YEAR 2015 MSA Ltd (Minerals Supply Africa Ltd) DUE DILIGENCE ANNUAL REPORT
This Due diligence for Responsible Supply Chain of Minerals from Conflict –Affected
and High –Risk Areas report for MSA Ltd (MINERALS SUPPLY AFRICA Ltd) covers the
reporting period from January 1st to December 31st, 2015.
1. MSA company overview
Minerals Supply Africa (MSA) is one of the largest minerals trading company in
Rwanda. The company has been established in 2008 and is dealing in
Procurement, Processing and Exporting of Cassiterite (Tin), Coltan (Tantalum)
and Wolfram (Tungsten) known as 3T minerals. The company is wholly owned
by CRONIMET Central Africa AG (CCA).
2. Minerals supply chain
The company buys minerals from mining cooperatives, mining companies and
small minerals traders (comptoirs) registered and operating in Rwanda .The
Company provides financial supports and technical advices to miners in order to
increase the mining production of Rwanda and contribute significantly to the
development of the country.
MSA sources for today around 110 artisanal mining companies / cooperatives
suppliers scattered in all provinces of Rwanda.
3. Due diligence
MSA has appointed a Due Diligence Team which makes visits to its suppliers’ mines as
requested by the OECD Model Supply Chain Policy and Due Diligence Guidance for
OECD responsible Global Supply chains of Minerals from Conflict-Affected and High
Risk Areas.
MSA buys minerals only from mining cooperative, mining companies and small minerals
traders which have mining operations in Rwanda. For this reason, when the supplier
brings minerals to MSA, he has to submit a legal mining permit from Rwanda Geology
and Mine department (GMD), a company registration certificate from Rwanda
Development Board (RDB), original certificate registration at Rwanda Revenue
Authority (RRA) showing the company Tin Number, a minerals transport log sheet
indicating which mine the minerals are coming from, the type of minerals (Coltan,
Cassiterite or wolfram), the weights of minerals bags, the plate number and driver of the
vehicle and the route he has used; all minerals sold to MSA are iTSCi tagged.
These instructions are available at Stocks and Procurement Department Office; English
and Kinyarwanda language versions are available. At the same time, the supplier is
given by MSA a copy of OECD Due diligence guidelines translated in local language
Kinyarwanda or English version for one who prefers it.
As MSA is working in Great Lakes Region area, neighboring DRC where there are still
active illegal armed groups, the company has put in place a structure to conduct Due
diligence activities following prioritized risk assessment to avoid conflict minerals to
enter in the supply chain.
Risk Assessment in the Minerals supply Chain
i.
iTSCi listed companies for due diligence reinforcement and incident opened by
iTSCi on particular case (production reported by the company which seems to
be higher than mining activities on site, misuse of tags and log books , stolen
tags, selling minerals of suspicious origin related to conflict or high risk area).
MSA own risk assessment: surge in production compared to regular monthly
company’s supply or MSA known company production baseline.
Confusion cases like companies which have been suspended by Geology and
Mine Department and which resume supplying minerals.
ii.
iii.
When a risk is identified from one of the above cases, MSA takes mitigation measures
to ensure responsible supply of minerals.
Those are:



Communication with the supplier.
Meeting with the supplier
Mine visit
When MSA is not satisfied by the findings from its investigations, it asks for
explanation through a letter written to the supplier asking for more information on
supplied production; the supplier has to reply within a deadline period of fifteen (15)
days from the date on which he has received the letter. In case the supplier does not
comply with those requirements or refuses to communicate back, MSA suspends
temporarily working with this supplier until the issue is solved.
4. MSA Due diligence activities design

MSA Due diligence Staff
The Company Management has appointed a team in charge of due diligence
activities on full time basis; MSA has provided to the team all means to do their
job: transport, air time and accommodation for mine visits located far from Kigali
etc...
A senior Geologist has been hired by the company in May 2013 to reinforce the
due diligence team.

Monthly Due diligence meeting
The company Deputy CEO holds a meeting, at the beginning of the month, with
all staff involved in due diligence in order to evaluate what has been in the
previous month, find together solutions to encountered difficulties related to
conducted due diligence activities and talk about due diligence activities
planned during the coming month.
Special due diligence meetings can be hold during the month depending on
specific raised risk assessment related to due diligence in minerals supplies
chain or minerals traceability.

Analysis of mining cooperative or mining company monthly minerals
production record.
MSA Minerals Stock Department sends to MSA Due diligence team every month
minerals supplied production from, mining company and small minerals traders
in order to do analysis of monthly supplied production from each supplier and
detect any bias related to known supplier’s baseline production; this may be
noticeable surge or depletion in relation with previous month’s supply; such
cases are investigated during due diligence mine visit.
 Follow up of iTSCi monthly report of listed companies for due diligence
reinforcement for MSA suppliers.

Incident reports on possible anomalies in minerals traceability chain by iTSCi
and other institutions, stolen tags for example.




Verbal communication with the supplier when a risk is identified.
Writing to the supplier about identified risk.
Meeting with the supplier when a risk is identified.
Mine visit to the site when a risk has been identified.

Sharing the results of meetings and mine visits with, first MSA other
Departments and MSA stakeholders: Minerals suppliers, iTSCi and GMD.
5. Summary of MSA Risk management plan to avoid minerals from conflictaffected and high risk areas entering in the supply chain.
SN Due diligence
risk assessment
1
Untagged
minerals
2
Unknown origin:
Tagged minerals
without minerals
transport sheet
showing route
from mining site in
Rwanda to MSA,
3
Illegal company:
no GMD mining
permit , no
company
registration
certificate by
Rwanda
Development
Board (RDB) , no
registration
certificate at
Rwanda Revenue
Authority (RRA)
showing company
TIN number
4
Suspended
company by GMD
for any reason
Due diligence measure to
perform
Not buying
5
MSA Due
diligence
team mine
visit
Company listed by
iTSCi for due
diligence
reinforcement in
his monthly report,
after mine visit
Not buying
Mitigation measures to
take
None, refused minerals and
inform GMD / iTSCi.
None refused minerals and
inform GMD / iTSCi.
Not buying
None, refused minerals
Not buying
None, refused minerals
Recorded
production
not matching
with realities
on ground
(small
number of
Writing explanation letter to
company Management with
a deadline to reply within a
period of fifteen (15) days.
workers, low
mining
activities
compare to
production
etc…)
Closed
mining site
6
7
New supplier to
MSA
MSA own risk
assessment:
Surge in monthly
production
compare to
previous supply or
MSA known
company month
production
baseline
MSA Due
diligence
team mine
visit
MSA Due
diligence
team mine
visit
Stopping buying from the
company until the site is
reopened.
Recorded
production
not matching
with realities
on ground
(small
number of
workers, low
mining
activities
compared to
production
etc…)
Closed
mining site
Writing explanation letter to
company Management with
a deadline to reply within a
period of fifteen days.
Recorded
production
not matching
with realities
on ground
(small
number of
workers, low
mining
activities
compare to
production
etc…)
Writing explanation letter to
company Management with
a deadline to reply within a
period of fifteen days.
Stop buying
Closed
mining site
8
9
10
Confusing
situation: company
supplying minerals
when already
suspended by
GMD or when
iTSCi has reduced
the number of tags
after mine visit
( smaller mining
operation than
previous visit)
Whistle blowing /
reports from
various institutions
(UN group of
Experts on DRC,
Civil Society,
NGO’s or
individuals on
minerals
traceability
irregularities.
Miners working
conditions
MSA team mine visit
Stopping buying from the
company until the site is
reopened and gets minerals
tags.
-Writing letter to the
company Management to
ask explanation on high
supplied volume of
production.
-Sharing information with
iTSCi and GMD for more
clarifications.
Cross checking the
information through other
people / reports on these
allegations by :
-communicating verbally /
writing with the supplier.
-Field mine visit.
Reacting according to the
findings of the due diligence
action taken: -verbal or
written explanations to the
supplier.
-suspension of
buying minerals from the
supplier in serious
breaching of minerals
traceability regulations.
Child labor ( mine worker
under 18 years old)
Temporarily suspend to buy
minerals until the issue is
solved.
Personnel Protection
Equipment (PPE): overalls,
rain boots, helmets etc…)
Asking the company to
provide PPE to all his mine
workers.
Working in high risk mine
safety conditions: unstable
high walls, none supported
tunnels and mine shafts,
hanging unstable rocks.
Verbal warning to the
company and ask to make
the mine safer.
Mine workers not affiliated to
insurance company
Verbal warning to the
company on issue and
asking to affiliate his
workers as soon as
possible.
11
Environment
Destroying environment when
mining (washing in streams,
cutting trees, land
degradation etc…)
Verbal warning to the
company and asking to
remediate to the situation.
12
Small minerals
buyers supplying
to MSA
(comptoir)
Visiting comptoirs at their
working place to check if they
have :
 Ministry of trade permit
to buy minerals in
Rwanda
 Company registration
by RDB
Not buying from
unauthorized and none
registered comptoir.





Types of paid taxes
Asking on iTSCi
membership of the
“comptoirs”
Employees working
conditions (no child
labor, health and
safety etc…)
If not done: Warning the
company to remediate to
the situation.
If the “comptoir” has a
conflict minerals policy
and a Risk
management plan
documents.
Asking the “comptoir”
to give to MSA copies
of Due diligence mine
visit reports on
“comptoirs” suppliers.
If not done, writing letter to
the “comptoir” asking him to
do Due diligence to his
suppliers and give copies of
reports to MSA within one
month deadline period.
“Comptoir”: local minerals trader
6. Independent third party audit
SYNERGY Company audited MSA from 07 to 09 July Year 2014 for the period
from July 2013 to July 2014 under consultancy of ITRI; audit report has been
already released and no major incident was raised by SYNERGY.
7. Participation to local and international stakeholder discussions
-MSA staff in charge of Due diligence has participated to the OECD workshop
organized in Kigali from 31st July to 1st August 2015 by OECD Staff in partnership
with the Government of Rwanda on “OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk
Areas”..
-Two MSA staffs , one from “Due diligence Department” and MSA –GMD
Liaison Officer have participated to ICGLR1 workshop on “Regional Certification
Mechanism (RCM) and ICGL Minerals Export Certificate” organized conjointly by
Partnership Canada (PAC), ICGLR Certification Unit and GMD from 29th
September to 30th September 2015.
-MSA CEO, David Bensusan participated to OECD meeting in Paris in 2012,
MSA CEO and MSA Deputy CEO participated to OECD meeting hold in Kigali in
2013.
MSA CEO has also attended OECD meeting on 3 – 5 November 2014 in
Kinshasa.
MSA CEO and Deputy CEO have also attended OECD meeting on 4 – 6 May
2015 in Paris.
8. Monitoring MSA suppliers
-MSA compiles an excel sheet of monthly supplied minerals production for each
supplier for each item of the 3T’s minerals; this enables easy follow up and
monitoring of the production of each supplier.
-MSA Due diligence team does, on regular basis, field mine visits and produces
mine visits reports shared with MSA stakeholders (iTSCi, GMD, Suppliers etc...).
1
ICGLR: International Conference on Great Lakes Region; this institution has a Minerals Certification Unit
responsible for minerals traceability designed to work in alignment with iTSCi.
MSA Management and MSA Due Diligence team hold meetings and
communicate regularly with suppliers by phone calls and written
communications.
9. Sharing data and information on supply chain with MSA customers and
protection of MSA supplier’s business information.
 Reports of monthly minerals purchases volumes are send to different
MSA Departments (Due diligence, Marketing and Finance), Rwanda
Geology and Mines Department (GMD) at the Ministry of Natural
Resources, and to iTSCi local office in Kigali.
 Copies of monthly reports of due diligence mine visits done by MSA Due
diligence team are transmitted to iTSCI local Office in Kigali for mining
companies listed by iTSCi for further discussions.
 Due diligence mine visits reports are published on MSA web site with
confidential information blanked, the link is
http://www.msaltd.net/media/news
 The Deputy CEO holds every month a Due diligence meeting with MSA
Due diligence team, Marketing Department and Administration
Department; the conclusions of the meeting are communicated to other
MSA Departments; minutes of the meeting are filed.
 Every new supplier to MSA receives a copy of OECD guidance document
translated in Kinyarwanda; he signs a proof of reception form which is
filed.
 Any other incident or suspicious case is shared with other stakeholders
(stolen tags, confusing cases etc…)
10. Analysis of 2015 Due diligence actions and mitigation measures taken.

All suppliers to MSA brought tagged minerals from mining companies /
cooperatives registered at Rwanda Development Board (RDB), and have
mining licenses issued by Rwanda Geology and Mining Department
(GMD); all suppliers operate on Rwanda territory.

MSA Due diligence team has designed a due diligence template for
mining companies and cooperative and for “comptoirs” to use during
company mine visit. Since October 2014, MSA Due diligence team is
using iTSCi production plausibility template.
 The due diligence team does regular mine visits according to a planned
schedule based in first priority to iTSCi listed companies for due diligence
reinforcement, MSA own risk assessment related to irregularities in
supply like surge in production or confusing situations.
 The list of the mining companies to be visited is communicated to MSA
Deputy CEO every Friday for the following week with explanation on
reasons motivating those due diligence mine visits.
 Due diligence mine visit reports are transmitted to the Deputy CEO by email with copies to Geology and Mine Department (GMD) and iTSCi; the
major findings of these reports are also shared with other MSA
Department (Stocks / Minerals Procurement, Operations and Marketing).
 During Year 2015: In addition to regular check and analysis of Chain of
Custody documents like MSA monthly supply production records for
each supplier, ITRI / iTSCi Minerals Traceability documents issued to
each supplier (tags and log book sheets), iTSCi Team monthly reports
for due diligence recommendations on visited sites, UN group of Experts
on DRC reports, Rwanda Geology and Mines Departments / Mines
Inspection Unit visits reports related to negative issues on ongoing
mining operations ( suspension of some mine sites), MSA Due diligence
has visited twelve ( 12 ) new companies apart from companies visited in
previous Year of 2014 where due diligence actions were mostly
monitoring of the progress of supplied production.

In 2015, MSA stopped buying temporarily minerals from eight (8)
suppliers for serious irregularities about minerals traceability issues.

In 2015, MSA wrote explanation letters to seven (7) supplies asking
clarification on surge in production supplied and letters to Three (3)
minerals traders “comptoirs” suppliers reminding them to send copies of
due diligence mine visit done on mines sites of their suppliers; one
comptoir reacted positively and sent copies of Due diligence to MSA and
two others stopped supplying minerals to MSA. Although all the mining
suppliers to which MSA sent letters did not reply, three of them got their
minerals tags and logbooks removed by ITRI / iTSCi because the mining
conditions on site did not improve during the following mine visit by ITRI;
two companies were later removed from the due diligence list because
there was improvement on their mining sites and one company stopped
supplying minerals to MSA.
11. Summary of detailed Due diligence actions (mine visits / meetings and
communication by writing) and mitigation measures taken during Year
2015.
This part of the report refers to due diligence action and mitigation measures
taken for every individual supplier mentioned in Section 10 of this report. It
contains confidential information such as suppliers’ names and business
relations / communications with them which could not be made public;
nevertheless the detailed report containing this section is available at MSA Office
and is ready for consultation following a request addressed to MSA
Management.