Introduction

‘I am Origins’ is a self-sustaining brand launched by the impact investment firm Chambers Federation with support from UKAID, USAID and the United Nations. Investing in the gold, cocoa, coffee and vanilla sectors in conflict-affected and high-risk areas of the Democratic Republic of Congo, Senegal, Mozambique, Kenya and Columbia, ‘Origins’ products are not just raw materials, but value-added products like roasted coffee, chocolate bars and gold wedding bands. It’s a new way of empowering women, responsible sourcing and in-country value-addition which recognizes the consumer demand for transparent, conflict-free, fair-trade, sustainable products. ‘Origins’ standards are implemented in the DRC by Fair Congo and managed by the Fair Congo Foundation, a cross section of professions from civil society, private, non-profit and development sectors. These standards define what it means to be ‘fair-trade’, ‘conflict-free’, eco-friendly’, and ‘organic’, with all of the benefits of the products increased value reaching the communities which produce them. ‘I am Origins’ aims to highlight those producers stories so consumers can know better not just where their products come from but who made it and how that economic opportunity brought peace and stability to their community.

Each step in our due diligence is summarized in reports for each individual export, structured to make our supply chain partners compliance process easier to manage. Each partner is encouraged to request customization to our reporting to fit their unique needs as well as visit our offices to view our processes first hand.

Management Team

All staff selected for employment have either worked directly for one of the Company’s development stakeholders or been vetted and referred to us by those same development stakeholders. At this time, the Company does not hire from the general public without these criteria being met first.

  • Gérant
    • Responsible for managing and executing the Company’s goals and strategies and presiding over the entire workforce. Oversees budgets and ensures resources are properly allocated. Ensures departments meet individual goals. Responsible for overall accountability to shareholders and stakeholders. Reviews DD reporting and export process and regularly audits to ensure management team compliance.
  • Directeur des finances
    • Responsible for overseeing and directing the Company’s financial goals, objectives, budgets and audits. Oversees and approves all DD reporting and export processes.
  • Chargé de la communication
    • Responsible for the public relations at a local level as well as international. Builds and sustains a company’s integrity. Writes and delivers press releases, social media postings and handles all communication sent to the public.
  • Agent logistique
    • Responsible for managing the transportation of personnel, all incoming materials and export process. Reports to the directeur des finances for senior management approval and verification.
  • Agent de conformité
    • Conducts all physical and desktop inspections, completes all inspections and due diligence reports. Reports to the directeur des finances for senior management approval and verification. Works with stakeholders, primarily civil society, to ensure overall supply chain integrity.

Due Diligence & Monitoring

Fair Congo (‘Origins’) due diligence standards have been developed in with our development stakeholders and industry organizations like the LBMA. Our process begins with civil society, local government and development stakeholders identifying our mine sites to be ‘green’ site validated. Once a desktop review of site logistics and production capacity is made our in-house agent de conformité (compliance officer) goes to the site to complete a pre-purchase site inspection and the ASGM DD form to evaluate each mine site and surrounding area. During each inspection, an ore sample is taken from each mine to catalog the XRF analysis, later used to supplement material traceability. DD continues with extensive documentation gathering as detailed in the ‘Origins’ Export Checklist, including KYC files completed on each organization or individual involved in the supply chain. Each cooperative is also trained to utilize our self-reporting tool which includes recording of any supply chain incidents

Due diligence is a never-ending process. Our agent de conformité continues to be randomly inspect sites along with our stakeholders, including civil society, completing new inspections every six to twelve months. Any sites reported through our Community Reporting Mechanism are immediately re-inspected, allowing a real-time response to any potential risks in the supply chain. Any incidents along the supply chain are documented and publicly disclosed both in an annual report as well as online.

Chain of Custody

Chain of custody is documented through a combination of transactional receipts from the mine site to the Fair Congo (‘Origins’) processing office as well as the use of tamper-evident, inventory-controlled security bags to prevent material contamination. Each cooperative partner already manually records all member sales, which data is captured and kept on record for any potential audit. Gold is placed into tamper-evident bags at each mine site with content details recorded on the exterior. These bags are kept sealed until arriving at the Fair Congo (‘Origins’) processing facility where it is opened in front of four agents from the Ministry of Mines and weight is verified. Post smelting and assay, the gold now in ingot form are placed into new tamper-evident bags which will only be opened by the receiving client after export. All chain of custody data is uploaded into the Consensas® platform and made available to each client.

Traceability

Material traceability from Fair Congo (‘Origins’) is verified on multiple levels. As discussed above, all of the due diligence documentation and chain of custody verification steps come together to ensure material can be traced to its source. Fair Congo (‘Origins’) however takes it one step further by cataloging spectrograph or XRF ore sample reports during the initial and follow up inspections to compare to material brought to our processing facility. This allows us to verify material provenance through traditional documentation measures as well as through enhanced XRF analysis, using the same technology used by most of our downstream.

AML/CFT

Gold traceability is only half of the compliance equation, and often the easiest. One of the greatest assets Fair Congo (‘Origins’) has is its parent company, a former USG contractor specializing in financial fraud investigations, US banking regulations and government asset management with over $2.5 billion in public and private assets managed. Understanding the need for financial transparency, especially for publicly traded companies, all payments from our clients are managed through our US accounts with JP Morgan Chase. Not only does this provide an arms-length transaction to a fragile state banking system making it easier to manage a financial audit, it keeps the transaction within the banking family of largest LBMA clearing house. Fair Congo (‘Origins’) has a local banking partner, Trust Merchant Bank, FATCA compliant, which is co-investing into mining communities with Fair Congo (‘Origins’) to broaden its mobile money platform. While not yet in operation, this platform will allow a complete digital trail of all funds paid all the way to the miner. Meanwhile, Fair Congo (‘Origins’) has set up cooperative subaccounts where they can monitor all transactions. Each supply chain participant undergoes an extensive risk analysis beyond that of the KYC to mitigate risks of all illicit activity, primarily money laundering.


For more detailed information regarding Fair Congo’s due diligence measures please contact us or visit the following links:

Fair Congo – OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected & High-Risk Areas

Fair Congo – OECD – Practical Actions for Companies to Identify & Address the Worst Forms of Child Labor in Mineral Supply Chains

Fair Congo – Fair Trade defined

Fair Congo – Facts & Questions


In addition to OECD guidelines and our 10 principles of fair trade, the parent and implementing Company, Chambers Federation, is a signatory to the UN Global Compact[8] (click here). More detailed information regarding the Company’s integration of these ten principles as well as their correlation to the United Nations SDGs please visit our latest ‘Communication On Progress’ listed on the UN Global Compact site by clicking here.

*The Fair Congo due diligence standards combine the most innovative methods being implemented by the various development agencies working on gold traceability in the region. It is not our intention to ‘reinvent the wheel’ but it is our intention to design a robust yet simple program that can scale to meet the international needs of the ASM market.
*Please note that during the course of implementation of these due diligence measures the Company may adapt some of the measures to suite the realities on the ground while still abiding to OECD guidelines. However, no changes will be made without review and discussion with the Company’s development stakeholders.