Details about the New Bugurama Mining Company (NBM)

Hi. We talk a lot about the hard- and software here.

And not a lot about mining. We do not even have a category for that. I wonder if we could change that a bit.

In the blog, I read that New Bugurama Mining Company (NBM) has been certified by the International Conference of the Great Lakes Region (ICGLR) in 2013. I tried to find this report. And materials and also more on the whole process itself (What do they do with all the water? Is it just for washing? Is the water afterwards contaminated or could it be reused? How do “Special Metals Resources” and “Wolfram Bergbau und Hütten AG (WBH)” support the project? What happend till 2016?)

I found ICGLR reports and publications, but no reports about the NBM mine. Can someone help me pointing out the right files? Maybe it’s included somewhere else.


Update I, these are some texts I found.
Business and Technical Management of Small-Scale Mineral Producers in Rwanda, Capacity Assessment Report & Training and Skill Transfer Recommendations (Mineral processing, SHE questions are discussed here)

NBM ANNUAL DUE DILIGENCE REPORT 2015 (Looks like the “offical” NBM docuemnt for 2015)

Update II (Links from @emmy, Thanks!):

Implementing Certified Trading Chains (CTC) in Rwanda For more Background

Greening ICT supply chains – Survey on conflict minerals due diligence initiatives Supply chains and natural resources


Perhaps @anon2751513 or @anon14889930 could help? Or @emmy?

Yes, I think Laura would be the right person, she is the author of the blog post. I think it would be nice if documents that describe the supply chain (and improvements there) would get a bit more publicity. Currently it looks like there is a very old document and some new changes, but nothing is documented expect the things that can be found in the blog.

And thank you @fp1_wo_sw_updates for opening this topic. Yes, there should be more talk about mining and all the stuff Fairphone stands for.


I agree, this is a hugely important topic and actually the reason that the entire Fairphone project originally got started.

@fp1_wo_sw_updates: there’s not a huge amount of information on that mine specifically. I also found the 2014 due diligence report here, so that you can compare the two reports from 2014 and 2015 and see what has improved/changed over the course of a year.

For a more general overview of how mining certifications in Rwanda got started, take a look at this report. I know it’s from 2011 and may seem outdated, but it gives a lot of useful background information on the whole mining situation in Rwanda and how the whole cooperation between the German BGR, GIZ, and the ICGLR got started. They created something called Certified Trading Chains (CTC) and started with pilot projects in Rwanda that have now been expanded to more mines in Rwanda and also pilot projects in DRC. The plan was always that the BGR would be involved in the pilot phase and that the CTC would eventually turn into an ICGRL Regional Certification Mechanism that the ICGLR could manage by themselves. I know that for a long time the project struggled to move on because they had trouble finding an independent third-party auditor that was both interested and met their expectations - though this was back in 2013, so I assume that at this point they have found someone. I haven’t followed the project too closely anymore since the pilot phase in 2013 (not because I’m not interested anymore, but because my own work has changed somewhat and time is, unfortunately, limited…).


Here’s one more report from 2012 that gives a very good overview of the different initiatives that exist to make ICT supply chains greener/fairer in terms of the natural resources they use. It also provides a good summary of the legal situation (for example the California Supply Chain Transparency Act and the Dodd-Frank Act).

The EU is still working on getting its own conflict mineral legislation underway, an amended draft is currently in the Trialogue Phase after the original draft was rejected by the European Parliament last May:

“On 20 May 2015, the European Parliament voted to reject the proposal of
the European Commission and the Parliament’s Committee on International
Trade (INTA) for a voluntary system of self-certification for importers
of tin, tantalum, tungsten and gold (“conflict minerals”) into the
European Union. The amended draft regulation marks a significant
departure from the proposed draft regulation by calling for mandatory
compliance by all importers of conflict minerals from conflict-affected
and high-risk areas around the world. Instead of the voluntary system
originally proposed, members of the European Parliament called for a
mandatory system of due diligence for smelters and refiners. Supporters
argue that due diligence provides a method for companies to ensure that
their purchasing practices do not fund armed conflict and human rights
violations in areas that are prone to violence and that lack adequate
protections from their governments.” (Source - emphasis added)

You can find more information on the current status here.


Thanks @emmy, I added your links to the article as well.

I’m still reading to find out more about the water use in 3TG projects. I guess the more one “optimizes” the efficiency of the mines the more chemicals and energy may be needed. I read that the mines are not running very efficient and that a lot of materials are lost with the waste water. I wonder how they plan to develop all this with the people at the site.

Also it’s interesting to see that Germany is so involved in this. Is that strategic involvement for resources? Or just a coincidence? Mostly it’s under the umbrella of the BGR/Federal Ministry for Economic Affairs and Energy (BMWi), not as expected under the GIZ/The German Federal Ministry for Economic Cooperation and Development (BMZ).

Mineral Certification in Rwanda (Includes a downloads sections with papers)

It would be nice see the “Process Certification Schemes” explained here. I wonder if they work as expected. ((Update: This last sentence was rewritten for clarification)).

What do you mean by that exactly?

Update: In terms of working as expected, here’s a report on the Impact of the Dodd-Frank Act and corresponding certification initiatives and their impacts on Congolese Livelihoods (Note: I have only briefly skimmed the report and not read it in full, but at first glance it seems worthwhile reading.)

Yes, this is strategic involvement. I guess you have already seen this page at the BMWi? I have been at several congresses and other gatherings where people talked about those actions - as far as I understand, it was never meant as a nice way to support developing countries or to ‘save our environment’.
It’s purpose is to make sure, German industries find available to them all natural resources they might need. For example, DERA (Deutsche Rohstoffagentur), which was founded in cooperation with BGR, aims to provide advice to corporations, especially to SMEs. There was also the idea of ‘resource partnerships’ (Rohstoffpartnerschaften) between German corporations and foreign mining operations. In these, technology would be traded against access to natural resources.
The background is that it was thought impossible for SME’s or even larger corporations to ensure access to every single resource that might be hidden in their product, so a new framework was established to gather all those enquiries.

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I agree that there’s certainly a certain degree of strategic interest, though from my understanding, the certified trading chains project was not solely done out of strategic interest. It did also involve some genuine interest in improving the social and environmental situation in the artisanal mining context. I guess you can argue about what the dominant motivation was, but I believe it was a mixture of both.

The Rohstoffpartnerschaften technically exist (last I knew there were 3 or 4 partner countries and 1 or 2 more potential partners in discussion), but they are viewed quite critically, both by NGOs (because countries with fairly obvious human rights abuses have been chosen as partners) and companies (because the government has basically said: we only provide a framework for partnership, but you’re the ones who have to actually fill it with content/activities/etc.)

As for @fp1_wo_sw_updates’ question why Germany is so involved in this: Germany’s economy is hugely dependent upon its exports, many of which are in the high-tech sector. Without access to the necessary natural resources, the future of the country’s economy is very much at risk. As a result, the government has significant interest in ensuring adequate access to so-called critical/economic-strategic resources (kritische/wirtschaftsstrategische Rohstoffe), which means that they do invest quite a bit of time in effort in various different strategies to securing this access. Among those are international projects like certified trading chains, resource partnerships, etc., but also domestic projects like improving the circular economy by increasing waste collection rates, improving recycling technologies, etc., as well as developing new technologies and regulatory standards for sustainable/ecological product design, consulting with SMEs on improving their material and resource efficiency and so on.

It’s hard for me to judge if Germany is doing more/less/the same as other western European countries, since I know its activities better than those of any other country. My guess is that the Scandinavian countries and the Netherlands may be doing more or a similar amount, while other EU countries might be doing less, but I honestly have no real idea. Anyone else know?

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You’re right, all of the mentioned projects and actions might not be based on strategic interest only, but there may also be social and/or environmental part in it. I didn’t mean to say that it is all a bad thing this is initiated by BMWi. I would guess it depends on the specific project whether those issues will also be accounted for or not and what the overall outcome will be. But the inital momentum was not driven by feelings of ‘making the world a better place’, which is the answer to why it wasn’t the BMZ getting active on this, I guess.

On the topic of supply chains and mining, here’s an interesting and very current analysis of how tech/electronics companies should likely expect an increase in NGO criticism, media attention and possible litigation with regard to the issue of forced/child labor in cobalt mining. Note that this comes from an attorney who advises global corporations on how to deal with issues in their supply chains, not from an NGO, meaning that some of the bigger names might at some point begin listening.