Since 2011 more than 65 (inter)national regulations have aimed at the respect of human rights by companies, and several of them have already become mandatory in certain countries such as France, the United Kingdom, the United States or Germany. The most emblematic case is that of the European regulation on conflict minerals (tin, tungsten, tantalum and gold) which explains that, from the year 2021, European companies that are supplying from conflict or high riskcountries will have to apply the guidelines of the OECD Due Diligence Guide, under penalty of being sanctioned.

For an ASM miner, complying with the CRAFT allows you to align yourself with the requirements that your buyer will demand and comply with (inter) national laws.

CRAFT as a code is a tool that can be used by a wide variety of actors, artisanal and small-scale mining (ASM) producers, mineral industry companiesthat source or intend to source from ASM , governments and other types of organizations like NGOs.

ASM producers or miners use it to understand the market needs for industry expectations from the due diligence process towards progressive improvement.
Refiners and companies can incorporate it as part of their ASM supply policies, as an instrument and initial support to carry out their due diligence and involvement with the sector.
Governmentscan take CRAFT as a guide to add to their policies and enforcement strategies and promote due diligence and strengthen legal supply chains and responsible mining.
Other types of organizations (NGOs, which include development projects for ASM) can use it to initiate accompaniment and define the path for the progressive improvement of miners interested in selling to the legal market, understand the needs of the market and help miners. to assess your compliance with the CRAFT.

The CRAFT requirements are the same if the scope covers miners and/or mineral aggregatorsor gatherers. What may happen is that some criteria do not apply due to the fact that at the level of the mineral gatherers there are no proper mining activities, such as the risks associated with extraction in underground mining. However, it is important to note that the scope of those who apply the CRAFT can include miners, aggregators or collectors and even processing plants as this scope refers to all those who work together to sell the mineral or metal to a formal buyer. For aggregators or gatherers and processing plants, it remains to be shown that throughout the chain that links them to miners, the risks are well managed.

The way to demonstrate it is by making CRAFT reports indicating how each criterion of the code is approached and fulfilled, the improvement proposals for a defined period are presented. Then it is updated showing the progress and new commitments. This can be considered as a management system for miners and a communication system with your formal buyers. This way you can then visit the facilities and validate these reports as part of your audits.

CRAFT reports are statements from the ASM produceron the fulfillment of each requirement. CRAFT reports that it is not a substitute for buyers’ due diligence exercise, but it is an excellent starting point to learn about the reality of your ASM provider.

CRAFT reports are the main instrument for managing and communicatingthe implementation of the CRAFT Code.

For example, buyers will review and verify the information provided by miners (the CRAFT Reports), ensuring that it is complete and reasonable. Said revision or audit of the reports will be the responsibility of the interested parties, such is the case as the buyers.

Industry companies that source from ASM

It differs in the fact that there is a real commitment to improve the conditions of the sector under the application of an internationally recognized code and that provides practical guidelines to show evidence of compliance.

CRAFT is a tool for applying due diligence in ASM, and therefore it is aligned with the OECD Due Diligence Guide’s intention to accompany international buyers and companies that source minerals relate to the sector and accompany them in their process of formalization, and also develop their suppliers’ capacities.

No, CRAFT is considered entry requirements related to Annex II of the OECD Due Diligence, however, it is not limited there. It also includes progress requirements that are not listed in the OECD GDD, but are key issues in ASM. This is so that ASM producers can begin accessing a legal market free of bad practices and later establish a path of improvement in other aspects that will allow them to later reach high-level standards.

No, CRAFT is considered entry criteria for those listed in Annex II of the OECD Due Diligence Guide. These represent the most criticaland concerning issues in supply chainsin terms of due diligence. However, this does not imply that the CRAFT requirements are only to be applied in these areas. Due diligence processes must be carried out regardless of the area where the extraction, processing, transport and marketing of minerals is carried out.

The LBMA has established a Responsible Gold Guidance to Refinersto combat systematic or widespread human rights abuses, avoid contributing to conflict, and meet high standards for combating money laundering and financing terrorism. This guide also reflects the guidelines of the OECD Due Diligence Guide. Complying with the guidelines of the Responsible Gold Guidance is essential for these refiners since it is a requirement to stay within the Good Delivery List, which is the group of refiners responsible for this association.

To meet the requirements of this Guide, Refiners must use the toolboxprovided by the LBMA itself which contains questionnaires that focus on artisanal and small-scale mining. Implementing the CRAFT Code allows these refiners not only to comply with the guidelines of the Responsible Gold Guide for Refiners in this sector of ASM, but also to go further in their due diligence by publicizing the way in which their suppliers are optimally managing risks.

For example, while implementing CRAFT, in the case of child labor, not only does it ask if the issue exists or not within its suppliers’ mining sites, but in addition, what kind of measures are you taking to mitigate the risk that minors are working in those sites.

CRAFT is a voluntary standard that follows ISEAL practices and was consulted and created by an international coalition linked to the gold supply chain. CRAFT is a public standard that can be used by different actors in mineral supply chains who are interested in ASM.

Instead, the SBGA criteria are the agreements defined by the members of the Swiss association on the requirements to be met by their ASM providers. CRAFT is quite aligned with these criteria as it takes the OECD Guide as a reference, however CRAFT explains in detail how to comply with each issue.

CRAFT is first made by the claims of artisanal and small-scale miners on how they meet each CRAFT criteria. It may be that the local or national buyer verifies these statementsor builds them togetherwith the miners. Validation is achieved as a result. In addition, there may be NGOs, governments or other types of organizationsthat verify these statements by comparing them with the existing reality of the miners.

These reports are then verified by independent third parties, and it remains the responsibility of the actors in the supply chain who wish to source from ASM.

CRAFT being an open source code under the Attribution-ShareAlike 4.0 International (CC BY-SA 4.0) license, means that it can be adapted, transformed and used, respecting its established criteria. The guidelines for the way it is applied can vary, but existing criteria should be maintained, unless they do not apply for a certain reason, due to the nature of the mining.

Attributionmeans if used, the respective credit must be used, provide a link to the type of license and indicate that changes were made.

ShareAlike indicates that if you mix, transform or build on CRAFT, your contributions must be distributed under the same license as CRAFT v1.0.

[1] https://creativecommons.org/licenses/by-sa/4.0/

These reports are then verified by independent third parties, and it remains the responsibility of the actors in the supply chain who wish to source from ASM.

CRAFT takes the logic of the OECD Five Step Framework and applies and adapts it to the ASM context.

Step 1: establish a Management system > adherence and application to CRAFT
Steps 2 and 3: risk identification, assessment and mitigation > CRAFT implementation
Steps 4 and 5: third-party audits and due diligence report> management tool with periodic reporting of CRAFT implementation and acceptance of receiving audits from its business partners.

CRAFT targets the needs of frameworks and regulations such as the OECD Due Diligence Guide (GDD), the United States Dodd-Frank Act, the European Union Minerals in Conflict Area Regulations and other related instruments that urge or require downstream actors to better understand and “eliminate risk” from their supply chains, and also to develop compliance processes and protocols for risk-based due diligence implementation and chain of custody or traceability systems .

Otherwise it can be said that it aims to provide an instrument for ASM and the overall industry to demonstrate their eligibility to sell and source minerals and metals from ASM, in accordance with the OECD Due Diligence Guide and legislation derived from this, such as the regulation of minerals in conflict areas of the EU that will be enforced in 2021.

CRAFT, passport to formal markets

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Frequently Asked Questions

Miners

Industry companies that source from ASM

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